As stated within Spirit’s Code of Conduct issued by its Corporate Compliance Officer, Spirit has a zero tolerance for the use of child labour, forced labour or human trafficking practices. Spirit will not knowingly do business with any subcontractors, business partner, supplier, or other third parties who violate this policy.
Spirit advises every employee to immediately report any concerns relating to child labour, forced labour, or human trafficking practices to their manager or the Corporate Compliance department.
In order to fulfil the needs of Spirit Europe’s customers, which include Airbus and Boeing, to design and manufacture aerostructures, we work with a range of suppliers across the globe. Spirit Europe works closely with and has developed positive relationships with our key suppliers. Due to the nature of our business and the strict compliance requirements we are subject to, we already engage fully with our suppliers to ensure that they can demonstrate compliance. We have a stable supply base that we work with regularly and have an expanded depth and knowledge of their business. If we engage new suppliers, we have a detailed process to audit their facilities prior to receiving orders. We operate within a very heavily regulated industry that requires the approval of suppliers not only by Spirit Europe but by its customers.
We consider that our sector is low risk due to the skilled nature of our workforce. However, we carry out on-site audits of all of our major suppliers and have a number of different policies that are aligned with our obligations under the Modern Slavery Act 2015 in the UK, including a Code of Business Ethics and Human Trafficking Policy.
As part of Spirit’s commitment to combating modern slavery, it has put in place an organisation wide general Anti-Slavery/Trafficking Policy. Further, we have put in place a UK specific anti-slavery procedure, Modern Slavery Procedure.
Spirit also has a number of policies and procedures designed to comply with other global requirements and, where possible, will develop organisation wide policies and procedures (or adapt these) to ensure that appropriate and coordinated action is taken throughout the organisation.
The following organisation wide policies and/or procedures are relevant to Spirit’s commitment to tackle modern slavery and human trafficking:
Spirit also makes suppliers aware of applicable policies, and requires them to adhere to the same high standards.
Specifically, Spirit Europe is currently engaged in the process of amending our form for supply contracts to include specific modern slavery clauses that will facilitate this in new supply contracts entered into.
We will also be conducting a review of our procurement processes to ensure that we are undertaking appropriate due diligence at the outset of any new relationship with a supplier.
We are currently assessing the steps that will be taken in relation to existing supply contracts that are not due for renewal for some time and where no on-site audit currently takes place.
These processes have been developed by our compliance, supply chain and legal teams.
For the next financial year, we will be working on formulating a specific modern slavery checklist that will form part of our supplier audit to ensure that this aspect is focused on separately. For suppliers that we do not carry out on site audits in relation to, we plan to conduct risk assessments (which may include the issuing of questionnaires).
Our procedures are designed to:
We do not consider that we operate in a high risk sector due to the skilled nature of our workforce. We will, however, assess geographical risks as we accept that exposure may be greater depending on the geographical location and will take into account the Freedom House categorisation and the Transparency International Corruption Perception Index (CPI).
Where we have identified a potential risk through our risk assessment procedures, we will explore ways of remedying and mitigating these risks through due diligence, improved procurement practices or industry collaboration.
We ensure all our suppliers adhere to our policy prohibiting slavery. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. If we find evidence of a failure to comply with our policy prohibiting these types of acts, we will seek to terminate our relationship with the relevant supplier.
In the course of the next financial year, Spirit plans to invest in educating staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees will be encouraged to identify and report any potential breaches of our antislavery and human trafficking policy. Employees will be taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Spirit’s slavery and human trafficking statement for the financial year commencing 1 January 2016 and ending 31 December 2016.