Modern Slavery Policy

Excool Ltd is a manufacturer of fully developed and purpose designed low energy data center cooling products. Our head office and manufacturing facility is based in Bromsgrove in the West Midlands where we employ over 150 people. We design, manufacture and commission energy efficient cooling solutions to data centers around the world.

The nature of our activities and just-in-time production model means that we rely significantly on our global supply chain in the manufacturing area of our business. Our supply chain currently extends over to Europe, Asia and USA.

We commit to review our procurement process on a regular basis. To implement a due diligence process using a supplier evaluation form with our new suppliers and then implement this with our existing suppliers. We will attempt to ascertain that the goods and services we purchase are not tainted by slavery, exploitation, coercion or human trafficking. The review of our supply chain will include consideration of whether each supplier is aligned to our ethical values.

We concede that as a relatively small business we do not have the resources to verify secondary sources of supply. Neither can we routinely visit suppliers. This is something we will review to determine whether there are additional measures we might usefully engage.

We use a number of sub-contractors to support our production process. We evaluate all our sub-contractors and will continue to review this part of our production to understand if there are any risks.

We use recruitment agencies to provide workers to fill vacancies and to provide cover for peaks in production. We use a small number of reputable agencies that we assess to ensure they have processes for preventing modern slavery, respecting workers’ rights, eligibility checks and ensuring fees are not charged for finding people work.

Ensuring that everyone we engage has the legal right to work in the UK. Our employee handbook reflects our commitment always to employ people in a legally compliant manner. Our recruitment and promotion policy enshrines a modern slavery and human trafficking guarantee. No member of staff is subject to forced labour or coercion: every member of staff contributes 100% legally compliant employment.

During our investigations to date we have not identified significant risks of modern slavery or human trafficking within areas of our organisation or our supply chain. We would therefore describe our overall risk level as low.

Operating a legally compliant approach to procurement and payment. We also ensure that our organisation and its staff observe the provisions of the Bribery Act 2010.

One of the most important ingredients of a successful business is its staff. We have already commented on our commitment to legally compliant terms and conditions of employment.

Upholding the highest standards in our human resources policies and practices.
We provide clear guidance to staff about tackling bribery and corruption. We operate specific provisions through which they can confidentially report any concern or “blow the whistle”. We promote equality and diversity and have adopted measures to deal with any instances of intimidation, bullying or harassment. All members of staff have access to our grievance procedure.

The employee handbook to include an Equal Opportunities Policy, Recruitment and Promotion Policy, Bribery provisions, a Whistleblowing policy, Bullying and Harassment policy and a Grievance procedure.

Provisions such as these not only reflect our commitment to the highest employment standards; they can also play an important supportive role in our opposition to modern slavery and human trafficking.