Modern Slavery Statement

At Pallman, we are committed to conducting business responsibly and have a zero tolerance approach to all forms of modern slavery across our operations. We are committed to ensuring everyone who works for Pallman Ltd does so in an environment where fundamental human rights are upheld, and we expect anyone that we do business with also upholds these principles as well. We are continuously working to improve our operations in practice reflect that expectation.

1. Our BusinessPallman is an aspiring, innovative and dynamic company that manufacture and supply a comprehensive range of mechanical and industrial engineering components of Air Filters, Fuel Filter, Hydraulic Filters, Liquid Filters, Oil Filters, and any other Filtration and Accessories, and Undercarriage Components and Tracks to Agricultural, Aviation, Construction, Defence, Forestry, Heavy Duty Vehicles, Industrial Equipment, Marine, Oil and Gas and Power Generation Industries, For Highway Trucks and Buses, Off Highway Trucks and Earth Moving Equipment, Industrial Processing Equipment, Renewable Energy, Power Generation and Wind Turbine markets.

2. Our Supply ChainPallman Ltd understands the level of risk posed by its suppliers in a modern slavery context. The majority of suppliers are based in the countries in which they are based are shown in the table below:

3. Our ValuesPallman have introduced a focus on Kaizen. This is a concept that refers to ongoing and continuous improvement working culture. The idea is that every small improvement adds up and supports a safer and more successful business in all respects. This has been visible within the approach taken by Pallman Ltd this year to improve how we identify and address risks within our supply chain and within our work force.

4. Focus on WellbeingAs with many businesses and people around the world, the past two years have presented unique challenges for Pallman and its staff. During this challenging period, Pallman Ltd recognised the mental strain and vulnerability people have faced during the uncertainty presented by Covid-19. We prioritised the welfare and safety of our colleagues by supporting flexible working arrangements and encouraging working from home wherever appropriate. This was accompanied with mental health awareness and resilience training, as well as presenting creative suggestions as to how to stay connected with colleagues while working from home and the roll out of a quarterly anonymous staff engagement surveys have been distributed to all staff members.

5. Our Governance and PoliciesPallman Ltd commitment to human rights and the eradication of modern slavery is shared throughout the business. Our policies support Pallman Ltd in mitigating risks, both within our business and our supply chain. Responsibility for managing these policies varies policy to policy. However, our annual modern slavery statement is ultimately approved by our board of directors and signed off by our Managing Director following a cross departmental review.

• Anti-Modern Slavery and Human Trafficking Policy

This statement is reviewed and updated each year, with an updated policy last issued during May 2019. The policy is an internal document that sets out the expectations we, as a business, have in relation to our zero tolerance approach to modern slavery and human trafficking. It applies to all individuals working in Pallman Ltd at all levels and grades (whether they are permanent, fixed term, or temporary) and all of Pallman’s subsidiaries.

• Whistleblowing Policy

This sets out how Pallman Ltd is committed to prompting high standards of openness, probity and accountability. Our whistleblowing policy is available for all staff to view on our intranet and is communicated annually. It sets out how complaints can be made, including the ability for these to be made anonymously.

• Pallman Ltd Code of Ethics Policy

This sets out Pallman Ltd expectations on how all colleagues are expected to behave. Colleagues receive a copy of it when joining our business, and an up to date version is maintained on our intranet. This is maintained by our HR department. Amongst other things, it requires colleagues to treat each other fairly and not to discriminate on any grounds, to always treat those who raise concerns of misconduct or malpractice in accordance with Pallman Ltd whistleblowing procedures and prohibits doing business with countries subject to trade restrictions, embargoes or sanctions. Failure to comply with this may result in disciplinary action.

• HR Recruitment and Selection Policy

This policy is managed by HR and sets out Pallman Ltd commitment to equality of opportunity in recruitment, selection, promotion and all areas of employment. Pallman Ltd aims to attract high calibre colleagues by ensuring that our recruitment and selection processes are effective, systematic and equitable. We recognise that colleagues are critical to our success, and the utmost importance is placed on ensuring that a consistent, fair and professional approach is applied throughout the recruitment and selection process. This enables us to employ the best people who possess the necessary skills and attributes, and who demonstrate the behaviours essential to fulfil our strategic ambitions.

Pallman Ltd will avoid unlawful discrimination in all aspects of employment including recruitment, promotion, opportunities for training, pay and benefits, discipline and selection for redundancy.

6. Risk Management and Due DiligencePallman Ltd commitment to human rights and the eradication of modern slavery is shared throughout the business. Our policies support Pallman Ltd in mitigating risks, both within our business and our supply chain. Responsibility for managing these policies varies policy to policy. However, our annual modern slavery statement is ultimately approved by our board of directors and signed off by our Managing Director, following a cross departmental review.

 Part A: Our People

• Recruitment and Fair Pay

To manage potential risks in relation to onboarding our employees, we ensure all our direct hires are subject to standard “right to work” checks, DBS checks and depending on the nature of the working permits, we may audit these from time to time. We have focused on staff wellbeing and taken steps to ensure all our staff are paid fairly.

• Changes to our recruitment processes

During the past year, our HR department has been working to develop a direct hire talent acquisition model to offer in house end to end recruitment services for our business, and the use of external recruitment agencies will be centralised and managed by a specific Talent Acquisition Term. It is anticipated that this will have many benefits for Pallman Ltd, including enabling more control and procedures around how staff members will join our business. This will also give more centralised control of ensuring all external suppliers of workers to Pallman Ltd have appropriate terms in place to protect Pallman Ltd, and any temporary or contract hire relationships.

• Training and awareness

Our staff play a key role in mitigating risk(s) both within our business and supply chain, and we recognise that appropriate training and communication is essential. Our Learning and Development Team have been working throughout 2019 to build on our existing training and to launch a new modern slavery training module to all staff to ensure year on year improvement in terms of our commitment to identify the risks of, and remove all instances of, modern slavery, human trafficking, and exploitation.

• Communication

Pallman Ltd recognises communication is an essential part of raising modern slavery awareness within our business. All of Pallman Ltd policies documents are made available either via internal communication channels as well as on our intranet. This statement will be distributed to all staff via internal communication channels following board approval and will be published on Pallman Ltd website.

We recognise communication must be both ways, which is why during the past financial year, quarterly anonymous staff engagement surveys have been distributed to all staff members. We believe anonymous, companywide surveys are a useful tool for understanding the wellbeing needs of all colleagues and to better recognised gaps in support they feel is needed.

• Whistleblowing Hotline

In May 2020, Pallman Ltd introduced a whistleblowing hotline to help create a culture where staff feel confident in raising concerns safely. A company-wide memorandum was emailed to all staff in at the beginning of FY2020/21 together with Pallman Ltd whistleblowing policy and information on the hotline, so that all staff are clear that there is a hotline service provided by an independent, external whistleblowing service provider that can be contacted. Once reports are made, responsible colleagues allocated to this are notified, so that if a report is received an investigation can be conducted and a response given to colleagues who have raised concerns within a specified timeframe.

Part B: Our Suppliers

Our standard supplier terms and conditions require compliance with all applicable law, and reference compliance with Pallman Ltd requirements with regard to modern slavery. We reserve the right to terminate immediately for breaches of these clauses. While our terms may vary between suppliers, our Legal department maintains a guidance note on changes we are able to accept to ensure essential clauses are not removed from our standard terms unless appropriate in that particular instance.

During the past year, Pallman Ltd have been investigating ways it can improve its supplier onboarding and supply chain risk management processes to ensure our Procurement team have access to support and are able to access up to date supplier information and ensuring compliance with Pallman Ltd onboarding requirements across the board. This review is ongoing, but we recognise Pallman Ltd needs to focus on:

• implementing more robust risk-profiling by suppliers when onboarding new suppliers.
• re-thinking what we require of suppliers based on the risk profile.
• improving Pallman Ltd supplier vetting processes.
• improving the way, we monitor supplier risk throughout the duration of the relationship; and
• conducting more audits of suppliers.

 
7. Measuring and Monitoring ProgressOur modern slavery statement will be reviewed annually by colleagues from Legal, HR, Risk and/or Procurement prior to it receiving board approval. This is done to ensure we are meeting our ethical and legal obligations and providing up to date information within Pallman Ltd statement. This annual review is a great opportunity for us to see how we have performed over preceding financial year, and how we can look to improve in the current year.Our performance during the financial year ended September 2020 was assessed by examining the following key performance indicators:

• Number of Pallman Ltd staff that have undertaken awareness training.
• Number of modern slavery complaints made to our whistleblowing hotline.
• Evidence or suggestion of any material breaches or reasons for concern.

Our goals for the financial year ending 30 May 2024:

• Communication: Ensure the Modern Slavery statement is communicated to all staff members as well as being uploaded to Pallman Ltd website.
• Training: Ensure new training is delivered to all Pallman Ltd staff and ensure this is communicated and pushed to maximise staff engagement and increase the number of Pallman Ltd staff who undertake this training in the next financial year.
• Whistleblowing: Maintain our high level of performance in relation to investigating all reports made to our external, independent, whistleblowing service provider within the target timeframes.
• KPIs: Improve on our KPIs/performance year on year and develop new KPIs. 

 
8. Board approvals
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved by our Board of Directors on 12th of May 2019.