Modern Slavery Act

Slavery and Human Trafficking

Brammer does not condone and will not participate in any form of human exploitation, including child or forced labour, slavery and people trafficking. Brammer is aware of the provisions of the Modern Slavery Act 2015 and this policy sets out the steps that Brammer Limited and its subsidiaries (the “Brammer Group”) have taken to try and remove the risk that slavery and human trafficking is taking place in any of its supply chains or as part of the Brammer Group’s business.

Our Business

Brammer is a leading pan-European added value distributor of high quality industrial maintenance, repair and overhaul products. We supply Bearings, Mechanical Power Transmission components, Fluid Power, and Tools and General Maintenance products, together with engineering and associated industrial services, to the maintenance repair and overhaul (“MRO”) market across Europe.

Brammer is UK headquartered, with the UK being our biggest operation, with our European geographic footprint now covering 23 countries and serving over 100,000 customers in every manufacturing sector, leveraging our pan-European network and delivering 24/7/365 locally across Europe from our 16 national distribution centres.

Supply Chain

Brammer is the authorised distributor of many of the world’s leading engineering component manufacturers. As an industrial supply distributor we offer around 6 million individual product lines, manufactured by thousands of companies.

Our Policies

The Brammer Group is committed to ensuring that slavery and human trafficking is not taking place in any of its supply chains or as part of the Brammer Group’s business. Many of the Brammer Group’s existing policies contain relevant elements which seek to ensure that this is the case. Including:

  • Labour practices policy, which sets out the Brammer Group’s ethos that “each and every Brammer employee has a right to work in a safe and supportive environment”. Brammer recognises and respects the legal and moral rights of all persons affected by its operations and is committed to providing a working environment free of harassment, discrimination or prejudice.

  •  Dignity at work policy, which sets out Brammer’s strong belief in the benefits of non-discrimination and equality of opportunity and supports employee engagement and representation.
  • Whistleblowing policy, under which Brammer commits to the highest standards of openness, probity and accountability.
  • Supplier code of conduct and sustainable procurement policy, which sets forth a number of actions where Brammer can use its purchasing power to help ensure ethical and sustainable procurement.
  • Fair business practice policy, where we ask that all employees demonstrate the highest possible levels of integrity, and act honestly and fairly when dealing with other employees and external stakeholders, and set out our expectation that all employees will act ethically and in a manner which is consistent with their training.


Risk Assessment and Due Diligence

The risk of slavery and human trafficking within Brammer’s organisation is substantially diminished by the implementation of the above mentioned policies and the procedures that the Brammer Group has in place across its operations.

The Brammer Group seeks to identify and minimise the risk of slavery and human trafficking in its supply chain by endeavouring to select suppliers who adopt high ethical standards which are consistent with Brammer’s corporate beliefs and values, and seeks to build long standing relationships with these suppliers. These standards include respecting the rights of the individuals who are employed by them.

As such, Brammer expects its suppliers (and their subcontractors) to operate their businesses and conduct employee relations in an ethical manner and to meet the requirements stipulated by both international and regional laws and industry standards. The majority of Brammer’s products are sourced from leading manufacturers within Europe who adopt high standards which are consistent with Brammer’s.

Brammer expects its suppliers to have in place policies that enable Brammer to be reasonably assured that they meet the standards expected of them. If suppliers fail to meet these expected standards, Brammer may suspend its relationship with that supplier until the issue is resolved.

Training and effectiveness

Brammer has briefed its purchasing team on the risks of modern slavery and human trafficking and agency worker providers have been reviewed in order to ensure that they are reputable and will comply with the Modern Slavery Act.

The Group carries out an employee survey every year to obtain feedback for management and to identify areas to focus upon to increase employee engagement still further. The group also regularly monitors training costs per employee to assess the efficiency of its employees through training in order to ensure the quality of its overall service delivery.

In addition to the whistleblowing policy, Brammer is in the process of assessing service providers for the introduction of a whistleblowing hotline so that unethical behaviour can be reported even more effectively. Should any concerns be held in relation to unethical behaviour, they can be raised in confidence via this hotline and will be subject to immediate investigation.

We do not have any key performance indicators in place in relation to compliance with this policy; however, any breaches of this policy should be reported to Brammer.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and is subject to an annual review.
June 2017