Modern Slavery and Human Trafficking Transparency Statement

Chugoku Paints (UK) Ltd.

Introduction from Norimasa Kunihiro / Managing Director

  We are committed to reviewing and, where necessary, improving our practices to combat slavery and human trafficking. In recent months we have been reviewing our supply chains as well as our practices and policies to ensure that we are doing all we can to combat the problem. This statement sets out what we propose to do in future.

Our business and its structure

  Our business is organised into four principal business areas:

1. Manufacturing and sales of marine paints, industrial paints and container paints.
2. Sales of painting related equipment.
3. Management and contract work for coating.
4. Inspection of surface treatment and coating.

  Chugoku Paints (UK) Ltd., is the UK sales and service division of its parent company Chugoku Paints B.V. in Netherlands. The parent company is wholly owned by Chugoku Marine Paints, Ltd. located at Tokyo Club Building, 2-6, Kasumigaseki 3-chome, Chiyoda-ku, Tokyo, 100-0013, Japan (hereinafter called “CMP“), who provides its products to the market worldwide. CMP Group has approximately 2,200 employees and 100 locations in the world.

For information on the Group’s business, group companies and activities, please visit the following website:  http://www.cmp.co.jp/global.html

CMP Group has an annual turnover in excess of £36m.

Our supply chains

  Chugoku Paints (UK) Ltd. requests all suppliers in its supply chain to take appropriate steps based on the relevant policies stated below. Additionally, we encourage our suppliers to apply such policies to their suppliers and sub-contractors so that it helps the mitigation of slavery or human trafficking risk in our whole supply chain.

Our policies on slavery and human trafficking

  We have recently updated our procedures to include an Anti-Slavery Policy which reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking

  We operate a zero-tolerance approach to Modern Slavery and we are committed to acting ethically in all our business dealings and relationships. We consider that the greatest risk of slavery or human trafficking could have been in our supply chain where operations and managerial oversight are out of our direct control.

We have in place systems to:

Monitor compliance by requiring every supplier and every employee of Chugoku Paints (UK) Ltd. to review and confirm their compliance with our legal code of conduct every year.
Carry out due diligence on all our suppliers to ensure their understanding of and compliance with UK anti-slavery law.
Require suppliers to commit to compliance with our Anti-Slavery policy.
Encourage the reporting of concerns and the protection of whistle blowers.

Supplier adherence to our values

  To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme. We have also commenced the process of actively seeking confirmation from our supply chain third parties (UK and overseas) that they comply with local labour laws and regulations. The system includes self-assessment questionnaires and contractual warranties to require suppliers to comply with our Anti-Slavery Policy. In the event that we are not reasonably satisfied with the responses to the questionnaire submitted by the suppliers, we may request the suppliers to explain the responses in detail and/or submit an improvement action plan. We are in the process of reviewing and revising our terms and conditions of supply within the supply chains with the planned adoption of these revised contracts with all existing business partners and new suppliers over the next financial year. The management are responsible for compliance in their respective departments and for their supplier relationships.

Training

  To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.

Our effectiveness in combating slavery and human trafficking

  In the event that suppliers fail to provide assurance to cease or prevent slavery and human trafficking or other adverse human rights impacts, we will consider terminating our business relationships with those suppliers.

Further steps

  Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:

Ask our suppliers to complete an anti-slavery questionnaire in order to assist our assessment of the risks posed in each area of our business.
Add contractual provisions in our purchase agreements and service agreements that require suppliers to warrant that no slavery is used anywhere in the supplier's business and that all necessary measures have been put into place to ensure that this remains the case.

  This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2017.

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