English > Supply Chain Disclosure | Milliken

Supply Chain Disclosure

Milliken's commitment to transparency in our supply chain

Cal. Civ. Code § 1714.43

Milliken encourages the State of California and similarly situated governments to pass wise laws that can be efficiently implemented, have a real impact on the many problems in their jurisdictions and truly make the World a better place.
 
Milliken is committed to treating our suppliers, customers, communities and environments with the highest level of integrity and respect.  That commitment is reflected in our strong supply-chain relationships, high-quality products, employee welfare, community reputation and minimal environmental impact.  As a socially responsible family of companies, we believe that our supplier partners should share this commitment.
 
Milliken is very proud of its own internal Code of Conduct, and we require that all of our employees reconfirm their compliance with our Code on an annual basis.  Similarly, we expect our suppliers to uphold the ethical business principles of our Supplier Code of Conduct (or their own code if it is substantially similar) and the highest, applicable international standards.
 
Our Supplier Code of Conduct prohibits child, forced or involuntary labor of any type (including forced, bonded, indentured or involuntary prison labor).  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 of Conduct.
 
As part of our global procurement process, Milliken evaluates our supply chain for risk, including human rights and labor risks such as child, forced or involuntary labor.  As appropriate, Milliken may audit our suppliers.  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.  Milliken’s 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.  All are encouraged to report any violation of the Supplier Code of Conduct to Milliken’s management or via the Alert Line.
 
All Milliken employees undergo annual training on our Code of Conduct.  Selected training is available to certain of our suppliers as well.
 
Further information on Milliken’s commitment to corporate social responsibility is provided on Our Values and Sustainability web pages.



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Modern Slavery Act 2015

We are proud of the steps we have taken to combat slavery and human trafficking. We have a strong commitment to ethical practices and are proud of our values embedded in our code of conduct. We have been awarded the World’s Most Ethical Company award by Ethisphere for the last consecutive 11 years.

We have a dedicated compliance team, which consists of involvement from the following departments:

·         Board of Directors.
·         Legal.
·         Finance.
·         Compliance.
·         Human Resources.
·         Procurement.
·         Business Management.

Organisation's Structure

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.

Our Business

Our 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.

Milliken Industrials Limited has branch offices in Ireland, Russia, Sweden and Denmark to support its international business activities.

Our Supply Chains

Our 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.

We 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 end users. 

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. 


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. 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.

We 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 of Conduct. 

When 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.

Within our own organisation we also have a commitment to responsible and sustainable manufacturing: Sustainability Commitment

Due diligence processes for slavery and human trafficking

We have in place systems to:

·         Identify and assess potential risk areas in our supply chains.
·         Mitigate the risk of slavery and human trafficking occurring in our supply chains.
·         Monitor potential risk areas in our supply chains.
·         Protect whistle blowers.

As part of our initiative to identify and mitigate risk we follow the following procedures:

1.   To engage a new supplier as a basic level:

a.    We send a new supplier questionnaire, which includes a commitment to our ethics standards; and

b.    Require the supplier to sign a copy of our Supplier Code of Conduct.

In 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. 

2.   Milliken’s 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.

3.   We implement a compliance due diligence process for high risk third party intermediaries such as agents, distributors and specifiers.

Training

All 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.

To 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 slavery.

Further steps

Following 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:

·         Develop a separate Modern Slavery and Human Trafficking policy.​​

·         Better 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 risk suppliers.

·         Better investigate our supply chain with regard to their approach towards Modern Slavery and Human Trafficking.

·         Develop 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.

·         Set specific KPIs for supply chain.

·         We 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. 

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 financial year ending 28 November 2016.