Modern slavery statement

Have a question? Get in touch with us here.

 

Modern slavery and human trafficking statement pursuant to section 54 of the Modern Slavery Act 2015

This statement is published pursuant to section 54 of the Modern Slavery Act 2015 and is the modern slavery and human trafficking statement of Gusto Gen Limited in accordance with section 54 of the Modern Slavery Act 2015 for the financial year ending 31 December 2018 (referred to throughout this statement together as "Gusto").

Gusto is committed to acting ethically and with integrity in all of its companies' dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in its own companies or in its supply chains.

Gusto's business

Gusto's business is comprised of the following three areas:

  • Gusto Aftermarket Parts - Gusto is a manufacturer of high-performance aftermarket spare parts for Turbogenerators and also a reseller of OEM spare parts. To support the development, engineering and manufacture of its range of spare parts, Gusto partners with world leading companies in UK, Europe and USA to provide specialist expertise and technology.

  • Gusto Aftermarket Services – Gusto provides inspection, testing and repair services for Turbogenerators with a small, highly-skilled team of Ex-OEM engineers based in UK and Canada. We also partner with world leading generator manufacturing facilities to enable high quality repairs at convenient locations across four continents.

Gusto’s predominant business is in the energy and technology sectors. As a result, its supply chains are complex. Whilst many of Gusto's tier 1 suppliers are based in the UK, many of Gusto's suppliers are also based all over the world. Often there can be a number of levels of suppliers between Gusto and the raw materials at the very beginning of the process. As such, respecting and complying with modern slavery, human trafficking and general human rights obligations is as much the responsibly of our suppliers as it is Gusto's.

Risk assessment

Gusto aims to have systems in place which:

  • identify and assess potential risk areas in Gusto's supply chains; mitigate the risk of slavery and human trafficking occurring in the supply chains; monitor potential risk areas in Gusto's supply chains; and protect whistleblowers.

The steps set out throughout the rest of this statement are aimed at remedying and mitigating identified areas of risk. Gusto hopes that the steps it takes will eliminate the risks of modern slavery and human trafficking taking place in its own businesses and its supply chains.

Gusto’s Code of Conduct and Business Ethics

Gusto Technology has published on its website, a Code of Conduct and Business Ethics which applies to all aspects of the supply of goods and services provided to Gusto Technology. The Code of Conduct and Business Ethics is provided to potential suppliers as part of the procurement process. The Code of Conduct and Business Ethics communicates the high standards expected of all Gusto Technology's partners and suppliers.

Under the Code of Conduct and Business Ethics, a prospective supplier must, amongst other requirements:

  • comply with all of the applicable laws, statutes, regulations and codes of the countries it is present in

  • maintain a safe and civilised work environment;

  • uphold the human rights of all employees and adhere with all laws, regulations, codes and government guidelines on human rights

  • take all reasonable steps to ensure there is no slavery, human trafficking or child labour taking place in its supply chains or elsewhere in its business; and

  • keep up to date with its understanding of the Modern Slavery Act 2015 and be in compliance with its requirements at all times.

Internal policies

Gusto has an Anti-Slavery and Human Trafficking Policy in place which its employees must adhere to. Employees are encouraged to report any act, treatment of workers or working conditions within its business or any tier of its supply chain that they feel constitutes any of the various forms of modern slavery and human trafficking. Reports can be made to their line manager, the Human Resources Department or confidentially in accordance with its Whistleblowing Policy. Gusto's Code of Conduct and Business Ethics applies to its own staff in addition to its suppliers.

In addition, Gusto has a number of other internal policies in place which ensure that slavery and human trafficking are not taking place in its businesses. Such internal policies include policies in respect of anti-bribery and corruption, whistleblowing, diversity and recruitment. Gusto carries out "right to work" checks on all direct employees prior to them commencing their roles in the business. This includes checking that the employee has a valid visa and is of an appropriate age to work.

Due diligence

As part of Gusto's procurement process, potential suppliers are required to complete a questionnaire to be considered as part of their bid. The questions include a number of questions aimed at ensuring that the potential supplier is aware, at an early stage of the procurement process, of its obligations to act ethically and that Gusto will not tolerate human trafficking, modern slavery or any other unethical practices in its supply chains.

Gusto intends to review the questionnaire to ensure that going forwards potential suppliers are required to confirm that they are in full compliance with the Modern Slavery Act 2015 and with Gusto's Code of Conduct and Business Ethics before they are fully engaged by the business.

The potential supplier's response will be assessed by the procurement team, with particular emphasis placed on answers to questions in relation to human rights and modern slavery.

Where possible, Gusto aims to ensure that all of its suppliers work in accordance with its expectations.

Gusto always aims to use its own standard terms and conditions which includes anti-slavery and human trafficking provisions. If a supplier breaches any of these provisions, Gusto has the ability to terminate the contract with that supplier.

Gusto’s suppliers are not allowed to sub-contract with third parties without Gusto's prior written consent to ensure that Gusto maintains oversight over its supply chains. Where appropriate, and with the welfare and safety of those individuals at risk as a priority, Gusto provides support and guidance to its suppliers to help them address any concerns in their businesses and supply chains.

Training

Gusto recognises the importance of its staff being aware of and understanding the risks of slavery and human trafficking. Gusto seeks to ensure that appropriate staff are able to identify the signs of slavery and human trafficking and that such staff are aware of what action to take if such activities are identified or suspected.

Further steps

Gusto is committed to eradicating the risk of slavery and human trafficking and continues to be proud of the steps taken by the group during the last financial year. Gusto recognises that modern slavery and human trafficking are evolving issues. Therefore, Gusto will continue to consider the effectiveness of the steps it is taking to eradicate modern slavery and human trafficking from its businesses and its supply chains and may take such further steps as it considers may be appropriate to address any risk of slavery or human trafficking.

This statement was approved by the directors of Gusto Gen Limited and published in accordance with section 54 of the Modern Slavery Act 2015 for the financial year ending 31 December 2018 on 20th June 2019.