Keeler supports the provisions set out in the Modern Slavery Act 2015 (the “Act”) and has taken steps to prevent modern slavery occurring in its supply chain and within its own operations.
This statement has been published in accordance with Section 54 of the Act and applies to Keeler and its subsidiaries (the “Group”) in respect of the financial year ended 31 March 2024.
Keeler has a culture of openness, integrity and accountability. We require our employees to act fairly in their dealings with fellow employees, customers, suppliers and business partners. We are committed to preventing modern slavery and human trafficking in our operations and in our supply chains. Keeler, as part of the Halma Plc Group has a range of policies and procedures which mitigate the risk of modern slavery.
Please view our Modern Slavery Act Statement via the Halma website.
Our worldwide Code of Conduct (Code) sets out the ethical standards that govern the activities of Keeler, our employees, and business partners. The Code includes a specific provision concerning the prevention of modern slavery and human trafficking, setting out:
The Code is available on Halma’s website. It is a Group-wide requirement that all our new employees receive, and sign to acknowledge that they have read the Code. A refreshed Code of Conduct will be rolled out in FY24.
Modern slavery prevention falls within Keeler’s human rights approach to sustainability via the Halma Group. Halma’s Human Rights and Labour Conditions policy endorses the dignity and rights of all individuals as established in the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. The policy commits Halma to integrate compliance with human rights throughout the Group’s activities, ensuring that human rights are respected at all times and are protected within Halma’s sphere of our influence.
The Policy includes several commitments which are key for modern slavery prevention:
Our Human Rights and Labour Conditions Policy can be found on Halma’s website here.
Keeler has a whistleblowing policy and an established third-party whistleblowing service via the Halma Group, accessible both online and by telephone, which allows employees in any of our businesses to raise concerns in confidence, anonymously (where permitted by law) and independent of their company. Our third-party whistleblowing facility is not limited to employees and can be used by anyone, including our customers and suppliers.
In order to ensure that the mechanism remains accessible and trusted by our employees, the whistleblowing policy explains how the process works, how anonymity will be preserved, and an assurance that a whistleblower will not be treated negatively for raising an issue in good faith.
Halma’s Board (and Audit Committee, where concerns relate to potential financial misconduct or fraud) reviews the nature of reports made through the whistleblowing channel in order to ensure that it remains an effective mechanism for raising concerns, that such reports are properly investigated under the direction of the Director of Risk and Compliance and that there are no recurring trends that would suggest underlying cultural or ethical issues in the Group.
No suspected or confirmed cases of modern slavery have been reported to date.
Our Whistleblowing Policy can be found within Halma’s Code here.
Keeler have incorporated specific clauses on compliance with anti-slavery laws in their standard sale and distribution terms and conditions. These terms also require that distributors do not engage in any modern slavery practice.
In 2019/20 Halma worked with STOP THE TRAFFIK to conduct a modern slavery risk map of the Group’s global supply chain.
STOP THE TRAFFIK’s inherent risk mapping methodology consists of ranking each supplier on a scale of 1 to 5 based on their economic sector and country of operation, where 1 is the lowest risk of modern slavery and 5 is the highest. These rankings combine intelligence from multiple open-source datasets with analysis from STOP THE TRAFFIK’s human trafficking Research and Intelligence Team. The inherent risk mapping is a theoretical modern slavery ranking which identifies where risks are most likely to be within our supply chain – it does not confirm their existence.
The risk-mapping project identified that our highest risk suppliers broadly fell into two risk areas:
1. Manufacturers in China producing electrical and metal components for our products.
2. Suppliers operating across Europe and North America in high-risk sectors, providing our company with services such as logistics, warehousing, labour provision, and construction.
Throughout 2022/23 Halma have continued to provide support and advice to our companies to enable them to conduct effective due diligence and mitigate their inherent supply chain risk. We have also continued to encourage our companies to utilise the supplier sustainability platform EcoVadis which reviews and rates suppliers on four key themes, including labour and human rights.
Keeler is committed to ethical and sustainable business practices, including adherence to the Modern Slavery Act 2015.
As part of Keeler’s supplier selection process, Keeler validates that all new suppliers adhere to the Modern Slavery Act, while its ongoing supplier evaluation program includes an assessment of a suppliers’ ethical business practices, health and safety governance, welfare facilities and employee training and development opportunities.
The Keeler board and relevant employees all undertake Halma’s Modern Slavery Act compliance training. Halma also runs online modern slavery training in partnership with VinciWorks. This currently includes two main courses: (i) Modern Slavery Act: Preventing Exploitation (“Preventing Exploitation Training”); and (ii) Modern Slavery Act: Practical Steps for Procurement (“Procurement Training”) (together the “Modern Slavery Training Courses”). To date, over 5,200 Modern Slavery Training Courses have been completed by Halma Employees. Senior management, subsidiary board directors and other key business personnel are automatically enrolled on the Preventing Exploitation and Procurement Training.
The Modern Slavery Training Courses cover a variety of topics including: (i) what modern slavery is, and which groups are at heightened vulnerability; (ii) how modern slavery affects UK companies and the legal implications; (iii) how to identify high-risk suppliers and operations; (iv) how to identify cases of modern slavery and report concerns; (v) which countries and products have higher risks of slavery and exploitation; and (vi) what questions to ask suppliers in order to uncover instances of slavery.
Halma’s statement is as follows:
“As the Group Chief Executive, I will lead this important agenda for Halma and our Group and will report annually on the steps that we have taken and will be taking to prevent modern slavery.”
A copy of this Statement is available on Halma’s website at www.halma.com and also at the Modern Slavery Statement Registry.
This statement was approved by the Board of Halma and signed on its behalf by:
Marc Ronchetti
Group Chief Executive
8 June 2023
Last updated: 31 March 2025
