The principles covered in this policy cover all areas of Goodwin PLC's operations and have been developed and continue to be reviewed against and updated by reference to relevant codes of corporate governance and international standards including the United Nations (UN) Universal Declaration of Human Rights, the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, the Guidelines for Multinational Enterprises established by the Organisation for Economic Cooperation and Development (OECD), the Rio Declaration on Environment and Development and the UN Convention against Corruption and the UK Modern Slavery Act 2015.
The Board of Directors supports the principles set out in those codes and standards and the aim of this policy is to translate that support into a set of guidelines and standards that set a common approach for Goodwin PLC and provide practical guidance for our managers, employees and contractors. We wish to be transparent, fair and reasonable.
This code applies to all of the operations of Goodwin PLC and its subsidiaries (“the Group”) and sets out the minimum standards which the Board of Goodwin PLC expects from staff in their internal and external dealings with colleagues, customers, stakeholders and third parties.
We always conduct our own services honestly and honourably, and expect our clients and suppliers to do the same. Our advice, strategic assistance and the methods imparted through our training, take proper account of ethical considerations, together with the protection and enhancement of the moral position of our clients and suppliers.
Basic standards of conduct:
Compliance with Law:
Conflicts of Interest and Confidentiality:
At Goodwin PLC, we have a long standing commitment to high ethical standards and expect our employees and everyone that we do business with, including our suppliers, to have the same high standards. Modern slavery is a crime and an abuse of human rights. It is constituted in the UK Modern Slavery Act by the offences of slavery, servitude and forced or compulsory labour and human trafficking. We do not tolerate such abuses in our business or supply chains and we are committed to improving our practices to eliminate any abuse or exploitation.
Business, Structure and Supply Chains
The Group focuses on manufacturing within mechanical engineering and refractory engineering sectors. Our mechanical engineering sector serves the oil, petrochemical, gas, LNG and water markets as well as defence contractors, civil aviation authorities and border security agencies. Our refractory sector serves the jewellery casting, aerospace, fire protection, tyre moulding and shell moulding casting industries.
The Group’s head office is located in Staffordshire in the United Kingdom and operates within Australia, Brazil, China, Finland, Germany, India, South Africa, South Korea, Thailand and the UK with a workforce of more than 1,000 employees.
Throughout the Group’s history it has built up a network of trusted suppliers, consisting primarily of manufacturing entities as well as service providers. Internally both Goodwin International and Noreva purchase the major value of their sand mould castings from Goodwin Steel Castings. Seven of our jewellery casting manufacturing companies buy manufactured cristobalite from another of our UK refractory companies, Hoben International.
The Goodwin PLC and its subsidiaries are continually reviewing and improving their policies in line with the United Nations Global Compact’s ten universal principles. In addition to the Modern Slavery Policy, the following policies are in place:
As required by the Act this Statement sets out the steps Goodwin PLC has taken during the recent financial year to safeguard against slavery in its various forms and human trafficking is not taking place in our businesses or our supply chains.
Throughout the year, adherence to our policy is mandated through our general contractual Conditions of Purchase. Furthermore, letters have been sent out to suppliers requiring our suppliers to adopt, implement and evidence adequate compliance in line with our policy and particular attention is paid through our Know Your Customer policy to find true identities.
Transparency is encouraged through whistle blowing awareness and the maintenance of personal visits by management where possible. No potential modern slavery concerns, or signs of such issues, were identified at any of our locations. However, we are mindful that we need to safeguard against complacency and remain diligent in this regard. The effectiveness of these steps continue to be monitored by the Audit Committee.
Currently, the Goodwin PLC Board is looking to into developing a comprehensive code of conduct for our employees that is intended to act as a global policy framework, setting out the behaviors, practices and standards we expect not only of our employees to adhere to but all we engage with.
As a part of the Anti-Slavery and Human Trafficking Policy the Group has implemented:
The Group will take steps to regularly assess, prevent, manage and mitigate the risks within our business and supply chains in high risk countries as identified on the Global Slavery Index (https://www.globalslaveryindex.org/index/).
At our Business conference, Directors and Senior Management receive training, raising the awareness and ensuring that the delegates understand the importance of the issue of Modern Slavery & Human Trafficking.
This awareness is enhanced through the on-line training courses that was set-up in previous years, whereby the Directors of all subsidiaries are encouraged to flow the values and best practices down within their own companies taking into account local legislation in order to achieve an understanding of best practice.
This statement is made on behalf of Goodwin PLC and its subsidiary companies, including Goodwin International Limited, in accordance with the obligation to make a modern slavery statement (Statement) under s54(1) of the Modern Slavery Act 2015.
This Statement was approved by the Board on 24th October 2019 and is signed on its behalf by:
The Group has outlined employee responsibilities in observing and upholding its position on bribery and corruption
We provide information and guidance to those working for the Group on how to recognize and deal with bribery and corruption issues.
We conform with the laws of the England and Wales, including the Bribery Act 2010.
It is the Group's policy to conduct all business in an honest and ethical manner. A zero-tolerance approach to bribery and corruption will be taken and all laws relevant to countering bribery and corruption will be upheld.
This policy applies to all individuals working at all levels within the Group who interface with external sources, including all employees and Directors, consultants, contractors, trainees, apprentices, interns, seconded staff, casual workers, agency staff, volunteers, agents, sponsors or any other person associated with the Group wherever located (collectively referred to as Workers in this policy).
The Directors have overall responsibility for ensuring this policy complies with the legal and ethical obligations of the Group, and that all those under its control comply with it.
The Chairman has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation.
Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
All employees are responsible for:
We wish to be transparent, fair and reasonable in processing and storing personal data.
Adopting the EU General Data Protection Regulations, the Group expresses a privacy notice on all its websites. To promote transparency and fairness we have carried out data impact analysis on our processes known to handle personal data. We will continue to consult and include individuals responsible for handling data with the intention of training them to comply with the Regulation. We aim to inform people how their data is used, gain consent and give choice in their personal data handling.
Personal data is encrypted and for contractual, insurance and legal requirements may be retained for periods proportionate to those needs and, where requests for data removal are refused, explanation will be given. The Data Protection Officer is the Chairman contactable through the Company Secretary firstname.lastname@example.org to whom any complaint should be made in the first instance and in the absence of resolution contact should be addressed to the independent Non-Executive Director.
The Group does not at present make contributions to political parties., The Group only makes charitable donations that are legal and ethical under local laws and practices.
Climate change is recognized as an international issue with national governments on both sides of the Atlantic committed to taking action to reduce greenhouse emissions.
The Group is acutely aware of its greenhouse gas emissions, for which we understand that there is a need for Group companies to contribute to targeted global reductions. We are committed to reducing the greenhouse gas emissions from our operations in a way which supports national government strategies and in line with our commitment to our customers to provide safe, efficient and reliable products and services.
Our key climate change commitments are:
Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If it is uncertain whether a particular act constitutes bribery or corruption, or if there are any other queries, these should be raised with an appropriate director. Concerns may be reported by following the procedure set out in the Whistle Blowing Policy.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
Training and Communication
Training on the policy will be given to all those that have interface with external sources. This should be identified at the induction stage for all new employees, though existing workers will also receive training as appropriate.
A zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
Monitoring and Review
Directors will monitor the effectiveness and review the implementation of the policy during the annual management review considering its suitability, adequacy and effectiveness.
Any improvements identified will be made as soon as possible and this policy amended as required.
Internal control systems and procedures will be subject to audit to provide assurance that they are effective in countering bribery and corruption.
Workers are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Chairman.
Anyone who has a reasonable belief that there is serious malpractice relating to any of the matters specified above, may raise a concern under the procedure detailed in paragraph below.
The issues raised may relate to another employee, a group of employees, the individual's own Board of Directors or other parties such as subcontractors
Concerns must be raised without malice and in good faith, and an individual must reasonably believe that the information disclosed, and any allegations contained in it, are substantially true.
In view of the protection afforded to an employee raising a bona fide concern, it is preferable if that individual puts his/her name to any disclosure. The identity of the person raising the matter will be kept confidential, if so requested, for as long as possible provided that this is compatible with a proper investigation.
Anonymous complaints are more difficult to authenticate but may be reported by dialing a telephone answering machine and leaving a message. This will be listened to by the Chairman or Company Secretary and investigated or acted upon as the person receiving the complaint sees fit (including the use of this procedure), having regard to the seriousness of the issue raised, the credibility of the complaint, the prospects of being able to investigate the matter, and fairness to any individual mentioned in the complaint.
Any disclosure should be made in the first instance in confidence to:
If no response is received following a disclosure from a named individual or the individual is dissatisfied with the response then the individual may raise the concern with the Partner of the Company’s Auditors:
KPMG Audit PLC (Tel: +44 (0) 121 232 3000)