Modern Slavery Transparency Statement

Introduction

Our business
As a global textile organisation, Camira offers turn-key products into the commercial interior and mass passenger transportation markets. Our products grace some of the most prestigious  installations of blue-chip headquarters, indoor arena and cinemas, healthcare facilities and education, and transportation on mainline trains, underground trains, public buses and coaches.

Headquartered in West Yorkshire (UK), Camira Group Holdings Limited continues to lead a dynamic group of companies with its Board of Directors retaining ultimate accountability for Group  strategy, policy, governance and risk management of modern slavery issues. Responsibility for the practical implementation of modern slavery risk mitigation activity is undertaken by our Human Resource, Strategic Purchasing, Sustainability and Compliance teams who consult and work with nominated employee representatives, internationally, nationally and locally.

See our Group Compliance Policy for more information.

Our policy
Underpinning our commitment to Making the Difference, we recognise our potential to influence the safeguarding of our international, national and local communities through our Corporate Social Responsibility Policy. It is one of our guiding principles to build and maintain the highest standards amongst our suppliers and take practical steps to guard against exploitation of workers, forced labour, harassment, intimidation and human trafficking.

Equally, Camira is focused on providing a working environment in which our People can thrive. Our suite of people-related strategies and policies ensure that integrity is ingrained as a core value, and annual delivery of our specialist modern slavery training validates our shared understanding of our compliance culture.

It is the responsibility of all our People to adhere to the strategies, policies and training provided, in addition to any specific local requirements. Our strategies and policies are extended to our prospective supply chain partners through our Supplier Assessment Framework and are made available though our corporate website and intranet.

See our Group People Strategy, Equality & Diversity Policy & Health & Safety Policy for more information.

Our principal risks
Our approach to identifying and assessing modern slavery risk is embedded within our broader risk management practices. Businesses and functions governed by this statement are contractually required to conform to Camira’s control requirements including, active diligence in the identification and notification of modern slavery risks. Our supply chain partners are additionally contractually obligated to mitigate modern slavery risks with their supply chain partners.

We have considered the exposure of Camira to modern slavery risk, taking into account the nature of our business activities; the application of group policies, particularly purchasing and recruitment practices.

Overall, we consider the Group’s exposure to Modern Slavery to be low.

Tackling modern slavery risk in our supply chain
The management of modern slavery risk and impact in our supply chain is embedded into our Supplier Assessment Framework. Supported by our Strategic Purchasing team, our supply chain is responsible for ensuring compliance with local labour laws.

We assess the modern slavery risk to people in our supply chain by considering the country of origin we are sourcing products and raw materials from. Our Strategic Purchasing team develop expert knowledge of local labour laws and human rights risks through stringent assessment and audit of potential supply chain partners. The Camira Supplier Assessment Framework was introduced during 2018 with an achieved target of over 90% of total spend suppliers assessed.

Contractual obligations between Camira and its supply chain partners is now mandated through our newly introduced Supplier Framework Agreement. Our agreement places requirements on our suppliers to support the eradication of modern slavery risks through the adherence with local legislation. During 2018 we have focused on the implementation of the new agreements with our key suppliers. Of our major suppliers instructed during 2018, four are now contracted under our Supplier Framework Agreement.

Tackling modern slavery risk in our business
The management of modern slavery risk and impact in our business operations is embedded into our recruitment processes. Supported by our Human Resource team, our Leadership team is responsible for ensuring compliance with local labour laws. Introduced in 2018, all employees receive regular mandated training on ethical behaviours. In particular, we provided modern slavery awareness training with refresher training taking place annually in November. To date, 100% of employees affecting our modern slavery risk exposure have undertaken our modern slavery awareness training.

We encourage the raising of questions and concerns related to ethical business practices. Besides operating an ‘open-door culture’ to encourage dialog between our workers and Leadership team, our Whistleblowing Policy ensures people can report any concerns in confidence. Concerns raised are reviewed by subject matter experts within the Camira Group; we also seek external counsel when required. To date no concerns have been raised related to modern slavery.

Looking forward
In the next 12 months we will continue to strengthen our approach to managing the risk of modern slavery within our business.

• Improvements to our Supplier Assessment Framework by introducing ‘weighted’ scores that prioritise modern slavery issues;

• Improvements to our Terms of Purchase to ensure all suppliers, no matter how big or small, are captured within our risk management framework;

• Requirement that supply chain partners provide an annual Modern Slavery Statement pledging their continued commitment to the eradication of modern slavery.

• Introduction of a Global Code of Conduct, for all our People, to ensure clear expectations about our approach to compliance and ethical issues;

• Development of a Sustainability Roadmap, encompassing five distinct areas of improvement, including People, Culture and Communities;

• Improved communication opportunities for our People to raise questions or concerns related to compliance and ethical issues.

Declaration
This statement has been made in line with the reporting requirements of Clause 54, Part 6 of the UK Modern Slavery Act and the Californian Transparency in Supply Chains Act of
2010 (SB 657), for the financial year ending 31st December 2018. This statement applies to all subsidiaries of Camira Group Holdings Limited.
This statement is approved by the Board, and has been signed by the Chief Executive Officer,
on behalf of the Board of Directors.

Signed

Grant Russell
CEO
Camira Group Holdings Limited

The following subsidiaries of Camira Group Holdings Limited are represented
through this Modern Slavery Transparency Statement:

EEA (Incl. UK) based subsidiaries
Camira Fabrics Limited
Camira Transport Fabrics Limited
Camira Yarns Limited
Holmfirth Dyers Limited
Camira Fabrics GmbH
UAB Camira Fabrics

Non-EEA based subsidiaries
Camira Fabrics (Shanghai) Limited
Camira Group, Inc
Camira Group Pty Ltd
Luna Textiles, Inc