Modern Slavery and Anti Human Trafficking Policy and Disclosure Statement

The purpose of the policy is to ensure that Flowmax Limited and all of its subsidiaries companies respect international principles of human rights including, but not limited to those expressed in the UN Declaration of Human Rights, United Nations Global Compact Principles and those principles contained within the UK’s Modern Slavery Act 2015.

This policy should be read alongside the SA Bias Group Code of Ethics and Anti-Corruption Policy which also apply to Flowmax companies.

This policy applies to Flowmax Limited and all of its subsidiaries.

Flowmax Limited and its subsidiaries are committed to:

  • conducting business with honesty and integrity; treating all people with dignity and respect and complying with applicable laws, regulations and treaties;
  • protecting and promoting human rights globally: no tolerance of child labour, forced labour, including prison labour, or any use of force or other forms of coercion, fraud, deception, abuse of power or other means to achieve control over another person for the purpose of exploitation;
  • complying with employment laws as well as national and international laws governing issues of supply chain management and expects those with whom Flowmax Limited and all of its subsidiaries does business to do the same;
  • taking moral and social responsibility for a zero-tolerance approach to modern slavery in all forms;
  • preventing slavery and human trafficking in all corporate activities, and ensuring, as far as the Group is able, that our supply chains are free from slavery and human trafficking;
  • continual revision of policies and standards to ensure compliance with UN Declaration of Human Rights, United Nations Global Compact Principles and those principles contained within the UK’s Modern Slavery Act 2015.

Flowmax Limited’s approach in identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations is the following:

  • Whistleblowing – we encourage all Flowmax Limited and its subsidiaries employees, to report any concerns relating to unlawful conduct, malpractice, dangers to the public or the environment, modern slavery and any other matter of a serious nature to the Compliance Officer.
  • We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to declare that they provide safe working conditions, treat workers  with dignity and respect, and act ethically and within the law in their use of labour. Any violations will lead to the termination of the business relationship.
  • Training: Flowmax Limited require all staff working in supply chain management and relevant roles to complete awareness training on how to assess the risk of slavery and human trafficking in relation to various aspects of the business, how employees can identify the signs of slavery and human trafficking and what should be done if this activity is suspected.
  • Procedures and standards are in place to ensure that practices relating to Health and Safety
Flowmax Limited forms part of the SA Bias Industries Group which Group has a reputable Social
and Ethics Committee with a well-established Social and Ethic’s Charter. A Compliance Officer, the CFO of the SA Bias Industries Group, Gerhard van Vuuren, has been appointed by the Committee for coordinating and overseeing compliance of all companies in the Group with the Social and Ethics Charter.

Flowmax Limited and all of its subsidiaries has a zero tolerance approach to modern day slavery and human trafficking, both within the Group and in the Group’s supply chain.

This statement has been approved by the Flowmax Industries Board of Directors, and will be reviewed and updated annually.

The Flowmax CEO is responsible for the administration of this policy.

Modern Slavery Statement

This Modern Slavery and Human Trafficking statement relates to actions and activities of Flowmax
Limited and its subsidiary companies during the financial year ending 31 December 2019. It sets out the Company’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains.
We all have a duty of care to be alert to risks, however small. Employees are expected to report any concerns and management to act upon them.
The Modern Slavery Act 2015 covers four activities:
Slavery – Exercising powers of ownership over a person.
Servitude – The obligation to provide services imposed by the use of coercion.
Forced or compulsory labour – Work or services exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.
Human trafficking – Arranging or facilitating the travel of another person with a view to their
This statement covers all four activities.
Flowmax Limited Business Activities
Flowmax Limited forms part of the SA Bias Industries Group based in South Africa.
Flowmax Limited is an industrial holding company comprising a group of small and medium sized
companies in the UK and The Netherlands associated with the manufacture, import and distribution of medium technology fluid handling equipment, consumables, spares and service. Each group company is managed independently and at a local level.

The Group is committed to conducting business in a professional, transparent, ethical manner and to quality assured standards. The Company and all its subsidiaries have a zero-tolerance approach to modern day slavery and human trafficking, both within the Group and in the Group’s supply chains.


How is the Modern Slavery Act 2015 relevant to Flowmax Ltd?

Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part. At a very basic level, preventing exploitation and human trafficking and protecting our workforce and reputation makes good business sense.


The Modern Slavery Act 2015 recognises the important part businesses can and should play in tackling slavery. With this in mind, we will pay close attention to:
  • Our supply chain. The Company and its subsidiaries are committed to mapping the first tier supply chain and identifying sectors at risk. We expect to be able to publish this information in the statement for the next financial year.
  • Our recruitment activities. This includes the appointment of suppliers as well as employees. New suppliers will only be approved and appointed following a due diligence process to understand their commitment to ethical business. The majority of our employees are appointed on a permanent basis, and Group companies keep the use of temporary, casual or zero hours workers to a minimum. We will fully comply with, and often exceed, UK employment legislation requirements.
  • Payment of suppliers and employees. The Group is committed to operating a fair pricing structure for suppliers and will pay in line with the agreed terms of business. All our employee rates of pay exceed the current National Minimum / Living Wage. Salaries will be reviewed on an annual basis and we will ensure employees are fairly remunerated for their contribution to the business in line with markets rates.
  • Any outsourced activities. Particularly in jurisdictions that may not have adequate safeguards. We will take a risk-based approach and seek assurance from suppliers and where appropriate verify that their activities are aligned with the objectives of the UK modern slavery legislation.

Flowmax Limited, our managers and colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.

We will:
  • Review our policies and procedures preventing exploitation and human trafficking and protecting our workforce and reputation.
  • Ensure our recruitment policy is understood by all involved in the recruitment and selection process and background / right to work checks are carried out consistently.
  • Check our supply chains.
  • Make appropriate checks on all employees, recruitment agencies, suppliers, etc. to ensure we know who is working for us.
  • Ensure we have in place an open and transparent grievance process for all staff.
  • Seek to raise awareness so that our colleagues know what we are doing to promote their welfare.
  • Make a clear statement annually setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibilities to our employees and our clients seriously.

Managers will:
  • Listen and be approachable to colleagues.
  • Respond appropriately if they are told something that might indicate a colleague, or any other person is in an exploitative situation.
  • Remain alert to indicators of slavery.
  • Raise the awareness of our colleagues by discussing issues and providing training so that everyone can spot the signs of trafficking and exploitation and know what we do.
  • Use their experience and professional judgement to gauge situations

All colleagues should:

  • Be aware – if you suspect someone is being controlled or forced by someone else to work or provide services, follow our reporting procedure.
  • Follow the reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated.
  • Tell us if you think there is more, we can do to prevent people from being exploited.

Our Policies
The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This affirms our intention to act ethically in our business relationships.

The following policies also set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

Whistleblowing policy – the Company encourages all its workers, customers and other business partners to report and provides a confidential channel to express any concerns related to its direct activities or its supply chains.

Ethical Code of Conduct (ECoC) policy – the ECoC sets out the actions and behaviour expected of employees when representing the Company.

Corporate Social Responsibility (CSR) policy – the Company’s CSR policy sets out how we work responsibly with suppliers and local communities.

Grievance procedure – the Company’s internal grievance procedure provides employees with the proper channels to raise and escalate concerns.

Recruitment policy – the employee recruitment policy sets out the Company’s approach to consistent, transparent, and fair recruitment processes in line with employment legislation.

The Risks
The principal areas of risk we face, related to slavery and human trafficking include:

  • Supply chains
  • Recruitment activities

The Company is committed to assessing these risks and putting in place the relevant mitigation measures, which will be formally reported in the statement for the next financial year.

Due Diligence Processes
The Company undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. We will operate an ongoing human rights due diligence process in line with the UN Guiding Principles on Business and Human Rights to identify, prevent, mitigate and account for how we address our impacts on human rights.

The Company maintains an awareness of the risks linked to modern slavery including high risk sectors, lack of regulation in source countries, complex employment arrangements, presence of vulnerable workers and the absence of worker representation and rights.

The Company builds long-standing relationships with its primary suppliers and makes clear our expectations of business partners. We evaluate the modern slavery and human trafficking risks of each new supplier and invoke sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

The Company will provide specialist training to those employees who are involved in managing recruitment and our supply chain. This training will include raising awareness of the signs of modern slavery, identifying risks and information about how to raise complaints within the Company.

More general awareness training is provided to all employees by providing easy access to information via media most appropriate to the recipient.

Any at risk groups identified by the Company will receive adequate training to ensure they are fully aware of their rights and how to access the Company’s grievance procedure.

Performance Indicators
The Company will use key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including:

  • Annual payroll reporting.
  •  Employee modern slavery training
  •  Supplier auditing.

The results of these KPI’s will be published in the statement for the next financial year.


Approved by Flowmax Board of Directors

Date: 30/6/20
Signed: Graham Morrell – CEO Flowmax Group
Next review: 31/12/20

Action points 2020

  • Prepare appropriate KPI’s and report the Companies performance.
  • Map the first tier of the supply chain and identifying sectors at risk and put in place relevant mitigation measures.
  • Introduce a due diligence process to the appointment of new first tier suppliers to understand their ethical commitment to business.