Introduction
This statement is made by Wacker Neuson Ltd., Stafford (“Wacker Neuson UK”) pursuant to Section 54 (1) of the Modern Slavery Act 2015 and sets out the steps the company is taking to minimize the risk of modern slavery and human trafficking taking place within its organization and supply chains. It has been approved by Wacker Neuson UK’s board of directors on 31 May 2023
Wacker Neuson UK has a zero tolerance to any form of modern slavery. We are committed to integrity and honesty as well as the commitment to consistent compliance with legal and regulatory requirements. Both our employees as well as our suppliers are required to adhere to this standard.
Structure and Business
Wacker Neuson UK is part of Wacker Neuson Group, an international family of companies and a leading manufacturer of light and compact construction equipment. The Group is headed by the executive board of Wacker Neuson SE, a European stock corporation (Societas Europaea) with its headquarters in Munich, Germany. It operates as a management holding company with a central management structure and is responsible for strategic Group governance functions. It directly or indirectly holds shares in 45 affiliates. The Group offers its customers a broad portfolio of products, a wide range of services and an efficient spare parts service. The product brands Wacker Neuson, Kramer and Weidemann belong to the Wacker Neuson Group. Wacker Neuson is the partner of choice among professional users in construction, gardening, landscaping and agriculture, as well as among municipal bodies and companies in industries such as recycling, energy and rail transport
The Group employs around 6,300 employees worldwide, the headquarters are in Munich, Germany. There are approximately 140 sales and service locations worldwide and production facilities in Germany, Austria, USA, Serbia and China. Wacker Neuson UK operates as a sales and service affiliate of the Group. It distributes Wacker Neuson Groups´ range of products and spare parts via a dealer network throughout the United Kingdom and Ireland. In addition to is facilities in Stafford, one of the Groups dedicated research and development centres is located at Wacker Neuson UK’s Leicester facilities. Approximately 70 people are based in the UK.
Supply Chain
Within the UK, Wacker Neuson UK maintains relationships with local suppliers on a smaller scale, while all products and spare parts are sourced from other Wacker Neuson Group companies. For the engineering and production of its machines and equipment, the Group sources pre-manufactured parts, components and raw materials for its production plants via a global network of suppliers.
Policies
We operate a number of group wide or local policies to ensure we are conducting our business in an ethical and transparent way. These include:
- Code of Conduct
All of our employees are required to comply with the company’s code of conduct which sets out the principles of company ethics and the daily conduct expected in the workplace and also provides guidelines on preventing corruption.
Each employee of Wacker Neuson UK are required to sign a statement confirming that they have received, read and understood the Code of Conduct.
The most recent version of the Code of Conduct can be found online at wackerneusongroup.com/en/group/compliance
- Supplier Code of Conduct
Wacker Neuson Group expects all its suppliers to adhere to the ‘Code of Conduct for Wacker Neuson Group Suppliers’, compliance with this code is the basis for our continued relationship with our suppliers.
This includes undertaking all suppliers to comply with the ‘General Declaration of Human Rights’ of the United Nations, to support the principles of the UN Global Compact and recognise the core labour standards of the International Labour Organisation and the rights established by the Organisation for Economic Co-operation and Development.
The code of conduct specifically requests that suppliers refrain from the use of forced labour and child labour. Suppliers commit to this code by completing and signing a Declaration of Compliance.
The most recent version of the Supplier Code of Conduct can also be found online at wackerneusongroup.com/en/group/compliance
- Whistleblower System “Tell-it”
Via the external web-based whistleblower system „Tell-it " serious cases of violation or misconduct in connection with the Wacker Neuson Group such as human rights violations can be reported. The whistleblower system offers an additional line of communication, which is available both for the employees of the Wacker Neuson Group, as well as business partners, such as customers and suppliers. It can be accessed 24 hours a day from anywhere in the world and confidentially under the following link: www.bkms-system.net/wackerneuson
In light of the new German Supply Chain Due Diligence Act, a new category was added to the existing Tell-it whistleblowing system in order to be able to provide information on human rights in a more targeted manner in the future.
- Recruitment Policy and Practices
Wacker Neuson UK undertakes right to work checks for all employees recruited in the UK to ensure they have the a valid work visa if required and are of appropriate employment age. Wacker Neuson UK does not employ anyone below the legal school leaving age.
Risk Assessment
Framed by the group wide compliance management system, Wacker Neuson Group stands for a culture of responsible corporate governance through a variety of proactive compliance measures designed to specifically engage employees and suppliers. The measures are described in our policies section above.
To remain competitive in the long-term, the Group is having to work with a much more international group of suppliers than it did a few years ago. This is why the Group sourcing strategy includes countries with generally higher risks of human rights violations compared with Europe and North America. The expansion into such countries and the development of the Groups´ sourcing, sales and production structures have pushed human rights high on the Wacker Neuson Group list of priorities. Wacker Neuson Group aims at all times to protect human rights, both within in the Group´s internal organisation and throughout its supply chain.
The Group uses a non-financial risk management system to identify and assess risks arising from the Group’s business activities that could impact social and employee-related human rights. All affiliates complete a risk analysis questionnaire. In fiscal 2022, no cases of confirmed corruption were reported to the Compliance Committee by individuals in the organization. Similarly, no confirmed cases of corruption in the supply chain were reported.
Due Diligence
Our aim at all times is to protect human rights, both in our internal organisation and throughout the supply chain, and the company continually reviews its existing compliance and risk management systems with regard to the Modern Day Slavery Act 2015. In 2021 this has included starting to map our supply chain, initially focussing on our main Tier 1 suppliers.
The established Group-wide compliance management system strives to reduce the risk of human rights violations by employees in the organisation, whether on the basis of standard reporting processes, tip-offs via the whistle-blower system, or employee training and events. The protection of human rights is very much a priority in this process.
As enshrined in the Company’s Strategy 2022 and the Group’s excellence goal, the Group is committed to ensuring that it only selects suitable suppliers. As a result, the Group’s supplier audits for direct production materials focus in particular on potential new suppliers. The Supplier Development department, which is part of Quality Management, is responsible for this task. The department works independently in the different production sites and uses globally defined methods and tools to carry out audits in high-risk countries.
Supplier audits for direct production materials, known as “Supplier Potential Assessments”, are carried out on the basis of Group-wide uniform evaluation standards. The only exception here is the North American production company, which includes human rights in its own supplier quality process audit. An internal guideline containing standard assessment criteria forms the basis for the qualification of potential suppliers. The guideline focuses on factors such as freedom of assembly and exclusion of child labour. If any shortcomings are identified in a supplier’s organization, action plans are drawn up to permanently
eliminate these weaknesses. Only suppliers that meet the internal criteria will be included in the global supply network. In this way, the Group hopes to reduce the risk of human rights violations occurring in its supply chain.
In fiscal 2022, 20 audits were carried out on potential suppliers in Europe and China. Additionally,5 audits were carried out on existing suppliers in Europe and China. The audits are generally determined according to industry- or country-specific risk criteria or on an event-driven basis. In addition to quality and delivery requirements, there is an increased focus on compliance with human rights, particularly with regard to working conditions. The reviews of both groups of suppliers revealed that there were no indications of violations with regard to human rights compliance in fiscal 2022. Furthermore, no complaints or suspected cases involving violations of human rights aspects within the supply chain were reported to the Group in fiscal 2022
Within the UK, local procurement is carried out as defined at Group level. All decisions on whether to work with a UK based supplier are preceded by an appraisal of the suppliers with respect to their performance on factors like the environment, working conditions, and the protection of human rights. Local suppliers are made aware of Wacker Neuson UK’s Modern Slavery Statement and of the Group Supplier Code of Conduct. Suppliers are audited as an ongoing process to identify those organisations which are required to produce their own modern slavery statement and copies of these are obtained where appropriate. For suppliers that fall below the threshold requiring a modern slavery statement, they are issued with a declaration to confirm their commitment to combat modern slavery within their own business and supply chains.
In 2022, Wacker Neuson UK neither received complaints about violations of human rights or suspected violations of human rights in the organisation nor such complaints about suppliers with existing business relationships.
Training
Part of compliance training involves raising employees’ awareness of compliance risks and the need to respect the applicable legal regulations, which also indirectly encompass the protection of human rights. Training has taken place on the legal positions affected by the German Supply Chain Due Diligence Act and the new processes for the relevant employees and this will be rolled out in further in fiscal 2023.
Any insights resulting from the non-financial risk assessment questionnaires will be used in the coming years to implement individual risk mitigation initiatives, with particular focus on eLearning courses.
The HR Officer in the UK and members of the spare parts procurement team have attended a series of online briefings and workshops provided by the Supply Chain Sustainability School focussing specifically on modern slavery within the construction industry. A briefing document has been issued to all staff to raise awareness and ensure a better understanding of the issue. This includes information on the appropriate action to take if they encounter anything that raises concerns.
Stafford, on 31 May 2023
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Richard HARRISON
Managing Director
