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Modern Slavery Act 2015

Thwaites Ltd - Modern Slavery and Human Trafficking Statement




Thwaites is a privately owned company and is the leading manufacturer of compact dumper trucks for the construction industry. It is a single site operation based in Warwickshire, UK.




The 2015 Modern Slavery Act ('the Act') came into force on 29 October 2015. This statement is made pursuant to Section 54 of the Act and sets out the steps Thwaites Limited has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of the business.

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Victims are coerced, deceived and forced against their free will into providing work or services. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited whether they consent to such travel or not. Modern slavery is a crime and a violation of fundamental human rights.

Thwaites has a zero tolerance policy towards any breach of human rights, including modern slavery and human trafficking.

Within Thwaites core operations, the procurement of engineering materials and high specification componentry is a significant part of our process. As such, these materials are sourced from suppliers in Western Europe and member states of The European Union. Thwaites does not deal in countries or commodities identified as “high risk”.

Thwaites is a vertically integrated manufacturing company with very limited sub-contract activities related to its processes. Any sub-contract work is undertaken in the UK.

During the last financial year, Thwaites continued to review of its business and operations in relation to the Act. Any new suppliers fell into the category detailed above relating to commodity type and geographical region. It was identified that Thwaites has a low risk supply chain based upon the Global Slavery Index and The United States Department of Labour - List of Goods Produced by Child Labour or Forced Labour, but that areas of increased risk may exist earlier in the supply chain process. In order to ensure that Thwaites remained compliant with legislation, including the provisions of the Act, Thwaites has started to put in place systems and procedures to:

          • Continue to monitor and assess potential risk areas in our supply chain – using supplier location and type of product or service.

          • Update Thwaites Supplier Questionnaire to include questions relevant to the Act.


Our employees are encouraged to identify and report any potential breaches of our policies wherever and whenever they occur.


This represents Thwaites’s statement in accordance with Section 54 of the Modern Slavery Act 2015 for our financial year ending 31st August 2018 and has been approved by the Board of Directors.






Kevin Phelan

Operations Director

Thwaites Ltd


Last updated: 22/01/19




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