Premdor Crosby Limited - Modern Slavery Act Statement
This statement has been produced in accordance with section 54 of the Modern Slavery Act 2015 for the financial year ending 31st December 2023 for Premdor Crosby Limited (and its subsidiaries) with a principal place of business in the UK. Premdor Crosby Limited (and its subsidiaries) (hereinafter referred to as “Premdor”) are subsidiaries of Masonite International Corporation (“Masonite”) which is headquartered in British Columbia, Canada.
Premdor has brought together a collection of industry leading manufacturers to offer an inspirational range of internal and external doors that helps to define the contemporary spaces of today and tomorrow.
Premdor is committed to ensuring our supply chain and our business reflect our values and respect for human rights. Premdor does not use of any form of involuntary labour including forced, prison, indentured, bonded, slave, or human trafficked labour and fully supports efforts to combat, prohibit, and prevent human trafficking and slavery. As a subsidiary of Masonite, Premdor leverages, and is subject to, many of Masonite’s policies, including its Supplier Policy, that provides that all suppliers must comply with applicable international, federal, state, provincial, and local laws, rules, regulations, and ordinances in connection with the design, manufacture, sale, deliver and use of their products, which includes laws regarding human trafficking and slavery. Premdor further states as follows:
Supply Chain Verification
Premdor does not have an enterprise-wide or third party administered verification process to evaluate and address risks of human trafficking and slavery. Most of our suppliers are located in Europe and other Tier 1 countries that are considered low risk. The others are in Tier 2 countries.
Premdor evaluates the supply chain annually and uses the Global Slavery Index to evaluate risk in the supply chain for modern slavery and considers a prevalence of below 1% low risk. No suppliers are currently above the 1% threshold. However, should a supplier have a prevalence of above 1%, mitigating action is taken.
Supplier Audits
Premdor suppliers are subject to Masonite’s supplier code of conduct (GLS-FORM-QMS-017). Premdor does not have an enterprise-wide unannounced independent audit process to evaluate supplier compliance with company standards for preventing human trafficking and slavery from entering our supply chain. At this time Premdor does not intend to use a third party to conduct audits of its suppliers. Premdor suppliers are subject to the above-referenced Supplier Policy that provides that all suppliers are required to allow Premdor representatives access to their manufacturing and storage facilities when a Premdor product is being manufactured or stored.
Supplier Certifications
Premdor requests that suppliers confirm that they have read and understand Masonite’s Supplier Policy which provides that the suppliers must comply with applicable international, national and local laws, rules, regulations, and ordinances in connection with the design, manufacture, sale, deliver and use of their products, which includes laws regarding human trafficking and modern slavery.
Internal Accountability
Premdor maintains internal accountability standards that employees must meet. Premdor employees are trained on and required to comply with The Masonite Values Operating Guide, Masonite’s code of conduct, which contains anti-forced labour provisions. Masonite maintains a confidential whistleblower helpline by which employees and suppliers may report compliance failures by employees, suppliers, or contractors, including any suspected failures regarding human trafficking or slavery.
Employee Training
Premdor employees and management who have direct responsibility for supply chain management are trained in overall supplier expectations, including the requirement to act ethically and in accordance with The Masonite Values Operating Guide, Masonite’s code of conduct & Masonite’s anti-bribery policy. Premdor employees responsible for supply chain are trained to screen and only deal with suppliers who comply with applicable local laws.
Premdor’s focus for 2024
A. Premdor will review the policies to which we are subject to determine whether improvements or enhancements can be made and, with respect to Masonite’s Supply Policy, consider and implement measures to ensure our vendors review, sign & return certifications.
B. Premdor will consider and implement appropriate KPIs to measure outcomes of the effectiveness of the steps we have taken, including with respect to supply chain verification.
C. Premdor will review our training offering to see if improvements or enhancements can be made – for all employees, as well as those in higher-risk roles.
D. Premdor will monitor its performance against KPIs once implemented with a view to continually improving Masonite’s effectiveness in ensuring slavery and human trafficking is not taking place in any of our supply chains or in any part of our business.
This statement has been approved by the Board of Premdor Crosby Limited.
Signed by Gary Vaughton, Managing Director 10/05/24.