TRADELINK WOOD PRODUCTS LIMITED modern slavery statement summary (2020)

Organisation address
Unit 31 Nw Works,
135 Salusbury Road,
London,
England,
NW6 6RJ

We asked the organisation a series of questions about its modern slavery statement. Its answers are published on this page as a statement summary.

This statement provides information for all 6 recommended topics

What is a modern slavery statement?
UK law requires certain organisations to publish an annual modern slavery statement on their website, setting out the steps they are taking to address modern slavery risks in their operations and supply chains. Read more in the government guidance on publishing modern slavery statements.

PDF version of the statement (optional)

There is no PDF version of this statement.

PDF statements were first introduced to the registry for the 2023 statement year.

About this statement summary

All answers relate to the financial year covered by the statement. The organisation is responsible for all the information it provided. Some of our questions are optional, so organisations may not have answered all of them. The statement summary does not replace the full modern slavery statement – below we provide a link to the full statement on the organisation’s website.

Statement period and sign-off details

The statement covers the following period:
1 January 2019 to 31 December 2019

The statement was signed off by:
Herman Schey (Managing Director)

It was approved by the board (or equivalent management body) on:
10 December 2020

Recommended topics covered by the statement

Government guidance encourages organisations to cover a range of topics in their modern slavery statements, setting out the steps they’re taking to address modern slavery risks in their operations and supply chains. Read about the recommended topics in the statutory guidance.

We asked the organisation to tell us which topics its statement covers.

Topics recommended by government guidance Organisation’s response
The organisation’s structure, business and supply chains Covered
Policies Covered
Risk assessment Covered
Due diligence (steps to address risk) Covered
Training about modern slavery Covered
Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation's actions and progress over time Covered

The organisation’s sectors and turnover

Sectors

The organisation operates in the following sectors:

  • Forestry, timber products, paper and containers and packaging

Turnover

Its turnover in the financial accounting year of this statement was:

£60 million to £100 million

If the organisation is a public body, this amount is based on the organisation’s budget for the year of the statement.
What does 'turnover' refer to in group statements?
If this is a group statement, this includes the total turnover for all the organisations covered by the statement.

Number of years producing statements

The organisation has been producing modern slavery statements for the following number of years:
1 to 5 years
How does this work for group statements?
If the statement is for a group of organisations, this answer applies to the organisation with the longest history of producing statements.

Policies (optional)

We asked the organisation whether its policies include the following provisions in relation to its domestic and international supply chains, as well as its own operations.
Policy provisions we asked about Organisation’s response
Freedom of workers to terminate employment Included
Freedom of movement Not included
Freedom of association Included
Prohibits any threat of violence, harassment and intimidation Included
Prohibits the use of worker-paid recruitment fees Not included
Prohibits compulsory overtime Not included
Prohibits child labour Included
Prohibits discrimination Included
Prohibits confiscation of workers' original identification documents Not included
Provides access to remedy, compensation and justice for victims of modern slavery Not included
Other
Not included

Training (optional)

We asked the organisation whether it provided training on modern slavery, and who it was for.
What counts as training?
We explained that by ‘training’ we meant anything designed to increase knowledge and skills around identifying, addressing or preventing modern slavery risks. This could range from formal training courses to broader awareness-raising activities such as workshops or webinars.
We asked who the training was for Organisation’s response
Your whole organisation No
Your front line staff Yes
Human resources Yes
Executive-level staff Yes
Procurement staff Yes
Your suppliers Yes
The wider community No
Other
No

Monitoring working conditions (optional)

Engaging with others

We asked the organisation to tell us who it engaged with to help monitor working conditions across its operations and supply chains.
We asked who the organisation engaged with Organisation’s response
Your suppliers Yes
Trade unions or worker representative groups Yes
Civil society organisations No
Professional auditors Yes
Workers within your organisation Yes
Workers within your supply chain Yes
Central or local government Yes
Law enforcement, such as police, GLAA and other local labour market inspectorates No
Businesses in your industry or sector Yes

Social audits

We asked the organisation to tell us about any social audits it used to look for signs of modern slavery.
What are social audits?
A social audit is a review of an organisation’s working practices from the point of view of social responsibility, and should include an evaluation of working conditions in the organisation’s operations and supply chains. By their nature, audits of supplier workplaces represent a snapshot in time.
Social audits we asked about Organisation’s response
Audit conducted by your staff Yes
Third party audit arranged by your organisation Yes
Audit conducted by your supplier’s staff No
Third party audit arranged by your supplier No
Announced audit No
Unannounced audit No

Grievance mechanisms

We asked the organisation how workers in its operations or supply chains could raise concerns or make complaints.
We asked if workers could raise concerns this way Organisation’s response
Using anonymous whistleblowing services, such as a helpline or mobile phone app No
Through trade unions or other worker representative groups Yes

Other ways of monitoring working conditions

We asked the organisation whether it had any other ways of monitoring working conditions across its operations and supply chains:
We believe the best way is regular visits to our suppliers by high level management. We build up close relationships with suppliers, who give us access to audit their respective chains to forest level

Modern slavery risks (optional)

Warning Identifying modern slavery risks is a vital step towards eradicating it. The government encourages organisations to be as open and transparent as possible, to improve understanding, collaboration and best practice around tackling this worldwide problem.
We asked the organisation to describe up to 3 priority risks it focused on during the period of the statement, including details of the affected workers, the activity involved, and the location.

Priority risks for this organisation (1 of 3)

Workers in the Forest Harvesting and extraction phase of the chain often do not have adequate working and living conditions, such as poor sanitation and living quarters
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 3 suppliers and below
    Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect Organisation’s response:
  • Low income and basic education level workers
In which country Organisation’s response: Brazil
Actions or plans to address this risk Organisation’s response: We conduct annual supplier audits. The following factors are checked to be in a suitable & hygienic standard: ⮚ Workers living quarters. ⮚ Drinking water supply ⮚ Sanitation installations ⮚ Drainage ⮚ Canteen and kitchen facilities ⮚ Level of PPE, safety and first-aid equipment

Priority risks for this organisation (2 of 3)

Workers in sawmills sometimes are not proved the required PPE safety equipment
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 1 suppliers
    Provide their products and services directly to your organisation.
  • Tier 2 suppliers
    Provide products and services to your organisation via your Tier 1 suppliers.
Who was it most likely to affect Organisation’s response:
  • Low income and basic education level workers
In which country Organisation’s response: Brazil
Actions or plans to address this risk Organisation’s response: We conduct regular supplier audits, where we check theLevel of PPE, safety and first-aid equipment at our suppliers facilities. We have an annual evaluation risk assessment of our current suppliers.

Priority risks for this organisation (3 of 3)

Workers in the supply chain may not be receiving the salaries agreed by their respective sector labour synicates
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 2 suppliers
    Provide products and services to your organisation via your Tier 1 suppliers.
  • Tier 3 suppliers and below
    Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect Organisation’s response:
  • Low income and basic education level workers
In which country Organisation’s response: Brazil
Actions or plans to address this risk Organisation’s response: The supply chain for each product/species undergoes a detailed Risk Assessment Analysis. For example, in Brazil we use 3rd party auditors to do a desktop audit of the company and if necessary, further onsite audits are conducted. This includes field audits and visits to the mills to conduct further risk assessments or obtain any information that could not be found via desktop audit.

Indicators of forced labour (optional)

We asked the organisation whether its statement refers to finding any International Labour Organization (ILO) indicators of forced labour.
What are ILO indicators of forced labour?
The International Labour Organization (ILO) has produced a list of the most common signs of forced labour. They’re based on the definition of forced labour as ‘all work or service which is extracted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.’ More details and guidance are available on the ILO website, and in their publication ILO indicators of forced labour
ILO indicators we asked about Organisation’s response
Abuse of vulnerability No
Deception No
Restriction of movement No
Isolation No
Physical and sexual violence No
Intimidation and threats No
Retention of identity documents No
Withholding of wages No
Debt bondage No
Abusive working and living conditions Yes
Excessive overtime No
Other
-

Actions taken in response to finding ILO indicators

We asked the organisation to tell us whether its statement refers to any actions it took after finding indicators of forced labour
Actions we asked about Organisation’s response
Financial remediation, including repayment of recruitment fees No
Change in policy Yes
Change in training No
Referring potential victims to government services No
Supporting victims via NGO No
Supporting investigations by relevant authorities No
Other
Notifying the supplier in question that their Chain has risks of slave labour and orientation how to remedy and find solutions

Demonstrating progress (optional)

We asked the organisation how its statement demonstrates progress over time in addressing modern slavery risks. They provided the following answer:
We set progress goals and next steps for future statements. We aim to each year increase transparency of supplier audits, providing examples of what risks were identified and what was done by the company to mitigate risks found. We are supported by Ardea Intl with whom we have conducted Gap analysis, training & receive support on MSA Statement compliance. Special Note: Delayed 2020 MSA statement approval delayed due to staff shortages and supply chain disruptions, caused by COVID-19 Pandemic.