The breadth, depth and interconnectedness of the automotive supply chain make it challenging to effectively manage business and sustainability issues. Respecting human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility. As customers, however, we play an active role in supplier development and have adopted various means to clearly communicate our expectations to our suppliers.

We operate from a number of sites which are based throughout the United Kingdom and Europe, typically our customers are businesses in the following channels and sectors:

• After-Market
• Agricultural
• Commercial
• Fast Fit
• Golf
• Industrial
• Leisure
• Marine
• Motor Accessories
• OE (Original Equipment) / OES (Original Equipment Supply)

As a company Platinum International supplies automotive parts, such as Batteries, and automotive consumables, such as Lubricants (Oil), to an international market. All products that we purchase, within our supply chain, are highly technical products which require a high degree of:

• Automated specialist production,
• Consistent product delivery standards, and are typically from
• Tier 1 manufacturers

The above nature of the products that we purchase, typically defines our supply chain as being not labour intensive, requires specialist operators and is highly automated. For suppliers, this creates barriers to entry without significant financial investment in both machinery and human capital.

We expect all those in our supply chain to comply with our zero tolerance approach to slavery and human trafficking. Suppliers must act ethically and within the law, in their use of labour. Should suppliers become unable to meet this standard, we would look to terminate the business relationship.

In our standard procurement process, we issue purchase orders that incorporate our Terms and Conditions. The T&Cs are further supplemented by Company Policies, which expand on our expectations and suppliers’ obligations on specific topics. For example, our Corporate Governance Policy sets out the prohibition of child labour, forced labour (including human trafficking), physical disciplinary abuse and any infraction of the law. Additionally it also covers our Social Responsibility, Anti-Corruption and our Environmental requirements. Our Corporate Governance Policy seeks to challenge the violation of Human Rights, Basic Working Conditions and uphold good Corporate Responsibility. This is in order to address workplace issues such as, working hours, child labour, forced labour, discrimination, freedom of association, Health & Safety and environmental concerns.

This policy applies to our own Company and we encourage businesses throughout our supply chain to adopt and enforce similar policies, in their own operations. Furthermore, we seek to identify and do business with companies that have aligned standards consistent with our Corporate Governance Policy.
Slavery and Human Trafficking
Slavery and forced labour can take many forms, including human trafficking or child labour. Platinum’s Corporate Governance Policy, clearly states that we will not tolerate forced labour (including human trafficking) or child labour.

In our supply chain we conduct site visits of our manufacturing partners to ensure compliance. These include actions to safeguard against human rights abuses (including forced labour and human trafficking) in our supply chain. For example our Company Policies forbid the use of forced labour, child labour and physically abusive disciplinary practices. Our definition of forced labour is inclusive of human trafficking.

We reserve the right to terminate our relationship with a supplier if issues of non-compliance with our policies are discovered and/ or noncompliance is not addressed in a timely manner.

We assess risk related to human trafficking and forced labour associated with our supply base. Our preliminary assessment is based upon the company, the geography, the commodity purchased and the nature of the business transaction. In 2016, as a result of this analysis, we added Indonesia to our list of high-priority countries. The high-priority country list, combined with our assessment history in a given country and engagement with the buying community, is used to prioritise our assessment efforts.

America’s – Argentina, Brazil, Columbia, Dominican Republic, Honduras, Mexico, Nicaragua and Venezuela.

Asia – China, India, Malaysia, the Philippines, Taiwan, Thailand and Vietnam

Europe, Middle East and Africa – Morocco, Romania, South Africa and Turkey

The Company Directors are responsible for compliance in their respective departments and for their supplier relationships.

Whistleblowing Policy
We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains, of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for individuals to make disclosures, without fear of retaliation. In addition, we work with a third party provide a ‘Whistle Blowing’ hotline which is available on a 24/7 basis.

Antibribery and Corruption Policy & Code of Conduct & Ethics Policy

The Company’s above codes clearly sets out to all employees the actions and behaviours expected of them, when representing the Company. We strive to maintain the highest standards of employee conduct and ethical behaviour when managing all aspects of our business (including our supply chain). All colleagues are trained in this policy.

Recruitment and use of agency staff

We use only specified, reputable employment agencies to source labour and verify the practices of any new agency we use using before accepting workers from that agency.

The Company ensures that all potential employees have the legal right to work in the UK and that relevant employment legislation is adhered to.

Equal Opportunities Policy

The Company operates an Equal Opportunities Policy which reflects our commitment to promoting a working environment that is free from discrimination, harassment and victimisation.  It is Company policy to provide equal employment opportunities to all employees regardless of personal status and to prohibit all forms of discrimination.  In order to achieve this, employment decisions will be based on merit, attributes, abilities and qualifications.

Where possible, we build long standing relationships with local suppliers and make clear our expectations of business behaviour.

We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.

We expect each supplier in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain.

• Use of the Whistleblowing Policy in relation to Modern Slavery and Human Trafficking.
• Reviews of our recruitment and payroll systems to ensure recruitment practices remain legally compliant.
• Reviews with our direct suppliers to understand the level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.

• We communicate our policies Corporate Governance and Whistle Blowing with all staff including our Purchasing team. Additionally, our Supply Chain and Procurement Directors regularly visit and assess suppliers to ensure Company policies and legal requirements are adhered to by our Supply Chain partners.

• We regularly conduct visits of supplier factories to monitor compliance with Platinum’s expectations and legal requirements. If any issues are identified during an audit, the supplier is required to prepare a corrective action plan and resole all violations within an agreed upon time period.

All Directors have been briefed on the subject.

Stuart Dale

18/01/2019