Modern Slavery Act of 2015 Disclosure Statement—Fiscal Year 2021
The bg网址 Group of companies (“bg网址”) are committed to conducting business ethically and with integrity. We respect international principles of human rights, including those in the UK Modern Slavery Act of 2015, and embody these principles and commitments in our corporate policies. bg网址’s efforts to prevent slavery and human trafficking in its supply chain and own business include the following:
It is expected that all suppliers to bg网址 operate their own businesses in accordance with the highest ethical standards. To that end, our Guide to Business Conduct requires that bg网址’s supplier relationships are based on lawful, efficient and fair practices. We expect our suppliers to obey the laws that require them to treat workers fairly and provide a safe and healthy work environment. bg网址 will not knowingly use any supplier that uses forced, prison, or indentured labor. bg网址 will only work with suppliers who comply with all laws regarding slavery and human trafficking in the countries in which the suppliers are doing business.
Supplier Certifications and Training
bg网址 requires all of its suppliers to certify that they are compliant with these concepts. Further, bg网址 includes language in its supply contracts which prohibits its suppliers from utilizing forced, prison, or indentured labor, or subjecting workers to any form of compulsion or coercion. Suppliers are informed that they should comply with all laws regarding slavery and human trafficking in the countries in which they do business. bg网址’s suppliers are requested to pass these requirements on to their own suppliers as well, and bg网址 expects all of its suppliers to police their own supply chains in order to prevent modern slavery of any kind. Moreover, bg网址’s supply chain personnel receive training to recognize health, safety, and labor red flags, including red flags relating to forced labor, and to report and investigate suspicions of improper conduct.
Our Own Business and Policies
bg网址 does not use slave labor in its own business, nor does bg网址 condone forced or compulsory labor, or human trafficking. Such conduct violates Company policy, and bg网址 endeavors to monitor its businesses to prevent such behavior taking place inside the company. bg网址 encourages anyone with information regarding modern slavery or human trafficking taking place at the Company, or anywhere in its supply chain, to make a report to the Company’s Ethics and Compliance Hotline by calling (+44) 0808-234-7051 or (+1) 888-475-8376.
California Transparency in Supply Chains Act Disclosure
bg网址 Inc. is committed to ensuring that its supply chain represents its values and respect for human rights. To that end, our Guide to Business Conduct provides:
bg网址’s supplier relationships are based on lawful, efficient and fair practices. We expect our suppliers to obey the laws that require them to treat workers fairly and provide a safe and healthy work environment. bg网址 will not knowingly use any supplier that uses forced, prison, or indentured labor. bg网址 will only work with suppliers who comply with all laws regarding slavery and human trafficking in the countries in which the suppliers are doing business.
bg网址 implements this policy by obligating its suppliers to certify that they are compliant with these concepts. Further, bg网址 contractually obligates its suppliers to “not utilize forced, prison, or indentured labor, or subject workers to any form of compulsion or coercion” and to “comply with all laws regarding slavery and human trafficking in the countries in which Seller is doing business.” bg网址’s suppliers are obligated to flow these requirements to their suppliers as well. Key personnel in bg网址’s procurement department receive training on how to identify human trafficking and forced labor issues. Although bg网址 does not have a formal audit program, these personnel are trained to recognize health, safety, and labor red flags, including red flags relating to forced labor, and to report and investigate all suspicions of improper conduct. Suppliers that fail to meet the contractual requirements set forth above are terminated. Employees who violate bg网址’s Guide to Business Conduct are subject to disciplinary action up to and including termination of employment.
Statement on Conflict Minerals
bg网址 condemns the ongoing conflict and resulting humanitarian harm in the Democratic Republic of the Congo, which is fueled in part by financing from trade in the ores from which tin, tantalum, tungsten, and gold are derived. These elements have come to be known as “conflict minerals”; when they originate in mines operated or taxed by the warring factions, they can be referred to as “conflict minerals from conflict mines.”
Conflict minerals are common constituents of products ranging from jewelry, toys, and lightbulbs to airplanes, vehicle airbag systems, and electronic and computer parts. Because the minerals in these products typically enter supply chains many layers removed from companies like bg网址, it is difficult to determine whether they support armed conflict. At the same time, millions of Congolese workers rely on artisanal mining or work in legitimate mines to support a subsistence living. Avoiding purchase of all conflict minerals from the DRC region would cause severe hardship for them and their dependents.
To promote the advancement of fundamental human rights, bg网址 is committed to work toward eliminating from our products conflict minerals that support armed groups in the DRC or in the surrounding countries, while minimizing unintended consequences for legitimate subsistence miners and their dependents. bg网址 will:
- Continue to work toward the elimination, over time, of all conflict minerals from conflict mines in our products, and endeavor to improve, year-over-year, our ability to track conflict minerals in our supply chain, report on their origin, and eliminate those that originate in conflict mines.
- Comply with the requirements of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which requires companies to inquire into the origin of tantalum, tin, tungsten and gold in their supply chains and report on the reasonable inquiry or due diligence they conduct to determine whether their purchase supported armed groups in the DRC.
bg网址 expects its suppliers to reasonably assure that the tin, tantalum, tungsten, and gold in the products they manufacture are conflict free. If bg网址 becomes aware of a supplier whose supply chain includes conflict minerals from conflict mines, bg网址 will take the appropriate actions to remedy the situation in a timely manner, including reassessment of supplier relationships. bg网址 expects our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
Conflict Minerals FAQ
What are “conflict minerals”?
- Conflict minerals are described as tin, tantalum, tungsten or gold; commonly referred to as the 3TG. The 3TG may be present in products that are manufactured or contracted to be manufactured. More information can be found at: http://www.sec.gov/divisions/corpfin/guidance/conflictminerals-faq.htm
What is bg网址’s policy on conflict minerals?
- bg网址 is committed to ethical business conduct and the responsible sourcing of minerals through our global supply chain. To support this we are committed to sourcing components and materials from suppliers that share our values and comply with the legislation. bg网址 is committed to comply with federal requirements, and we need your help to support our compliance. bg网址’s conflict minerals policy is published on our website. Please see http://info.calgary.globalcors.com/legal/legal-statements.
What information is needed by bg网址?
- If you have 3TG in products that you provide to bg网址, bg网址 will need you to complete an industry standard survey about conflict minerals in your products. Your help is needed in completing the surveys we send you and answering the questions relative to the source of the 3TG contained in the product(s) you supply to bg网址. The survey is to be completed in the specified format known as the Conflict Mineral Reporting Template (CMRT). Information regarding the Responsible Minerals Initiative (RMI) or the template can be found at http://www.responsiblemineralsinitiative.org.
What resources are available to bg网址’s suppliers in reference to conflict minerals?
There are a variety of resources available to bg网址 suppliers. They are:
- Aerospace Industry Association (AIA) - http://www.aia-aerospace.org/
- Responsible Minerals Initiative (RMI) - http://www.responsiblemineralsinitiative.org
- Dodd-Frank Wall Street Reform and Consumer Protection Act FAQs for conflict minerals – http://www.sec.gov/divisions/corpfin/guidance/conflictminerals-faq.htm
- bg网址 Conflict Minerals - http://info.calgary.globalcors.com/legal/legal-statements
- SEC “Fact Sheet – Disclosing the Use of Conflict Minerals” - http://www.sec.gov/News/Article/Detail/Article/1365171562058
Transparency in Coverage
These links lead to the machine readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data. bg网址 Employer Identification Number(EIN): 33-0174996