Policies
Quality Policy
DAVANT was established in 1989 at Ledbury, in rural Herefordshire selling pipe insulation into plumbers’ merchants. DAVANT are now part of the privately owned LINTHWAITE Group of companies, which are now established as a national manufacturer and distributor across plumbing and building trade outlets throughout the UK. At our Jugs Green site we employ up to ten people. In addition, and when necessary we employ part time staff in order to respond to increases in product demand.
The overall goal of DAVANT is to maintain and increase our current market share by improving our reputation for providing full customer satisfaction.
For this reason, the purpose of our Jugs Green Quality Management System (QMS) is to define and provide processes that enhance customer satisfaction, by consistently providing products that meet customer and applicable statutory and regulatory requirements. Therefore, the primary objective of our Jugs Green QMS is:
* Delivering to specification products to our customers
* On Time In Full Customer Deliveries
* Manufacturing our products in the most cost-effective manner
To demonstrate our ability to comply with our Jugs Green QMS primary objectives we are committed to conforming to the requirements of ISO9001:2015 for the purpose of maintaining a BSI certified QMS.
From this DAVANT is fully committed to the continual improvement of the Jugs Green QMS.
Compliance with our statutory and regulatory requirements will be assured through the application of the DAVANT Environmental & Health and Safety Management Systems.
This policy is available and maintained as documented information as part of the Jugs Green QMS.
The Policy will be posted on all Company Notice Boards and on the DAVANT web site (https://davant.wpengine.com/) for the purpose of communication and understanding within DAVANT, and to interested parties as appropriate.
Health & Safety Policy
The Object of this policy is to provide a framework around which a safe and healthy environment can be maintained.
The Company’s Policy is to pay due regard to the health and safety of its employees and to that end its management of that function is equal in importance to any other of its activities.
The Company recognises and accepts responsibility for providing a safe and healthy working environment on premises under its direct control.
The Company recognises and accepts its obligations to ensure that other parties are not adversely affected by its activities.
The Company will take steps, insofar as reasonably practical, to meet its health and safety responsibilities, paying particular attention to:
* A safe and healthy working environment, and safe access to it
* The provision and maintenance of safe plant, equipment and systems of work
* Safe arrangements for the use, handling, storing and transportation of equipment and materials
* Provision of suitable working procedures
* Provision of sufficient information, instruction, training & supervision to enable its employees to avoid hazards and contribute positively to their own H&S at work
* The health & safety issues as regards to employment of young persons
* Internal auditing of practices against procedures
The Company will seek to ensure effective consultation and communication of its Policy through formal discussion at its management meetings, and informal discussion with employees.
Changes to this Policy or Procedures will be reviewed as appropriate and brought to the notice of each employee.
It is the Duty of each Employee to work in accordance with this Company Policy and appropriate procedures, and each employee must accept and carry out their duties bearing in mind their responsibility to:
* Act with due care to prevent injury to themselves and/or others
* Follow approved working procedures, including the correct use of safety equipment and protective clothing
* Report accident, damage to equipment and potential hazards
* Make known to their supervisor, should they not be familiar with the operation of any item of plant or equipment which they may be asked to operate, in order that training can be given.
The Company regards it as essential that the principles set out in this Policy Statement are dutifully applied by each employee.
Environmental Policy
The Company is committed to carrying out its business activities in accordance with government environmental policies and all applicable laws and regulations.
The Company will specifically:
* strive to prevent the unnecessary release of substances that cause environmental harm to the air, water or land
* train and encourage employees to conduct their activities in an environmentally responsible manner
* conserve natural resources through careful planning and efficient use
* minimise waste through positive source selection and recycling
* handle and dispose of wastes through safe, environmentally responsible methods
* conserve energy by improving the efficiency of its use in business operations
* conduct regular environmental assessments at the company’s facilities and make recommendations for improvements
* encourage business partners to strive for the same high levels of environmental performance
* review the impact on the environment during corporate planning and decision making
We believe that effective environmental performance ensures effective business performance.
To achieve and in pursuit of these goals, we will implement the following principles:
* We will commit to continual improvement and prevention of pollution
* We will develop and promote policies and procedures that minimise, where practicable, the detrimental environmental impacts that our activities may have upon the environment
* We will endeavour, as a minimum requirement, to always conduct our activities within the law and the requirements of statutory regulators and with other requirements to which the organisation subscribes
* We will encourage the development of suitable methods, which promote positive environmental impacts upon the environment and which promote environmental protection and/or minimise their negative environmental impacts
* We will encourage clients and suppliers to pursue environmental best practice and to apply environmentally favourable solutions
* We will aim to provide education and training for our employees, to help them include environmental considerations in all aspects of their work, ensuring that they are aware of this environmental policy
* We will attempt to promote the efficient use of natural and sustainable resources and minimise, where possible, our use of utilities and production of waste
* We will attempt to respect the environmental demands of the communities in which we operate and society in general
Ethics Policy
As a manufacturer and supplier, Linthwaite Ltd work towards meeting the principles of the Ethical Trade Initiative (ETI) Base code. The company complies with national and other applicable law and, where the provisions of law and the ETI Base Code address the same subject it applies that provision which affords the greater protection.
Employment
There is no forced, bonded or involuntary prison labour.
Workers are not required to lodge “deposits” or their identity papers with the company and are free to leave after reasonable notice.
Freedom of association and the right to collective bargaining
Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
Linthwaite Ltd adopts an open attitude towards the activities of trade unions and their organisational activities.
Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.
Where the right to freedom of association and collective bargaining is restricted under law, Linthwaite Ltd facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.
Safe and Hygienic Working conditions
A safe and hygienic working environment is provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps are taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
Workers receive regular and recorded health and safety training, and such training is repeated for new or re-assigned workers.
Access to clean toilet facilities and to potable water, and, where appropriate, sanitary facilities for food storage are provided.
Accommodation is not provided by the company for its workers.
The company manages its health and safety responsibilities by use of a senior management representative.
Child labour
Linthwaite Ltd employ people who are at least 14 years of age, the local legal minimum or higher. The company does not recruit child labour.
Remuneration
Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.
All workers are provided with written and understandable Information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.
Deductions from wages as a disciplinary measure are not permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures are recorded.
Working hours
Working hours comply with national laws, collective agreements.
Working hours, excluding overtime, are defined by contract, and do not exceed 48 hours per week.
All overtime is voluntary. Overtime is used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It is not used to replace regular employment. Overtime is always compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay.
The total hours worked in any seven day period do not exceed 60 hours, except where allowed by national law or a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce and that there are exceptional circumstances such as unexpected production peaks, accidents or emergencies.
Workers are provided with at least one day off in every seven day period or, where allowed by national law, two days off in every 14 day period.
Discrimination
There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.
Regular employment
To every extent possible work performed is on the basis of recognised employment relationship established through national law and practice.
Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub- contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.
Physical or mental abuse or harassment
Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation are prohibited.
Anti-Bribery Policy
This Policy applies to all permanent and temporary employees of the Company (including any of its intermediaries, subsidiaries or associated companies). It also applies to any individual or corporate entity associated with the Company or who performs functions in relation to, or for and on behalf of, the Company, including, but not limited to, directors, agency workers, casual workers, contractors, consultants, seconded staff, agents, suppliers and sponsors.
This Policy outlines the Company’s position on any form of bribery and corruption and provides guidelines to:
* Ensure compliance with anti-bribery laws, rules and regulations in the UK and in any other country which the Company may trade.
* Enable employees and persons associated with the Company to understand the risks associated with bribery and to encourage them to recognise, prevent and report any wrongdoing, whether by themselves or others.
* Provide suitable and secure reporting and communication channels ensuring that any information that is reported is properly and effectively dealt with.
* Create and maintaining an effective framework for dealing with any suspected instances of bribery or corruption.
Legal obligations
This policy is based on the UK legislation according to the Bribery Act 2010 and it applies to the Company’s conduct both in the UK and abroad. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
It is an offence in the UK to:
* Offer, promise or give a financial or other advantage to another person (i.e. bribe a person), whether within the UK or abroad, with the intention of inducing or rewarding improper conduct.
* Request, agree to receive or accept a financial or other advantage (i.e. receive a bribe) for or in relation to improper conduct.
* Bribe a foreign public official.
You can be held personally liable for any such offence.
It is also an offence in the UK for an employee or an associated person to bribe another person in the course of doing business intending either to obtain or retain business, or to obtain or retain an advantage in the conduct of business, for the Company. The Company can be liable for this offence where it has failed to prevent such bribery by associated persons. As well as an unlimited fine, it could suffer substantial reputational damage.
Policy statement
All employees and associated persons are required to:
* Comply with any anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which they might be expected to conduct business.
* Act honestly, responsibly and with integrity.
Safeguard and uphold the Company’s core values by operating in an ethical, professional and lawful manner at all times.
Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a bribe.
The Company recognises that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this Policy is expected of all employees and associated persons at all times. If in doubt as to what might amount to bribery or what might constitute a breach of this Policy, refer the matter to your line manager or to the Company’s Compliance Officer.
For the Company’s rules and procedures in relation to:
The receiving of business gifts from third parties and corporate hospitality offered to or received from third parties by the Company is not prohibited.
The giving of business gifts to clients, customers, contractors and suppliers is not prohibited provided the following requirements are met:
The gift is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage and it complies with local laws and that:
* It is given in the Company’s name, not in the giver’s personal name
* It does not include cash or a cash equivalent (such as gift vouchers)
* It is of an appropriate and reasonable type and value and given at an appropriate time
* It is given openly, not secretly
* It is approved in advance by a director of the Company
In summary, it is not acceptable to give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given, or to accept a payment, gift or hospitality from a third party that you know or suspect is offered or provided with the expectation that it will obtain a business advantage for them.
Any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government procedure or process, otherwise known as a “facilitation payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are common in some other jurisdictions.
Responsibilities and reporting procedure
It is the contractual duty and responsibility of all employees and associated persons to take whatever reasonable steps are necessary to ensure compliance with this Policy and to prevent, detect and report any suspected bribery or corruption in accordance with the procedure set out in the Company’s Disclosures in the Public Interest Policy. You must immediately disclose to the Company any knowledge or suspicion you may have that you, or any other employee or associated person, has plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with the business of the Company. For the avoidance of doubt, this includes reporting your own wrongdoing. The duty to prevent, detect and report any incident of bribery and any potential risks rests not only with the directors of the Company but equally to all employees and associated persons.
The Company encourages all employees and associated persons to be vigilant and to report any unlawful conduct, suspicions or concerns promptly and without undue delay so that investigation may proceed and any action can be taken expeditiously. In the event that you wish to report an instance or suspected instance of bribery, you should follow the steps set out in the Company’s Disclosures in the Public Interest Policy. Confidentiality will be maintained during the investigation to the extent that this is practical and appropriate in the circumstances. The Company is committed to taking appropriate action against bribery and corruption. This could include either reporting the matter to an appropriate external government department, regulatory agency or the police and/or taking internal disciplinary action against relevant employees and/or terminating contracts with associated persons.
The Company will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. It is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future.
Record keeping
All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off the record” to facilitate or conceal improper payments.
Breach of Policy
A breach of any of the provisions of this Policy will constitute a disciplinary offence and will be dealt with in accordance with the Company’s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render the employee liable to summary dismissal.
As far as associated persons are concerned, a breach of this Policy could lead to the suspension or termination of any relevant contract, sub-contract or other agreement.
Monitoring compliance
The Company’s Compliance Officer(s) are responsible for ensuring compliance with this Policy and will review its contents on a regular basis. They will be responsible for monitoring its effectiveness and will provide regular reports in this regard to the directors of the Company who have overall responsibility for ensuring this Policy complies with the Company’s legal and ethical obligations.
Training
The Company will provide training to all employees to help them understand their duties and responsibilities under this Policy. The Company’s zero tolerance approach to bribery will also be communicated to all business partners at the outset of the business relationship with them and as appropriate thereafter.
Anti-Slavery Policy
As a manufacturer and supplier, Linthwaite Ltd work towards meeting the principles of the Modern Slavery Act 2015. The company complies with national and other applicable law and, where the provisions of law and Modern Slavery Act 2015 address the same subject it applies that provision which affords the greater protection.
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Linthwaite Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Linthwaite Ltd has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
Our business
Linthwaite Ltd and its group of companies are firmly established as a nationwide manufacturing and distribution business into the Plumbing and Building Industry.
We are an independently owned business and take pride in selling an ever increasing range of quality products predominantly into the independent merchant sector.
The range has diversified significantly since the turn of the century. This from what was the original concentration of a solid core insulation materials; to today’s comprehensive offering of over 5000 insulation and building plastics products. We maintain very strong stock levels of high quality products and these are delivered from our Distribution Centres, in Herefordshire and Scotland, predominantly with our own fleet of liveried vehicles.
Our policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
1. Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help or advice.
2. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
3. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
4. Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
Our suppliers
Linthwaite Ltd operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery and on site audits which include a review of working conditions. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
In addition to the above and, as part of our contract with suppliers, we require that they confirm to us that:
1. They have taken steps to eradicate modern slavery within their business
2. They hold their own suppliers to account over modern slavery
3. (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
4. (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
5. We may terminate the contract at any time should any instances of modern slavery come to light
Training
We regularly update our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.
Our performance indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
* No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
