Responsibility in Manufacturing

Burnetts' target is to manufacture products that our customers require whilst preventing the depletion of natural or physical resources, so that they will remain available for the long term.

We focus on the three key areas of sustainability: economic, environmental, and social impact.

As such we are continually investigating and reducing our energy use, lessening the impact of our processes on the environment. Whilst ensuring our staff have our commitment to human rights and working conditions.

Reducing our energy use is not only an economic target it also benefits the environment by reducing emissions. Burnetts continues to work on lower temperature materials to reduce energy use but also invests in the latest machinery to improve efficiency. We are focusing on reducing waste streams through investment in advanced material handling systems during processing.

Recycled content materials are now increasing in focus throughout the plastic industry. Development of materials with acceptable performance characteristics and processing repeatability are being developed more and more. Burnetts continue to offer trials in these new materials to reduce the environmental impact of plastic by recycling. 

We are also focused on reducing our packaging use and where possible utilising returnable containers and methods.

Our ongoing measurement in this area is uploaded each year to SAQ. Self-Assessment Questionnaire on CSR/Sustainability for suppliers in the automotive value chain.

Guiding-Principles.pdf (drivesustainability.org)

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Whistle Blowing Policy

At Burnetts Manufacturing Limited, we enable employees to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. This covers any concerns which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures e.g. disciplinary. These concerns could include:

  • Financial malpractice or impropriety or fraud
  • Failure to comply with a legal obligation or Statutes
  • Dangers to Health & Safety or the environment
  • Criminal activity
  • Improper conduct or unethical behaviour
  • Attempts to conceal any of these

Burnetts Manufacturing Limited advocate you are protected by the law on any of the above or similar situations.

POL005 Iss.03

 

Modern Slavery Statement

This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 (“the Act”) and sets out the steps the Company has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. This statement applies to Burnetts Manufacturing Limited (“BML”).

Modern slavery is a crime and a violation of fundamental human rights. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships

We expect the same exacting standards from all our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

BML has assessed the risk of human trafficking or slavery in our supply chain and it is believed that the risk is low given the nature of the businesses which we are involved in.

We base our relationship with our suppliers on our Code of Business Ethics which expressly prohibits forced, illegal or inhumane labour practices in the suppliers to any part of our business. Should it come to light that any of our suppliers are using forced, prison or indentured labour or that their workers were subject to any form of compulsion, coercion, or human trafficking we would expect that behaviour to be stopped immediately.

 

POL002 Iss.03

Equal Opportunities and Diversity  

What this policy covers

The Company recognises the benefits of a diverse workforce and is committed to providing a working environment that is free from discrimination.

The Company will seek to promote the principles of equality and diversity in all its dealings with employees, workers, job applicants, clients, customers, suppliers, contractors, recruitment agencies and the public.

All employees and those who act on the Company's behalf are required to adhere to this policy when undertaking their duties or when representing the Company in any other guise.

Your entitlements and responsibilities

Unlawful discrimination

Unlawful discrimination of any kind in the working environment will not be tolerated and the Company will take all necessary action to prevent its occurrence. 

Specifically, the Company aims to ensure that no employee or job applicant is subject to unlawful discrimination, either directly or indirectly, on the grounds of gender, gender reassignment, race (including colour, nationality, caste and ethnic origin), disability, sexual orientation, marital status, part-time status, pregnancy or maternity, age, religion or belief, political belief or affiliation or trade union membership. This commitment applies to all aspects of employment, including:

  • recruitment and selection, including advertisements, job descriptions, interview, and selection procedures.
  • training
  • promotion and career-development opportunities
  • terms and conditions of employment, and access to employment-related benefits and facilities
  • grievance handling and the application of disciplinary procedures
  • selection for redundancy

Equal opportunities practice is developing constantly as social attitudes and legislation change. The Company will review all policies and implement necessary changes where these could improve equality of opportunity.

Recruitment of ex-offenders

The Company actively promotes equality of opportunity for all candidates, including those with criminal records where appropriate.

The Company requires you to provide details of any relevant criminal record at an early stage in the application process. Specific rules about which convictions and spent convictions you should disclose and those you need not disclose - known as "protected convictions" - are contained in legislation.

Any such information should be sent in a separate confidential letter to the designated person. Only those who need to see it as a formal part of the recruitment process will have access to this information.

Having a criminal record will not necessarily prevent you from being appointed.

Any recruitment decision will depend on the nature of the position and the circumstances and background of the offence(s). The Company will discuss with you the relevance of any offence to the job in question.

If you fail to reveal any information relating to disclosures in accordance with the Company's Disclosures Policy, this may lead to the withdrawal of an offer of employment.

The Company's policy in relation to the handling of criminal records data is contained in the Disclosure and Disclosure Information Policy.

Career development

While positive measures may be taken to encourage under-represented groups to apply for employment opportunities, recruitment or promotion to all jobs will be based solely on merit.

All employees will have equal access to training and other career-development opportunities appropriate to their experience and abilities.

However, the Company will take appropriate positive action measures (as permitted by equal opportunities legislation) to provide specialist training and support for groups that are under-represented in the workforce and encourage them to take up training and career-development opportunities.

Procedure

Complaints of discrimination

The Company will treat seriously all complaints of discrimination made by employees, clients, customers, suppliers, contractors or other third parties and will take action where appropriate.

If you believe that you have been discriminated against, you are encouraged to raise the matter as soon as possible with your manager or other senior employee using the Company's Grievance Procedure (outlined elsewhere in the Employee Handbook).

Allegations regarding potential breaches of this policy will be treated in confidence and investigated thoroughly. If you make an allegation of discrimination, the Company is committed to ensuring that you are protected from victimisation, harassment or less favourable treatment. Any such incidents will be dealt with under the Company's Disciplinary Procedures.

Investigating accusations of unlawful discrimination

If you are accused of unlawful discrimination, the Company will investigate the matter fully.

During the course of the investigation, you will be given the opportunity to respond to the allegation and provide an explanation of your actions.

If the investigation concludes that the claim is false or malicious, the complainant may be subject to disciplinary action.

If the investigation concludes that your actions amount to unlawful discrimination, you will be subject to disciplinary action, up to and including dismissal without notice for gross misconduct.

Equal Opportunities Monitoring

The Company may carry out monitoring for the purposes of measuring the effectiveness of its equal opportunities and diversity policy.

POL012 Iss.03

Anti-Bribery Policy 

Burnetts Manufacturing Limited (BML) has a zero-tolerance policy towards bribery and corruption whether in the public or private sector.  This Policy applies to all personnel of the Company. It also applies to third party business partners where they are acting on behalf of the Company.  It extends to all business transactions involving BML in every jurisdiction.

The Company’s senior management are committed to conducting business according to these standards.  Bribery and corruption may expose the Company, its personnel and its business partners to criminal prosecution, regardless of where bribery has taken place in the world.  It is also likely to adversely affect the Company’s image and reputation.

Company personnel must operate in accordance with the anti-bribery laws applicable to the Company’s dealings worldwide, as well as with this Policy. No personnel or business partner will suffer adverse consequences for refusing to give or receive a bribe, even if it means that the Company loses business as a result.  

POL003 Iss.03

Conflict Minerals Statement

Policy Statement on Conflict Minerals

As a socially responsible Company, Burnetts Manufacturing Limited has concern for the well-being of people and communities. We conduct business fairly and ethically, respect human rights, comply with laws and regulations.


It has been widely reported that profits from sale of certain minerals mined in the Democratic Republic of the Congo (DRC) or adjoining countries have helped to finance war and human rights violations.


Those minerals are tin, tungsten, tantalum and gold, referred to as “Conflict Minerals.” In August 2012, the United States Securities and Exchange Commission (SEC) approved the final rule regarding the sourcing of conflict minerals as defined in the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502. Under this rule, publicly traded companies must report annually the presence of  “Conflict Minerals” originating from Central Africa in either the products they manufacture or contract to manufacture, or use in the production process.


Burnetts Manufacturing Limited, although not a publicly traded company, supports the aims and objectives of the laws related to sourcing and utilization of “Conflict Minerals”.


Burnetts Manufacturing Limited’s aim is to ensure that only “conflict free” materials and components are used in our products.


Burnetts Manufacturing Limited is not knowingly sourcing the specified metals from facilities in the “Conflict Region” and wants to ensure full compliance with these requirements.


Burnetts Manufacturing Limited ask our suppliers to undertake a due diligence with their supply chains to assure that specified metals are being sourced only from mines and smelters outside the “Conflict Region”.

 

If we become aware of a supplier that is sourcing these metals from the “Conflict Region”, Burnetts Manufacturing Limited will take the appropriate actions to remedy the situation in a timely manner, including reassessment of supplier relationships.

 

Burnetts Manufacturing Limited expects our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.

POL015 Iss.02

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