WFEL - Rapidly Installed Military Bridges ABOUT WFEL & MODERN SLAVERY ACT STATEMENT HOME / ABOUT WFEL & MODERN SLAVERY ACT STATEMENT MENU ABOUT WFEL OUR RESPONSIBILITIES At WFEL we work hard to ensure that we operate as a socially responsible, ethical and environmentally friendly business. SLAVERY & HUMAN TRAFFICKING STATEMENT Our commitment in respect of the Modern Slavery Act 2015 This statement is made pursuant to Section 54, of the Modern Slavery Act 2015 and sets out the steps WFEL Holdings Limited and its subsidiary WFEL Limited is taking to prevent slavery and human trafficking in our business and supply chain. It is our belief that modern slavery and human trafficking are abhorrent practices that will not be tolerated in our own operations or in our supply chains, and we will take such steps that are reasonable to ensure than none are present. We are committed to working ethically and with integrity and we require our business partners to do the same. We will issue this statement and provide follow-up instruction to relevant managers and employees that manage either our people or our suppliers. We will require that every manager completes a declaration and returns it to us on an annual basis to affirm that they will comply with our Policy. We will conduct a risk assessment on our supply chain and higher risk suppliers will be subject to an audit to ensure they are complying with their declaration and obligations under the Modern Slavery Act. We will update template commercial agreements to include an obligation that labour suppliers will comply with the Act and ensure that their suppliers and sub-contractors will too. If any supplier is found to be in breach of the Modern Slavery Act we will discontinue all commercial activities with them. If any employee is found to be in breach of the Modern Slavery Act this will be treated as Gross Misconduct and will be subject to disciplinary action. Ian Anderton, WFEL Managing Director 22nd January 2019 OUR ENVIRONMENT The company recognises the importance of environmental management and, as such, operates an accredited Environmental Management System to ISO 14001 with additional regulation under The Environmental Permitting (England and Wales) Regulations 2016. HEALTH & SAFETY The company is committed to the health and safety of all of its employees and contractors, particularly given the scale of its manufacturing operations. As a demonstration of this commitment, the company has maintained its registration to OHSAS 18001: 2007 during the year. Accident frequency rates are actively monitored and reviewed, with the 2016/17 reportable frequency rate being significantly lower than the national trend reported by the Health and Safety Executive. QUALITY WFEL runs an ISO 9001 approved Quality Management System which covers all aspects of the business from design through manufacture and test. The facility is further supported by an on-site United Kingdom Accreditation Service approved laboratory (UKAS Accreditation No: 0328) which supports welder, weld process and material type approvals. Further certification includes EN3834 for Welding and EN 1090 for CE Marking. WFEL has been awarded the Cyber Essentials Certificate of Assurance. OUR COMMUNITY We have been based at the same site in Heaton Chapel, Stockport, UK for more than 75 years and we remain an important employer and take our responsibility for nurturing local engineering talent seriously. Our factory is home to one of the UK’s only advanced Aluminium Welding Schools. WFEL has also been a proud supporter of Stockport’s famous Fairey Brass Band for more than 70 years. OUR INDUSTRY As a company which exports its products to almost 40 different countries worldwide, trading equitably and transparently has become a cornerstone of our business. Bribery and corruption is, unfortunately, a feature of corporate and public life in many countries across the world. Therefore, as governments, businesses and non-governmental organisations such as Transparency International work together to tackle the issue, WFEL Limited has adopted a clear policy whereby we support our employees to make decisions in line with our Anti-Corruption Code. WFEL Limited upholds all laws relevant to countering bribery and corruption in all the jurisdictions in which it operates, including, but not limited to: 1. Foreign Corrupt Practices Act (US) 2. Bribery Act 2010 (UK) 3. Criminal Finances Act 2017 OUR VALUES WFEL is committed to: Delivering world-leading engineering solutions Remaining at the forefront of the design and manufacture of tactical military bridges Focused on improving what we do and how we do it Providing industry-leading training and support Building long lasting and collaborative relationships with our customers Preserving the legacy of over a century of British engineering excellence WFEL is a responsible and ethical business which is committed to our environment, our staff and our community. WFEL CORPORATE INFORMATION ULTIMATE HOLDING COMPANY WFEL’s ultimate holding company is KMW + Nexter Defense Systems N.V., a company incorporated in the Netherlands. WFEL’s immediate parent company is land defence systems provider, Krauss-Maffei Wegmann GmbH & Co KG (‘KMW’), a company incorporated in Germany. PRINCIPAL ACTIVITIES The principal activities of the company are the design, manufacture and after-sales support of rapidly-deployable, modern bridging systems and related products for use in military, homeland security and disaster relief scenarios. UK TAX RISK STRATEGY The following tax strategy statement applies to WFEL Limited (‘WFEL’) and its holding company, WFEL Holdings Limited, which together comprise “WFEL” or the “UK Group”. The publication of this UK strategy statement is regarded as satisfying the requirements of Schedule 19 of the Finance Act 2016. This tax strategy statement applies to all UK taxes applicable to the UK Group and it is effective for the financial year ending 31 December 2018. The tax strategy statement will be reviewed annually and updated as necessary. APPROACH TO TAX GOVERNANCE AND RISK MANAGEMENT The tax affairs of the UK Group are managed by WFEL’s Finance Director, the UK Group’s finance team, and external tax expertise is used where necessary. WFEL complies with all relevant revenue laws, and all taxes are accounted for and paid. Procedures and controls are in place to ensure tax compliance obligations are satisfied. WFEL recognises that risks will inevitably arise from time to time in relation to the interpretation of tax laws and the nature of our compliance arrangements. Where necessary, WFEL engages external advisers to assist in identifying, evaluating, monitoring and managing these risks. RESPONSIBLE ATTITUDE TOWARDS TAX PLANNING WFEL does not enter into any aggressive tax planning or support the use of artificial structures that are established solely to avoid paying tax and have no business purpose. TRANSPARENT APPROACH TO ENGAGING WITH HMRC The UK Group engages with Her Majesty’s Revenue and Customs (‘HMRC’) in an honest, respectful, transparent, and co-operative manner. The UK Group does not take positions on tax matters that may create reputational risk or jeopardise our good reputation with HMRC. 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