FENDER MUSICAL INSTRUMENTS EUROPE LIMITED
SLAVERY AND HUMAN TRAFFICKING STATEMENT
We, Fender Musical Instruments Europe Limited, are committed to improving our practices to combat slavery and human trafficking. Our aim is to market and sell musical instruments and accessories in a way that helps, and does not hurt, the people and communities involved in our business.
2. ORGANISATION'S STRUCTURE
We are a part of the Fender Musical Instruments Corporation group of companies (FMIC Group), and our ultimate parent company is Fender Musical Instruments Corporation (FMIC). FMIC has its head office in Scottsdale, Arizona, United States of America. We provide marketing and sales support services to FMIC in the sale of musical instruments.
3. OUR BUSINESS
Our business activity (and turnover) is concentrated on the sale of musical instruments and accessories in Great Britain, Austria, Belgium, Bulgaria, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Latvia, Lithuania, Luxembourg, Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia, Spain, Sweden, Switzerland, and greater Europe.
4. OUR SUPPLY CHAINS
The FMIC supply chain includes the sourcing of materials and components principally related to the manufacture of FMIC products and related services.
5. OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. The FMIC Group’s Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships. We seek to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place any where in our (and the FMIC Group’s) supply chains.
6. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
We (as part of the FMIC Group) have in place systems to: (1) identify and assess potential risk areas in our supply chains; (2) mitigate the risk of slavery and human trafficking occurring in our supply chains; (3) monitor potential risk areas in our supply chains; and (4) protect whistle blowers.
We maintain internal accountability standards and procedures for employees failing to meet company standards regarding slavery and trafficking. The FMIC Group's Code of Conduct holds personnel accountable for ensuring compliance and ethical standards in The FMIC Group's international business.
At this time The FMIC Group does not conduct independent, unannounced inspections of third party facilities in its supply chain (in part due to challenges such as visa requirements in territories where The FMIC Group conducts business). However, for scheduled visits to OEM partner facilities in territories with such requirements, The FMIC Group now routinely includes unannounced agenda items dealing directly with human slavery detection and prevention. Going forward, The FMIC Group is actively seeking opportunities to incorporate independent, unannounced audits into its compliance plan.
7. SUPPLIER ADHERENCE TO OUR VALUES
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we (through the FMIC Group) have in place a supply chain compliance programme. This consists of :
- • All of the FMIC Group's direct suppliers have received a bulletin that announces the FMIC Group's policy of combatting slavery and human trafficking.
- • The FMIC Group’s standard purchase order (PO) terms require all direct suppliers to represent and warrant that products made for and on behalf of the FMIC Group, are in compliance with laws prohibiting slavery and human trafficking.
- • Senior supply chain managers in the FMIC Group have personally met with some of the FMIC Group's most critical OEM partners, to instil ongoing cooperation in the FMIC Group's commitment against unlawful labour in its supply chain. Master agreements with these critical OEMs contain (like the FMIC Group's standard PO terms) prohibitions against slavery and human trafficking
- • In territories around the world where the FMIC Group does not sell direct and instead relies upon third party distributors, written distributor agreements are used that contain specific provisions against slavery and human trafficking.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide periodic training to our staff..
As part of the FMIC Group, we maintain internal accountability standards and procedures for employees failing to meet company standards regarding slavery and human trafficking. The FMIC Group's Code of Conduct holds personnel accountable for ensuring compliance and ethical standards in the FMIC Group's international business. The FMIC Group maintains a compliance "hotline" that all personnel are instructed to use in the event violations of law or policies are suspected and/or detected.
9. OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
- • Instances of breaches of Modern Slavery Act;
- • Use of labour monitoring and payroll systems to check eligibility of employees in the UK; and
- • Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.
We welcome input from all our stakeholders on this important issue. If you have any questions or require further information, or simply would like a copy of this statement, please email us. We will provide you with a copy of the statement within 30 days of receiving your request, and will respond to your questions or information request within the same timescale, if possible.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the current financial year.
FENDER MUSICAL INSTRUMENTS EUROPE LIMITED
Date: 30 December 2016