have a dedicated compliance team, which consists of involvement from the
Milliken Industrials Limited in the UK
is a manufacturer of a diverse range of products, including floor coverings,
mats and airbag fabric, and is a provider of consulting services. We are a part
of Milliken & Company (Group), and our ultimate parent company is Milliken
& Company. Milliken has its head office in South Carolina, in the United
States of America. The Group has over 7,000 employees worldwide and operate globally.
business is organised into 4 business units: Milliken Floorcovering, Milliken
Mats, Milliken Airbag and Performance Solutions by Milliken. All business units
operate under the Milliken Industrials Limited legal entity. We have three
manufacturing sites in the UK; Wigan, Middleton and Bury. The Bury site is
unionised. The management teams of the business units report into the global
business units situated in the USA.
Industrials Limited has branch offices in Ireland, Russia, Sweden and Denmark
to support its international business activities.
supply chains differ by business division within the legal entity.
Milliken Floorcovering: Raw materials for carpet
and luxury vinyl tiles are sourced from Europe, North America and China. In
terms of selling our products our routes to market do differ by region but
predominantly the business sells through a network of distributors and dealers
who work with construction contractors and architects to have our products
specified into projects. Alternatively, we supply end users directly with their
floor covering requirements.
have a global sourcing program for raw materials for Milliken mats, which is reviewed
quarterly to determine the optimum source of raw materials. The regions that we
source from include Europe, North America and Asia. The majority of our mats
are supplied to laundries, which then place our mats in situ at their
customers’ premises. We supply logo printed mats for commercial use to various
Airbag: The majority of sourcing for the
airbag business, including raw materials, machinery, spare parts and chemicals
comes from the European Union. Our coated fabric is then supplied to an OEM
that cuts and sews the airbags for supply to the automotive industry.
Performance Solutions by Milliken is our consulting business
that provides knowledge and training to clients based on our experiences in
safety and operational excellence. Global clients are sourced through our
business development team located in the US. Our practitioners spend a
significant amount of time at the clients’ premises to deliver the training,
coaching and mentoring.
policies on slavery and human trafficking
are committed to ensuring that there is no modern slavery or human trafficking
in our supply chains or in any part of our business. Our Code
of Conduct reflects our commitment to acting ethically and with integrity
in all our business relationships and to implementing and enforcing effective
systems and controls to ensure slavery and human trafficking is not taking
place anywhere in our supply chains. All Milliken associates commit to the Code
of Conduct annually. We have spent a significant amount of time reviewing the
Code of Conduct during the course of this year to ensure that it is up to date
and is benchmarked against companies of a similar size and footprint.
ask all new suppliers to sign up to Milliken’s Supplier
Code of Conduct or demonstrate that they have their own codes of conduct
embedded in their organisations. Our Supplier Code of Conduct prohibits child,
forced or involuntary labour of any type (including forced, bonded, indentured
or involuntary prison labour).
Employment must be voluntary.
Milliken reserves the right to terminate its relationship with any
supplier who refuses to comply with the ethical principles of our Supplier Code
recruiting staff within Milliken Industrials Limited, our HR team ensure that
every applicant has the necessary identification and rights to work. All
Milliken Industrials Limited employees are paid above both the minimum wage and
living wage. Our Payroll and Benefits team audit salaries regularly and will
accordingly flag any wages below those levels. Milliken often uses agency
workers to provide flexibility to its work force at peak times. We have long standing relationships with our
employment agencies and ensure that the same level of salary is paid to agency workers
as to permanent staff in accordance with UK employment legislation.
our own organisation we also have a commitment to responsible and sustainable
diligence processes for slavery and human trafficking
have in place systems to:
and assess potential risk areas in our supply chains.
the risk of slavery and human trafficking occurring in our supply chains.
potential risk areas in our supply chains.
part of our initiative to identify and mitigate risk we follow the following
engage a new supplier as a basic level:
send a new supplier questionnaire, which includes a commitment to our ethics
the supplier to sign a copy of our Supplier Code of Conduct.
addition, key strategic suppliers or suppliers in vulnerable areas or those
that are in high corruption perception index countries undergo an in-country
audit. Members of the procurement team may visit the local premises and meet
with key representatives of the supplier to ensure that health and safety and
ethical standards are at an acceptable level. We also risk assess all key
suppliers and implement a FMEA (Failure mode and effect analysis) audit for
those that are classified as elevated or high risk. Given the nature of
Milliken’s business and the high quality of our suppliers, we do not typically
utilize third party auditors to audit suppliers.
third-party, anonymous (if allowed by the laws of the caller’s country) Alert
Line hotline is available to all Milliken employees as well as our suppliers to
raise concerns about unethical conduct.
All are encouraged to report any violation of the Supplier Code of
Conduct to Milliken’s management or via the Alert Line. The Alert Line is advertised
on notice boards at Milliken sites and is detailed in our publicly available
Codes of Conduct. We also demonstrate a commitment to non-retaliation in our
Code of Conduct.
implement a compliance due diligence process for high risk third party
intermediaries such as agents, distributors and specifiers.
Milliken administrative and management employees undergo annual training on our
Code of Conduct. All training for employees is recorded in our online GEM
system. Selected training around ethics and bribery is available to certain of
our suppliers and commercial agents as well.
ensure a high level of understanding of the risks of modern slavery and human
trafficking in our supply chains and our business, we will be developing a
specific program of training for those people who visit suppliers to ensure
they are clear of the risks and examples to look for that may indicate modern
a review of the effectiveness of the steps we have taken to ensure that there
is no slavery or human trafficking in our supply chains we intend to take the
following further steps to combat slavery and human trafficking:
a separate Modern Slavery and Human Trafficking policy.
map our supply chain to cover the entire scope of our business, encompassing
Operations, Property, Logistics, HR, IT and International, as well as
continuing to focus on our product supply chains, and prioritise the highest
investigate our supply chain with regard to their approach towards Modern
Slavery and Human Trafficking.
a Training programme to roll out to key staff to ensure they fully understand
the risks and how it applies to our specific supply chain.
specific KPIs for supply chain.
plan to assess and consider the development of further measures including (i)
the response to our Code of Conduct; and (ii) the potential audit of specific
suppliers where we determine that there
may be a heightened risk of slavery and trafficking within those organisations.
statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and
constitutes our slavery and human trafficking statement for the financial year
ending 28 November 2016.