Vorwerk UK Limited – Company Number 05228875
Address – Ashurst Park, Church Lane, Ascot, Berkshire. SL5 7DD
Transparency in Supply Chain Statement for the financial year ending 31 December 2022
1.1 Vorwerk UK Limited ("Vorwerk") is committed to preventing modern slavery and human trafficking in its business and supply chains.
1.2 In accordance with its obligation under the Modern Slavery Act 2015 (the "2015 Act"), Vorwerk sets out below a statement of the steps taken in the last financial year to minimize the risk of slavery and human trafficking not taking place in any part of Vorwerk's business or in any of its supply chains.
2. Our business
2.1 Vorwerk develops and manufactures homeware products, trading under the Thermomix® and Kobold® brands.
2.2 Vorwerk's products are manufactured in China, France and Germany before being shipped to the UK for distribution.
3. Our supply chains
3.2 When engaging with suppliers, we undertake legal and compliance due diligence before committing to engage with a supplier. This process was in place throughout 2022.
3.3 [Codes of Conduct]
The Vorwerk Group’s Supplier Code of Conduct for Business Partners [published in November 2022] sets out fundamental ethical and behavioural principles and applies to all business partners who collaborate with the Vorwerk Group. https://www.vorwerk-group.com/de/meta/einkauf/codes-of-conduct/Code-of-Conduct-for-Business-Partner_en.pdf
3.4 In line with the Supplier Code of Conduct for Business Partners, Vorwerk does not partner or conduct business with any individual or company that participates in:
(a) Forced, bonded or indentured labour or involuntary prison labour ILO Forced Labour Convention (No. 29) and the ILO Abolition of Forced Labour Convention (No. 105).
(b) The exploitation of children (including child labour defined in the ILO Convention No. 138 on minimum age and the ILO Convention No.182 on the Worst Forms of Child Labour).
(c) Harassment or discrimination.
(d) Harsh or inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers or the threat of any such treatment; or
(e) Human trafficking or any form of modern slavery.
3.5 Vorwerk expects suppliers and partners to:
(a) Pay workers according to applicable wage laws, including minimum wage, overtime and mandatory benefits.
(b) Respect the rights of workers in compliance with local laws to associate freely, join or not join labour unions, seek representation, to join workers' councils; and
(c) Protect the workers' health and safety.
4. Our controls
(a) Ethical behaviour is the foundation of our success in achieving our business objectives and we recognise it is in our best interest to set high standards for ourselves at all times, including not engaging in modern slavery or human trafficking, and to align ourselves with agents, representatives, suppliers and partners who have similar high standards of business conduct.
(b) Vorwerk has in place a Code of Conduct for Business Partners. It is expected that the Code and the supporting policies and guidelines that go with it, as well as the laws and regulations of the countries where staff work, will be followed. If norms from different countries contradict each other, the stricter rule should be applied. This includes complying with applicable anti-slavery and human trafficking laws.
(c) Vorwerk has in place an Employee Handbook, which covers the following areas.
(i) Gratuities and Bribery - It is our policy to conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
(ii) Equal Opportunities – Following the Equality Act 2010, Vorwerk does not discriminate because of age, disability, sex, gender reassignment, pregnancy, maternity, race (which includes colour, nationality and ethnic or national origins), sexual orientation, religion or belief, or because someone is married or in a civil partnership. These are known as "protected characteristics”.
(iii) Harassment - Vorwerk will not tolerate employee behaviour or conduct which involves the harassment or bullying of any fellow employee or third party; such behaviour is completely unacceptable.
4.2 Risk assessment
4.2.1 Vorwerk is not aware of any slavery or human trafficking issues within its business or supply chains during 2022. In the last financial year, no potential issues of this type have been identified or reported through internal reporting channels, audit processes, whistleblowing or otherwise.
4.2.2 We consider that adherence to and compliance with our policies and procedures, should reduce the risks of modern slavery occurring in our business or supply chains
4.2.3 On this basis, we consider the risk of slavery or human trafficking for Vorwerk in its business and its supply chain continues to be low. However, we recognise that the international nature of our business operations may give rise to modern slavery risks, and the need to keep these risks and controls under review. Vorwerk is committed to preventing slavery or human trafficking in its business or supply chains. For this we have established due diligence measures regarding our employees and our suppliers.
4.3 Due Diligence
(a) All employees have a contract of employment that determines their rights and obligations including their salary, hours of work, and their notice period to terminate the contract, and their holiday entitlement.
(b) Employment contracts are reviewed annually to ensure Vorwerk is legally compliant.
(c) Employees are free to hand in their notice at any time.
(d) All employees are paid at least the national minimum wage, and auto enrolled into the pension scheme within the legal timeframes.
(e) All employees need to provide bank details which include their names. We do not pay salary into another person’s account nor to someone not employed by Vorwerk.
(f) Vorwerk adheres to all legislation regarding employment contracts, wages, health and safety, working time, holiday entitlement and rest breaks.
(g) All employees undertake an induction process where points of the contract and support are signposted.
(h) Vorwerk operates a Whistleblowing Policy and procedure. https://www.vorwerk-group.com/en/home/about_vorwerk/corporate-governance
(i) We provide training on the policies and relevant laws and regulations applicable to staff and partners' roles. All employees are made aware of both the Harassment Policy and Working Hours Policy.
4.3.2 Supply Chain
As part of Vorwerk Group, is establishing human rights due diligence measures in its procurement practices in line with the supplier’s requirements set out in the Vorwerk Code of Conduct for Business Partners.
4.4 Breach of Policies
(a) Vorwerk is not aware of any breach/human rights violation in its own operations or at its suppliers. If any case is found/reported, Vorwerk will investigate and take appropriate action.
5. Current and future further actions
5.1 In the coming year, Vorwerk will proactively consider what further steps could be taken to ensure modern slavery and human trafficking is not occurring in its business and supply chains.
In addition, Vorwerk Group will conduct a human rights risk analysis to identify, minimize and eliminate potential human rights violations in its own business and supply chains. This analysis will cover Vorwerk UK.
6. Approval of this statement
6.1 This statement was approved by the Management Board of Vorwerk UK Limited on May 23rd 2023.
6.2 This statement was signed by James Day, a Director of Vorwerk UK Limited on May 23rd 2023