Modern Slavery Statement

This statement applies to Bulgin Limited (also referred to in this statement as ‘the Company’).
The information included in the statement refers to the financial year 2022.

Our organisation

Bulgin is widely recognised as a leading manufacturer of environmentally sealed connectors and components. With over 100 years of experience in the industry, Bulgin continues to innovate and develop products and services to cater for its global customer base across a variety of markets. In 2016, Bulgin announced the strategic incorporation of sister company Arcolectric into its business offering. This brings together two complementary product portfolios to make Bulgin a more comprehensive and wider reaching provider of engineered solutions to meet the needs of the industry. In addition, the integration has expanded Bulgin’s expertise across a broader range of components, particularly electromechanical switches. Our popular Buccaneer Circular Connector range is well known in the industry for providing reliable, robust connections for power, signal and data in challenging environments.

The labour supplied to the Company in pursuance of its operation is carried out in Tunisia, the
United Kingdom and the United States of America. 

Definitions

The Company considers that modern slavery encompasses:

• Human trafficking
• Forced work, through mental or physical threat
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• Being dehumanised, treated as a commodity or being bought or sold as property
• Being physically constrained or to have restriction placed on freedom of movement.

Our Commitment

The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Company does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and
forced or compulsory labour.

No labour provided to the Company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the
minimum standards required in relation to its responsibilities under relevant employment legislation in our operating countries, and in many cases exceeds those minimums in relation
to its employees.

In order to fulfil its activities, the main supply chains of the Company include those related to supplier of raw material, plastics, based metals, electronic components, packaging,
machinery, tooling, plating and custom components from suppliers in the United Kingdom, European Union, Tunisia, United States and China. The Company operates with the first-tier
suppliers through agreements and contracts.

We expect our first-tier suppliers to uphold and advocate the same commitment to human rights that we do to their supply chain. This extends to, and beyond, modern slavery and human trafficking. Any supplier who is found to not be upholding these same principles will be reviewed and, ultimately, replaced if they do not modify their behaviour.

Potential exposure

In general, the Company operates with the approval and supplier evaluation processes, which limits potential exposure to slavery/human trafficking. Nonetheless, it has taken steps to
ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Our Commitment

Bulgin Limited carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Company has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

• Reviewing our supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
• Measures in place to identify and assess the potential risks in its supply chains
• Undertaking impact assessments of its services upon potential instances of slavery via supplier audits/assessments
• Any actions taken to embed a zero-tolerance policy towards modern slavery
• Any training provided to staff on modern slavery.

Policies

Although Bulgin Limited does not have a specific Modern Slavery & Human Trafficking (MS&HA) policy, it has other policies and procedures in place which address its MS&HT compliance requirements and standards. Details of these policies are outlined here:

Global Code of Ethics & Culture

Our Code of Ethics & Culture clearly sets out our expectations relating to the actions and behaviours of our employees and partners when representing us. As such the Code includes a
robust approach to Modern Slavery & Human Trafficking along with other key policies such as anti-bribery and corruption, fair employment and working with our third-party providers.

Recruitment & Immigration policy

We operate a robust recruitment & Immigration policy, including conducting checks on eligibility to work in order to safeguard against MS&HT. We also ensure we are compliant with ensuring that our employees are paid the National Minimum Wage (for their country of employment) as a minimum.

Actions taken in the past financial year

In the past financial year, we have initiated the following with the aim of ensuring that slavery and human trafficking are not taking place in any part of our business or our supply chains:

• A review and update of the Employee Handbook, and all HR policies contained therein, to clearly state our commitment to human rights and detail how any employee can report in confidence any concerns of malpractice.
• Implemented our Global code of Ethics & Culture.

Planned Future steps for the upcoming financial year

As part of our ongoing commitment to preventing MS&HT during our upcoming financial year, we will commit to:

• Embedding our Global Code of Ethics & Culture
• All employees will receive training on Modern Slavery & Human Trafficking.

Approved by the Board

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Bulgin Limited slavery and human trafficking statement for the financial year ended 31 January 2022.

Name Richard Harris
Title Group Head of Procurement
Date 08/April/2022

Bulgin Limited
Registered Address
200 Science Park Milton Road, Cambridge, England, CB4 0GZ, United Kingdom
t: +44 (0)1803 407757   w: www.bulgin.com
Registered in England and Wales No. 04949934