Human Trafficking and Slave Labour Policy/Statement.

This statement covers the activities of Tor Coatings, Tor Coatings is a manufacturer of materials used in the construction industry, such as coatings for roofs, floors, balconies, walls, and fire protection products. The oganisation operates in all countries of the world except for those that are subject to a trade ban or other sanctions as applied by the United Kingdom, United States, or the European Union. 

Tor Coatings acknowledges the provisions of the Modern Slavery Act 2015 and will ensure transparency within its organisation and suppliers of goods and services to the organisation. Tor Coatings is satisfied from its own due diligence there is no evidence of any act of modern day slavery or human trafficking within the organisation. 

Tor Coatings will not knowingly support or deal with any business involved in slavery or human trafficking. 

Tor Coatings is committed to ensuring that neither its employees or contractors or its suppliers use slave labour or engage in human trafficking. Pursuant to this Anti-Slavery and Anti-Human Trafficking Policy (the “Policy”), Tor Coatings specifically prohibits its suppliers from using forced labour of any kind. 

Tor Coatings Code of Business Conduct and Ethics and Whistleblower Policy establishes ethical business conduct as critical to our business and our expectation of compliance with applicable laws. 

Tor Coatings monitors its supply chain for compliance with this Policy by engaging in annual business reviews. 

Tor Coatings generally does not engage third parties: 

  • to verify product supply chains to evaluate and address risks of human trafficking or slave labour laws or 
  • audit suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains 

Tor Coatings promptly and thoroughly investigates any claims or indications that a supplier is engaging in human trafficking or slave labour, or is otherwise not complying with this Policy. Any such claim made through our Whistleblower process would be reported to appropriate Tor Coatings personnel or others as appropriate (e.g., the Board of Directors), along with the resolution of the claim and/or the findings of the investigation. 

Tor Coatings does not require certification from direct suppliers that materials incorporated into the product comply with laws regarding slavery or human trafficking of the country or countries in which they are doing business. Tor Coatings maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and human trafficking. Tor Coatings executives receive training on Tor Coatings Code of Business Conduct and Ethics and Whistleblower Policy, although specific training on eradicating slave labour or human trafficking is not generally provided. 

Tor Coatings will not continue to purchase goods or services from any supplier that is found to be engaging in human trafficking or using slave labour. 

Tor Coatings will take responsibility for implementing this policy and will ensure the policy is reviewed annually. 

This Policy is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our groups slavery and human trafficking statement. 

© HR 52 Law Limited
V.01 April 2021


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