This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Turmec Teoranta has taken and is continuing to take to ensure that modern slavery or human trafficking are not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labor. Turmec Teoranta has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our business

Turmec is a world leader in recycling solutions, providing turnkey resources for the waste sector worldwide. The company designs, manufactures and installs bespoke recycling systems which allow waste collectors to increase their recycling rate, recover higher-quality material from recycled waste most efficiently and cost-effectively, and divert waste away from landfill. All the equipment is designed in-house, manufactured in Rathcairn, Co. Meath and delivered worldwide, with installation and electrical teams sent to fit and commission the plants.

Turmec’s main export markets are currently the UK, Australia, EU and U.A.E. and around 90% of what the company manufactures is for export; of this 90%, 2/3rds goes to the UK and the majority of the remaining 1/3rd is exported to Australia.

Turmec works with various suppliers worldwide.

Our high-risk areas

The following activities are at risk of modern slavery within Turmec Teoranta and the list will be reviewed and updated from time to time:

• Use of staff by subcontractors or suppliers to Turmec Teoranta, where the suppliers’ processes are not compliant
• Employment of sub consultants, suppliers and sub-contractors by Turmec Teoranta, where their work practices may be non-compliant.

Our policies and procedures

We operate several internal policies and procedures to ensure that we are conducting business in an ethical and transparent manner.

Relevant policies and practices Turmec have in place describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations and these include:

1. Anti-Slavery and Human Trafficking policy and procedure – reiterating our position against all forms modern slavery, this policy outlines our procedures and processes which are designed to guard against the occurrence of modern slavery or human trafficking in our business operations as well as supply chain.
2. Whistleblowing policy and procedure – encourages our employees to report any concerns related to both, the direct activities or the supply chain, within the company. This include any situations that may give rise to an enhanced risk of slavery or human trafficking. We investigate every whistleblowing case and seek to achieve resolution within the shortest possible timescales.
3. Supplier code of conduct – Turmec insists on ethical standards from all of our suppliers; these are required to confirm that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
4. Recruitment policy and procedure – Turmec works only with recruitment agencies which share our commitment towards anti- slavery and the prevention of human trafficking.

Due diligence

The company undertakes due diligence when considering new suppliers and partnerships, and regularly reviews both. The organisation’s due diligence and reviews include:

1. Evaluating the modern slavery and human trafficking risks of each new partner and/or supplier
2. Reviewing the supply chain broadly to assess product, sector or geographical risks of modern slavery and human trafficking.

Our suppliers

Turmec Teoranta operates a supplier policy and maintains a preferred supplier list.  We conduct due diligence on all suppliers before allowing them to become a preferred supplier.  This due diligence includes an online search to ensure that organisations has never been convicted of offenses relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

1. They have taken steps to eradicate modern slavery within their business
2. They hold their own suppliers to account over modern slavery
3. (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
4. (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
5. We may terminate the contract at any time should any instances of modern slavery come to light]

Training

We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Approval for this statement

This statement was approved by the Board of Directors on November 2019