CED Stone Inspiring Beautiful Landscapes

Modern Slavery Statement



CED Stone Group
Modern Slavery Statement 2021


CED have produced this statement in line with and in recognition of Section 54 of the UK Modern Slavery Act 2015. It describes and links to our ethical strategy, targets and current actions in relation to prevention of Modern Slavery and forced labour, in our supply-chain. Forced labour includes the range of activities such as recruiting, concealing, transporting or obtaining workers where a person uses force or physical threats, psychological control or other deceptive means to compel someone to work. CED make it clear to all our supply chain partners that any form of Modern Slavery, forced labour, debt bondage, child labour or any other act of forcing workers to do something against their will and where they have no choice, is totally unacceptable and will not be tolerated under any circumstance. Other human rights abuses go “hand in hand” with Modern Slavery and our strategy is to monitor our supply-chain factories and watch for any warning signs or “red flags” that suggest there could be ethical trade issues present.



Natural Stone Industry background:

Natural stone production worldwide has some very complex supply chains. There can be some very good visibility at tier one factory level but much less, further down the chain at sub-contract and quarry level. Due to the sheer size, weight, awkwardness and cost of moving raw natural stone quarry blocks, they are often processed into finished products at factories located beside the quarry source. In large countries such as China, this means that a lot of production occurs at partner factories to the actual suppliers, that importers are dealing directly with. Also, as with other industries there can be a substantial amount of sub-contract work done, as jobs are shared by neighbouring factories to manage lead-times. There are seasonal “highs and lows” in our market
place and this can mean that there is a substantial amount of labour who are temporary and not employed directly by the factory. These temporary workers are often in a much more vulnerable position than the permanent workers, being less likely to have formal contracts or insurance cover and are more at risk of suffering labour rights abuses. Often it is illegal and unchecked mines and quarries that can be responsible for bonding workers. Ultimately it will be the build-up of pressure on local and national Government bodies, to ensure enforcement of local and International Labour Organisation laws, that will bring about the necessary changes. When you drill down into the whole concept and reasoning behind the Modern Slavery Act, it is to protect the workers that produce the goods that we consume here in the UK. When you buy something that costs very little it is probably the case that the workers who produced the product are being taken advantage of in some way. Low pay, long hours, physical and verbal abuse, forced and slave labour are all the more likely. It is a conundrum which is hard to solve. We all look for a bargain but do not always consider the cost. In our industry when the contractors have the orders to place, their buyers have the job of finding the cheapest price. Our investment in Ethical work and the fact that we will only trade with ethically supportive factories, means that there is an extra overhead to be considered. The more pressure that the UK consumers place on business and Government to demand evidence of ethical sourcing the better. This is the best way forward for sustainable change.



CED Ethical Supply Structure:

CED Stone Group always strives to lead by example in the way that we conduct ourselves and the fair way we interact and impact with our suppliers. We are conscious of the footprint that we leave and work hard to ensure that our purchasing and business practices have only positive effects on the workers in our supply-chain. It has been key that we map our supply-chain to the fullest extent to ensure that we know where our stone comes from and where it is being worked, so that we can assess the conditions that workers producing our goods work under. We source much of our imports from factories in both China and India. Through research and mapping we identified these as our highest risk areas and have targeted the majority of our ethical resources there. We also source stone products from across Europe and the UK. We continue to be vigilant and monitor these operations too, so that we can ensure that there is no forced or slave labour present and that workers have the freedom to leave their employer
if they choose to do so. Company size is important when it comes to how much influence one can realistically exert on supplier factories. However CED Stone do not see this as an excuse for any acceptance of Modern
Slavery. We rigorously inspect and audit supplier sites to look for signs that human rights abuses are, or might be present. Experience has taught us that collaboration and multiple stake-holder programmes, are the best way to influence improvements in regions, where our business levels, methods and reach alone, cannot affect any positive ethical change.



ETI Membership:


The Ethical Trading Initiative (ETI) is a leading alliance of Commercial Companies, Trade Unions and NGOs, that promotes respect for worker’s rights around the globe. Their vision is a world where all workers are free from exploitation and discrimination, and enjoy conditions of freedom, security and equity. Global supply chains are highly complex and challenging for companies committed to eradicating Modern Slavery. Worker’s rights issues are often deep-rooted and widespread and are best tackled through collaborative action. Through our involvement with ETI we are able to harness the expertise, skills and resources of their alliance members to identify these issues and help develop innovative, long-lasting solutions. We have been full and active members of ETI for several years and work on the collaborative project as part of the Rajasthan Sandstone Working Group. We believe that working with ETI and their Base Code of labour practices, is an essential for companies who are serious about Ethical Trade and eradicating Modern Slavery. The level of experience and knowledge that their tripartite of members bring and of which members have access to is vast and invaluable. They lead, guide and monitor their members and ensure that you are always thinking forward and working to resolve issues and improve conditions for workers.



Supplier Participation:


Many of our key suppliers have been working together with us for twenty and thirty years plus. These long-term supplier relationships are crucial to ensure year on year improvements for the workers. Building long term, open and honest relations with our suppliers has allowed us to be well informed and work with them to instigate positive change. This has allowed us greater access to workers for interviews and training, allowing us to better understand their situation and priorities. It is crucial that suppliers are fully on board, with regards to treating the workers with respect and encouraging them to exercise their right to have the freedom, to choose where they work. Following on from the success of the multi stake-holder collaboration in Rajasthan and working in conjunction with our Indian partner supplier, NNG Group, we have seen many significant ethical improvements at tier one factory levels in India. We found potential salient issues present here, based around discrimination of contract workers, no recording of contract worker hours, lack of safety gear distribution and uptake as well as poor HR documentation such as employment contracts and payment records. Some of the “step by step” improvements now in place, include new shaded garden areas for breaks and meal times. Safer working areas with more safety gear distribution to both permanent and contract workers. New HR systems including employment contracts and payments direct to bank accounts. H&S meetings and training. Worker grievance committee. Contract workers hours now recorded. This further increases the ethical transparency of our Indian production.



Covid19:

The last years have presented unprecedented issues with the global virus pandemic. This has limited our ability to travel, audit and train. However, we have been required to be extra careful, to ensure that the workers are safe and have the necessary protections to survive. Also, that their employment is secure and that they have enough money to get them through the periods of Lock-down. 1/ More engagement with suppliers to reinforce the H&S messages passed down by the WHO (World
Health Organisation); regular hand washing, wearing face masks, social distancing and having hand sanitiser available for use. 2/ Fulfil our payment obligations promptly for ongoing work to keep their cash-flow fluid. Beyond
this insist that they must pay workers for the work they have done on our orders even if running behind. 3/ Pay for orders in progress even if they cannot be finished or shipped. 4/ Where possible consider early payment so that workers can pay for medication and food and survive periods of isolation. 5/ Accept order delays without sanction. 6/ Avoid cancelling orders. 7/ Engage with our suppliers to ensure that workers are not being asked to work excessive overtime
due to delays to orders. 8/ Ensure suppliers accept that workers may feel unsafe if they return to work and try to ensure that they are not punished for making this decision. Covid lock-downs in Shandong China can lead to migrant and seasonal workers in stone factories being unable to work and earn money. The factories do not have emergency plans to fund these workers and there are not always the correct insurance covers in place. This leads to salience issues which could include children having to work to earn money for basic food and lodgings where their parents are no longer earning wages. We are keeping very close vigilance on these potential situations.



CED Business Ethical Principles:


Responsible business conduct and respect for human rights are at the heart of our operations. When identifying future business opportunities, we do so in partnership with others that are equally committed to respecting labour standards and advancing human rights. We strive for greater visibility and transparency within our company and communicate externally about the value of corporate responsibility. We offer sustainable work to our suppliers and encourage economic growth. Ensuring equal wages with no discrimination. Child labour and Modern Slavery are completely unacceptable and we will strive to eradicate these practices at every juncture. We champion labour rights and promote a safe working environment.



CED Business Ethical Process and Due Diligence:

Suppliers must sign up and agree to our Supplier Code of Ethical conduct. They must also sign our Ethical Business Contract. Supplier site must be fully mapped along with related quarry sources. Due diligence must be
established for the relevant sector and an understanding of cultural and country-wide issues established. There then follows a time-bound process of questionnaires, site inspections, audits and continuous monitoring to ensure that no Modern Slavery is present in the factories that make our finished products. Our general method for information gathering and initial breach targeting and resolving takes the following shape: Formalise CED policy with regards to Modern Day Slavery. Ask ethical questions at time of first contact. Inspect site to look for any areas where issues might suggest a possibility of some kind of involuntary work or poor practice in this area. Discuss with factory management and get worker input. Conduct audit to establish any gaps in Base Code compliance, discuss gaps and work with supplier to resolve. We have not uncovered any Modern Slavery within our supply chain. However, we remain vigilant and continue to implement small ethical “step by step” improvements to strengthen the worker’s position. These methods outline our business processes, built into our systems of supplier approval under our ISO 9001 – 2015 quality program. We help to encourage good practice at production sites which limits or eradicates the requirement for slave labour. Such as making sure the workers earn a living wage and all workers are given formal employment contracts. Over time SMETA audits are necessary at all factories we regularly use when purchasing from our over-seas supply-chain. These audits are assessed against the ETI Base Code and local laws. As the relationships develop, we go beyond audit and capacity build with our supplier. This currently includes investment in training, financing H&S gear, supplying ethical tools and systems guidance.



Ethical Communication:

At all times we strive to keep ethical trade and the Ethical Base Code principles at the forefront of our business strategy. The more visible and vocal we are about Modern Slavery will encourage others to support our stance and prioritise systems to avoid. We keep the topic of Modern Slavery visible in meetings and on social media. We systematically remind suppliers of their responsibilities to the workers they employ. We regularly discuss the topic with suppliers and encourage them to think more about how they can improve the environment and situation for their workers. Current work and strategy: Worker’s priority is key to how we are developing our strategy and ensuring Modern Day Slavery is not present in our supply-chain. We have gained much better access to workers over the last few years: workshops in India where priority worker issues have been discussed and actioned; CED staff talking directly to workers in India and China; tier one supplier organised worker discussions with factory workers at the factories they use for our orders. SMETA audits which include worker interviews. Surveys which include worker comments such as the Independent Evaluation of ETI Sandstone Programme in Rajasthan. We will continue to develop ways of understanding workers situation and concerns and adapt our process and strategy accordingly. Whilst we focus our resources in Asia, we also audit factories in Spain and Portugal to ensure there is no forced labour in place there. This forms part of our Iberian complete compliance programme. Beyond this we are vigilant here in the UK with regards to dealing with companies and people who provide services for us, such as maintenance and cleaning.



Current Targets to increase the effectiveness of our strategy to tackling Modern Day
Slavery:


● Ensure our guidance regarding Covid19 related issues are fully complied with by the factory management.
● Find other means to monitor and mediate while travel restrictions are in place.
● Reach further factories in China with worker interviews to monitor their situation.
● Increase our activities of working with our trading partners to help them ensure that there are no contracted employees on their sites who are forced to work against their will.
● Review our inspection and audit programmes to monitor if they are effective and calculating what else we can do to support our “zero tolerance” approach to Modern Day Slavery.
● Ensure our supplier contracts fully cover our criteria and demands with regards to employment of workers.
● Ask how we can be more effective in collaborating with both customers and suppliers to support our approach to Modern Day Slavery.
● Increase transparency and visibility further down through our supply-chain.
● Seek further collaborative ethical partnerships with other stakeholders in the areas our goods are produced.


Calum Fraser
Director – Commercial