Modern Slavery Policy

This statement has been published in accordance with the UK Modern Slavery Act 2015.

It outlines the measures taken by SGS Engineering (UK) Ltd and other relevant group companies during the 2023/24 financial year to assess and prevent the risk of slavery and human trafficking occurring in its business or supply.

About SGS - How our business operates and is structured

SGS Engineering (UK) Limited is a owned by SGS Tool Group Limited, a United Kingdom limited liability company. SGS has been retailing engineering products since 2003. SGS designs, develops, sources and sells engineering products and branded garden, garage and power tool products both in the UK and globally, operating in multi countries. SGS products are sold through our own retail trade counters as well as through wholesale partners and online via our digital platforms. At 1st January 2024, SGS employed 53 people including part time employees in its distribution centre and head office based in Derby UK. Corporate functions providing services in Finance, IT, Ecommerce, Customer Services, Sales & Marketing and Maintenance are located at the Derby SGS head office.

Our supply chains

While we undertake most of the design and development of our products ourselves, we outsource the manufacturing of most all our products except Gas Struts that are assembled in our manufacturing centre in Derby, UK. In most factories, the facilities are shared with production for other Engineering brands. We work closely and collaboratively with suppliers and service providers, numbering +20 suppliers in over 6 countries.

Our factory list

As a Brand we regularly inspect and visit our supplier factories to undertake product inspections, factory conditions and employee welfare including working practices and health and safety.

Transparency of a company’s manufacturing supply chain better enables a company to collaborate with civil society in identifying, assessing, and avoiding actual or potential adverse human rights impacts. This is a critical step that strengthens a company’s human rights due diligence.

Our policies relating to modern slavery and human trafficking.

SGS Terms & Conditions and Code of Practice for Suppliers are available upon request from SGS Engineering (UK) Ltd.

Terms & Conditions

Our T&C’s outlines the values and principles that help shape the way we work. It is primarily aimed at colleagues and we encourage our business partners, including suppliers, distribution and partners, to adopt and apply the T&C’s wherever they represent or promote the SGS brand. The key principles include:

  • We treat all colleagues and each other fairly, with dignity and respect
  • We operate with integrity and honesty.
  • We base our business relationships on respect; and expect the same from those that we do business with

Code of Practice for Suppliers

SGS Code of Practice summarises the minimum standards for working conditions that we expect our Suppliers to adhere to in the production of all SGS products. The Code of Practice requires compliance with all local legal and regulatory requirements of the country in which the facility is located; to recognise International standards and to uphold the core labour conventions of the International Labour Organization. Where there is any conflict between these we expect the higher standard to be achieved.

It contains specific requirements related to forced labour as follows:

  • All work must be conducted on a voluntary basis, and not under threat of any penalty or sanctions.
  • The Supplier shall not use any form of forced, bonded, indentured, trafficked, slave or prison labour.
  • Workers must not be required to lodge "deposits" or their identity papers with their employer. All workers should be provided free and unrestricted access to potable water and clean toilet facilities.
  • used in the Code of Practice the term “Supplier” includes but is not limited to vendors, agents, factories, sub-contractors and material & component suppliers

HR policies

SGS Engineering (UK) Ltd will not use or allow the use of forced, compulsory labour, slavery, servitude or human trafficking in the course of its business. This includes sexual exploitation, securing services by force, threats or deception and securing services from children and vulnerable persons.

Our employment procedures guarantee that SGS Engineering (UK) Ltd conducts appropriate checks on all staff to ensure they can legally work in the United Kingdom.

In addition, all internal policies are reviewed regularly to ensure continued compliance with the Modern Slavery Act 2015.

SGS operates the following policies which are relevant to the prevention of slavery and human trafficking in its operations:

  • Outsourcing Policy. This establishes that SGS Engineering (UK) Ltd will continue to comply with the Modern Slavery Act 2015 and conduct annual reviews of outsourced suppliers
  • Recruitment Policy. This confirms that SGS Engineering (UK) Ltd will conduct checks on all staff to safeguard that they can legally work in the United Kingdom
  • Corporate Responsibility Policy. This policy is designed to ensure that SGS Engineering (UK) Ltd is conducting its business responsibly.
  • Whistleblowing Policy. SGS Engineering(UK) Ltd encourages all of its employees to report any concerns related to the activities of the firm. The organisation’s whistleblowing procedure is designed to ensure that any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the individual who raised the issue. Additionally, the policy guarantees that no one will be victimised for raising a matter under this procedure.

Due Diligence and Audits of suppliers

We believe that our biggest exposure to Modern Slavery is in our product supply chains, which is a biggest focus initially. Within these areas, new suppliers and factories/sites are subject to due diligence checks in the form of a valid 3rd party ethical audit to SMETA (or similar standards). Existing factories are also required to provide SGS with 3rd party audit information.

In common with other retailers, audits are conducted either by our SGS Buying & Quality Control team or by a third-party service provider on our behalf.

These audits are used to assess compliance with SGS Terms & Conditions and Code of practice for suppliers and identify issues for investigation so action can be taken.

In the first instance, we aim to gather the information through our audit programme to take action to improve conditions were necessary and to inform sourcing decisions.

SGS does not tolerate forced labour, slavery or human trafficking within our direct operations or supply chains. Where any non-compliance to SGS Code of Practice for Suppliers is identified, we expect and support suppliers to take action to correct it. If a supplier does not take effective action in a timely manner withdrawing our business remains the final sanction.

Addressing the risks of modern slavery and human trafficking

SGS attaches real importance to the welfare of our colleagues and those employed by our suppliers. We are taking steps to strengthen our understanding and management of the risks of modern slavery and human trafficking in our own business or our supply chains, building on our Terms & Conditions and Code of Practice for Suppliers. These steps include:

  • Mapping our supplier chains to assess particular industry/sector and geographical risk, to have a clear idea of where the business risks lie
  • Assessment scope covers all aspects of our business including Retail operations, Property, Logistics, HR and IT as well as our product supply chains
  • Meeting with a 3rd party to discuss conducting a modern slavery risk assessment on behalf of SGS
  • Reviewing our governance structures for responsible sourcing of Goods for Resale (GfR) and Goods Not for Resale (GNfR)
  • Published the SGS Modern Slavery statement

During the remainder of the 2024/25 financial year, SGS will continue to build on these activities, considering the following areas in particular:

  • Internally publish the findings of modern slavery risk assessment, collate action plan to further mitigate risks and drive improvement using best practice examples from other retailers
  • Engage our supply base by writing to all areas of our business to raise awareness of the Modern Slavery Act and Human Rights
  • Review of potential KPIs and monitoring

Training and awareness

We aim to hold awareness training, on the prevalence of modern slavery and the Modern Slavery Act to highlight the issue and how we expect all colleagues to play their part.

Reviewing progress

Supply chains can change for many reasons and the threat of modern slavery can continue to evolve and change. We intend to continue to monitor and review our controls that guard against the risk of modern slavery which will be shared and reported on.

Approved by the Leadership of SGS Engineering (UK) Ltd in April 2024

Neil Sansom
Chief Executive Officer 
April 2024