This statement has been published pursuant to the requirements under section 54 of the UK Modern Slavery Act 2015 and the California Transparency in Supply Chain Act of 2010. It provides information regarding the business practices of Spectris plc, the holding company, its subsidiary companies, other companies within the Spectris group1 (together, “Spectris”/the “Group”), and the steps Spectris has taken to ensure modern slavery and human trafficking (“MS&HT”) is not taking place in its business and supply chains.
Spectris has a zero-tolerance approach to any form of modern slavery or human trafficking. It is committed to acting ethically, with integrity and transparency in all business dealings and it is committed to implementing effective systems and controls to safeguard against any form of MS&HT in any part of its business or operations. The Group considers that the risk of MS&HT taking place within its business or supply chain is relatively low and to date we have not uncovered an evidence of MS&HT within our business operations.
Spectris is a diverse business, with operations and over 7,600 employees in more than 30 countries. We provide critical insights to our customers through premium precision measurement solutions combined with technical expertise and deep domain knowledge. Precision is at the heart of what we do - our leading, high-tech instruments and software equip our customers to solve some of their greatest challenges to make the world cleaner, healthier and more productive. Spectris is focused on two key divisions - Spectris Scientific and Spectris Dynamics, which are placed in technology-driven end markets, with strong fundamentals and attractive growth trajectories.
Our businesses are united by the same purpose, the same values and the same corporate strategy. They all work according to a strong common framework of controls, management KPIs, financial discipline and rigorous operating principles, but each business is focused on its own markets, customers and technologies.
We recruit, develop and promote our people based on their talent, commitment and achievement; we continuously endeavour to ensure that everyone is treated equally and fairly whatever their race, colour, religion, national origin, gender, sexual orientation, age, disability or background. Spectris is a very specialised and technical business, and we rely on the skills and expertise of our people, many of whom are highly qualified engineers and technicians.
A summary of the businesses covered by this statement is below:
Malvern Panalytical is a leader in the advanced measurement and characterisation of materials. The company provides best-in-class sensor technologies, insightful data science and domain knowledge. They create superior solutions to accelerate innovation and deliver greater efficiency in R&D and manufacturing.
Particle Measuring Systems
Particle Measuring Systems specialises in particle counters that measure and monitor contamination levels in clean and controlled environments. With more than 60 patents, PMS create the technology that enables customers to make fact-based decisions, improve process yield and comply with changing regulatory requirements.
HBK provides a strongly differentiated and integrated physical sensing, testing, modelling and simulation solution which helps customers create leading products and accelerate product development. By delivering reliable precision through technologies that integrate the physical and virtual domains, developers can gain unprecedented insight into their product data and processes.
Red Lion Controls
Red Lion Controls manufactures a variety of industrial control products, from timers and counters to complex man-machine interfaces and has the latest surface mount and chip-on-board production capabilities. Red Lion's engineering team provides new product design both for a wide range of standard control products and as well as custom and OEM requirements.
Servomex is a leading supplier of gas analysers (for use in both hazardous and safe area applications) gas analysis systems and transducers, combined with a full
range of customer support products and services.
Our Supply Chains
Due to Spectris’ diverse business activities, it has a diverse supply chain. Spectris is committed to preventing MS&HT in its corporate activities, and to working with its supply chain to achieve this commitment. Spectris is committed to promoting responsible business practices with our suppliers as outlined in more detail below. Our objective is to build long-term shareholder value sustainably by supplying productivity-enhancing solutions and services for our customers. To achieve this, we need a global high-performance supply chain.
Spectris has high standards of business conduct applicable to the whole organisation. We govern the actions of our company and employees and hold them to the highest level of ethical and social accountability. Our goal is to work with suppliers who embrace and comply with the same principles as our own.
Spectris places high priority on compliance with the legislative and ethical requirements of the countries in which we operate, particularly with respect to employment practices, labour rights and equal opportunities. The Spectris plc HR Director has overall responsibility for employment policies, but responsibility for implementation is delegated to individual businesses, with operational policies and procedures tailored to suit local needs. We have a Group personnel policy, which includes the induction/onboarding process and makes mandatory a walkthrough of the group Values and Code of Business Ethics, including whistleblowing policy and hotline, and our commitment to equality.
Although Spectris does not have a specific MS&HT policy, it has other policies and procedures in place which address its MS&HT compliance requirements and standards. Details of these policies are outlined here.
Spectris maintains and issues policies and guidance at a Group level so that it can standardise and maintain oversight of the interactions that companies have with their suppliers. In the event that local legislation prevents compliance with Group policies and guidance (which is expected to be rare), businesses are required to explain their non-compliance and proposed mitigating actions and ensure that they have a dispensation from Spectris plc in place. An annual sign-off is required on the year-end financial reporting package, together with a statement that all relevant information has been disclosed to the external auditors.
Wherever possible Spectris uses a standardised sourcing agreement which includes key principles and values expected of suppliers. The standardised sourcing agreement is then tailored to specific laws governing the jurisdictions in which the Spectris group companies operate.
Our Human Rights Policy is consistent with the Core Conventions of the International Labour Organisation. Spectris aims to comply with internationally recognised human rights standards at all of our sites. We operate a number of additional internal policies to ensure that we are conducting business in an ethical and transparent manner. The internal policies include:
Supply Chain Management
We believe that suppliers, and other business partners, should have the opportunity to benefit from their relationship with us. In practice, this means that we work together to minimise and manage business risk and improve business practices, through education, training and the sharing of good practice.
Supply Chain Management Policy
In addition to the above, our Supply Chain Management Policy outlines the requirements we have of our suppliers which include a commitment to:
In addition to the above, we are progressively rolling out additional MS&HT prevention measures at Spectris entities, for example by including an express reference to the commitment to preventing MS&HT in their “Terms and Conditions for Purchase of Goods and/or Services”, requiring suppliers to “comply with all applicable laws relating to slavery and human trafficking including the Modern Slavery Act 2015.”
In addition to due diligence processes, Spectris conduct on-site visits to investigate the specific operations of key suppliers. This allows Spectris to analyse a supplier’s specific practices and procedures. Where risks are identified by our on-site team during these visits this may lead to further investigations and potentially a full audit. New and potential suppliers are made aware of the Spectris compliance framework.
Spectris is committed to identifying and preventing all forms of MS&HT in our business and supply chain. To this end, we implemented robust risk assessment procedures. For example, one of our entities screens for public information on our key suppliers, using the cloud-based Risk-Management solution “RiskMethods.” On-site visits and/or audits are undertaken. The Spectris DD toolkit is used for the evaluation of sales channel partners and the Dow Jones Risk Averter tool is used by some businesses to verify and monitor them.
The Group has assessed its supply chain against the top twenty countries identified in the Global Slavery Index to assess the geographical risks of modern slavery and human trafficking in the Group’s supply chain. Based on this assessment, the Group has focused attention on its manufacturing operations and key suppliers in South East Asia to ensure compliance with the SA8000 Social Accountability Standard (SA 8000). The Group has trained employees in the Spectris Asia Pacific supply chain to review and support compliance with SA8000 and key suppliers have been audited against the SA8000 standard by our auditors to ensure that they have attained the certification standard.
MODERN SLAVERY & HUMAN TRAFFICKING TRAINING
Spectris recognises that all supply chain management staff within the organisation working in all countries need to complete risk-based MS&HT training. Spectris does undertake regular refresher training on the Code of Business Ethics which includes training on fair employment, human rights and working with partners and suppliers. In 2021, comprehensive risk-based training on modern slavery and human trafficking was rolled out across Spectris to individuals who have direct contact with the Group’s supply chain.
FUTURE STEPS/ ANY OTHER ACTION
As part of our commitment to improving our procedures to identify and prevent MS&HT, a review of the Group’s Supplier Code will be undertaken in 2023 as part of a wider re-assessment of the social risk in the Group’s operations and supply chain.
This statement has been examined and approved by the Board of Spectris plc on 26 May 2023.
This statement relates to Spectris plc (UK Company Number 02025003) and the following subsidiary companies:
1 This statement sets out the steps taken by Spectris plc and the list of subsidiary companies set out in Appendix One.