Introduction from Senior Management

SBE Ltd is fully supportive of the aims of the Modern Slavery Act 2015 and are committed to improving our practices to combat modern slavery and human trafficking in every part of our business.

Organisation’s structure

SBE offers comprehensive aftermarket solutions within the telecommunications and consumer electronics industries. Our core business is in the technical repair and refurbishment of electrical devices. Our plants handle more than 5 million units of electronic equipment per year across Europe.

We are a part of the SBE Group with sites operating in France, UK, Poland, Portugal, US & Canada. Our Parent company has its head office in France.

Our supply chain

At SBE we purchase spare parts and products on a worldwide basis through complex, fragmented and intrinsically international processes. We recognise that some of our overseas suppliers operate in different legal, financial and cultural environments with unique accountabilities and responsibilities with regards to modern slavery and human trafficking. We comprehend there is, therefore, potential across the international supply chain for slavery and human trafficking to occur. We further recognise that modern slavery is a complex supply chain issue and we are working in conjunction with our customers and suppliers to help develop sustainable solutions to address this important issue.

SBE aims to buy spare parts and products from suppliers which can demonstrate an awareness of, and comply with, the appropriate social and ethical standards so that our supply chain is free from modern slavery and human trafficking abuse.

Our policies on slavery and human trafficking

SBE is committed to preserving our reputation as a progressive corporate citizen, accomplished at practically embracing our responsibilities and uncompromising in the pursuit of best practice. Principled trading practices are engrained into our operations.

SBE will not knowingly tolerate the use of forced, debt bonded, indentured labour, involuntary prison labour, slavery or human trafficking in its business.

Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing effective systems to ensure slavery and human trafficking is not taking place anywhere in our business.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we are committed to implementing and improving systems and procedures to avoid inadvertent complicity in human rights violations related to our own operations and our supply chain.

We have in place systems to:

• Identify and assess potential risk areas
• Mitigate the risk of slavery and human trafficking
• Protect whistle blowers

We recognise and are committed to:

• The Human and Labour Rights principles (Principle as set out in and publicly signed thereof under the United Nations Global Compact.
• Working to the guidelines and ethical Base Code of the Ethical Training Initiative (ETI)
• Ensuring that all third party labour providers and recruitment agencies comply with our Recruiter Compliance principles in tackling hidden labour exploitation.

Training

We strive to make sure all of our employees receive full training on the standards that we expect. During 2021, no reports have been received by SBE Ltd from employees, the public, our suppliers, or law enforcement agencies to indicate that any modern slavery practices have been identified.
Through our Human Rights Due Diligence Programme, we implement our actions to assess, prevent and address potential human rights impacts, to improve our performance on the ground, and to gather data to measure our performance. We keep integrating human rights into new and existing policies; provide training to our employees and assess human rights impacts in the operations. We’ve also integrated anti-slavery clauses into our template contracts.

Further Steps

SBE Ltd is committed to continue improving our approach to respecting human rights and preventing modern slavery.

We closely collaborate with suppliers to develop appropriate processes that enable us to meet the requirements of The Modern Slavery Act.

We are improving awareness and understanding of how and where issues may occur and how we may be able to prevent them.

We have engaged in a dialogue around minimum standards and continue to work with relevant stakeholders to share best practice and identify areas of improvement.

This statement has been approved by the SBE Board of Directors on behalf of the Group. A new statement will be published for each year on the corporate website.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes a slavery and human trafficking statement for the financial year ending 31 December 2021.