Modern Slavery Statement

Modern Slavery Statement FY18


This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes IRVINGQ Limited slavery and human trafficking statement for the financial year ending 30 September 2018


IrvinGQ (formerly known as Airborne Systems Ltd (ASL)) is a market-leading business based in the UK.  Our key business is based around Naval Decoy Systems, Parachutes, Aerial Delivery Equipment and Services.  IrvinGQ is a directly-reporting wholly owned subsidiary of Transdigm Group Inc, a $4 billion turnover US public company, which operates in the Aerospace and Defence market.

 

1 Our structure, business and supply chains

IrvinGQ has an annual turnover of approximately £45M and employs approximately 350 people across our sites in England and Wales. We conduct military parachute packing operations from our site in Hertfordshire, and we conduct design, development and manufacturing operations from our sites in Wales.

By value, 55% of our purchasing occurs in the UK, 20% in the US and 25% within the EU

There are some 500 repeat suppliers in our supply chain, including large volume textile fabric manufacturers and suppliers of unique aerospace components

 

2 Our policies in relation to modern slavery and human trafficking

IrvinGQ is committed to ethical conduct in all aspects of our business and has a zero tolerance approach to slavery and human trafficking. Our Code of Business Conduct and Ethics can be found here:

 

Transdigm Group Inc. » Innovative Aerospace Solutions :: Corporate Governance – Highlights

 

We have in place systems to encourage the reporting of concerns and the protection of whistleblowers.

IrvinGQ’s commitment to ethical and moral behaviour extends to all business dealings and transactions in which we are involved, regardless of location or sector. We remain committed to strengthening our practices in this area, both within our own business and across our supply chains. This statement sets out the steps we have taken during the financial year ending in 2018.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

IrvinGQ is committed to the prevention of modern slavery and human trafficking in all its forms, and will not tolerate or condone the abuse of human rights within any part of our business or supply chains.

 

During the course of FY18 we:

  • Undertook ethical training for every employee.
    Confirmed the status of our direct employees
    Undertook internal review and risk assessment of our supply chain with regard to possible exposure to modern slavery and human trafficking
    Reviewed our internal policies to counter modern slavery and human trafficking
    Undertook modern slavery and human trafficking compliance checks on our supply chain

 

3 Due diligence, specific risks and supplier adherence to our values

We assured ourselves that all our direct employees are subject to appropriate identity and security checks associated with our work in the defence sector, which enable us to be certain that none of our employees are trafficked persons or subject to any forced labour conditions.

We undertook a number of visits to our supply base and did not identify any risks of non-compliance in matters relating to modern slavery and human trafficking

4 Risk Assessment

In our risk assessment, we conducted internal review of our supply chain for risk of non-compliance with Law and Regulation, on the basis of our supplier quality accreditation programme. We determined that our suppliers are without exception at low risk of non-compliance. We undertook direct due diligence engagement with the supply chain and confirmed their commit to compliance with Law and Regulation.

As part of our risk assessment, we determined a need to include an express commitment to comply with the Modern Slavery Act or equivalent national legislation for our supplier base offshore from the United Kingdom. This was included in our annual update to our standard Ts&Cs

5 Measuring Effectiveness

In our 2018 survey and internal audit process we identified no instances of modern slavery, and no indicators that the risk of modern slavery in our supply chain was anything other than low.

6 Senior Leadership Team sign off of this statement

The Senior Leadership Team of IrvinGQ recognises the importance of the provisions of the Modern Slavery Act 2015 and the Directors aim to ensure that slavery and human trafficking have no part in the company’s operations and supply chain.
The Company has always been vigilant about employee welfare and aims to be transparent in its practices. We welcome the opportunity to state our firm commitment to a zero-tolerance approach to modern slavery and human trafficking.

           President