1. Introduction
1.1 Calor is a leading supplier and distributor of Liquefied Petroleum Gas (LPG) in Ireland, allowing customers who are located off the natural gas grid to use LPG for power in their homes and businesses.
1.2 Calor is wholly owned by the Dutch company SHV. Calor is an expert in LPG, Bio LPG and LNG procurement and commissioning, bulk gas storage, cylinder filling and storage, transport and delivery, installation, and maintenance. We also actively develop and innovate new LPG powered products such as our Calor Mini-BBQ and new lightweight cylinders.
1.3 Calor serves both residential and commercial sectors within Ireland.
1.4 Calor employs staff across its main operational sites and offices located throughout Ireland.
1.5 Calor’s financial year runs from the beginning of January to the end of December in any given calendar year.
2. Scope
2.1 This statement applies to Calor Teoranta in the Republic of Ireland and Calor Gas Northern Ireland Ltd. in Northern Ireland and to all Calor related activities. Furthermore, it extends to all persons and third parties employed by Calor and those who carry out work related activities on behalf of Calor.
2.2 The prevention, detection, and reporting of modern slavery at Calor and within our supply chain is the responsibility of all Calor employees and Calor suppliers. Senior Leadership Team (SLT) and the General Legal Counsel and Compliance Officer have overall responsibility for this policy and in ensuring that the company and its employees comply with its legal and moral obligations.
2.3 All managers have the day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.
3. References
3.1 The Modern Slavery Act 2015. (UK).
3.2 The Criminal Law (Human Trafficking) Act 2008 as amended by the Criminal Law (Human Trafficking) Act Amendment Act 2013 (ROI).
4. Definitions
CEO Chief Executive Officer
LPG Liquefied Petroleum Gas
NI Northern Ireland
ROI Republic of Ireland
SLT Senior Leadership Team
TPDD Third-Party Due Diligence
UK United Kingdom
5. Procedure
5.1 This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Calor has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or related supply chain. Effective systems and controls are implemented to safeguard against any form of modern slavery taking place within Calor and our supply chain.
5.2 Calor as a caring and sustainable business has a zero-tolerance approach to any form of modern slavery. Calor is committed to acting ethically and with integrity and transparency in all business-related matters.
5.3 This statement relates to actions and activities during the current calendar year and the statement is reviewed annually as a minimum. Calor recognises that it has a responsibility to take a robust approach against slavery and human trafficking. Calor is fully committed to ensuring there is no slavery and human trafficking taking place in any of its activities, and this extends to our supply chains.
5.4 Calor has developed and implemented internal policies to ensure that business is conducted in an ethical and transparent manner. The policies include:
• Dignity and Respect Policy.
• Diversity and Inclusion Policy.
• Environmental and Sustainability Policy.
• Procurement Policies.
• Supplier Code of Conduct.
• Whistleblowing Policy in the form of Speak Up.
• Anti-Bribery and Corruption Policy.
• Third Party Due Diligence Policy.
5.5 Due Diligence
5.5.1 In order to recognise and manage risks involved when engaging with third parties, Calor has implemented a Third-Party Due Diligence process (“TPDD”). This TPDD process is relevant for new third parties and for third parties that Calor already has an active business relationship with.
5.5.2 The TPDD process is intended to assist Calor in preventing, detecting, and responding to third-party risks. During the performance of due diligence activities, Calor will gather information about the third parties for the purpose of developing a business relationship with. When reviewing this information, Calor will seek to identify whether there is ‘information that gives reasons for concern’ and be alert for potential non-compliant or unethical behaviour.
5.5.3 By performing TPDD, Calor will obtain enough knowledge on the risks of doing business with relevant third parties for the purposes of making an informed decision about the third parties that Calor will engage with and where necessary to implement mitigating measures. Additionally, Calor will check third parties to ensure that their labour standards are compliant with any and all applicable legislation. TPDD activities consist of pre-screening; enhanced due diligence and periodic batch screening as performed by designated members of the Finance Team and overall responsibility resting with the General Legal Counsel and Compliance Officer. Following the introduction of the TPDD process, we will continually share information internally on how this process is working and consider what improvements or enhancements could be made to it. Calor’s CEO must approve reporting for enhanced due diligence screening.
5.6 Risk Assessment Process
5.6.1 In order to ensure that our suppliers operate in accordance with our expectations and the requirements of the Modern Slavery Act Calor will:
- Make contact with all suppliers regarding commitment to this Statement.
- Initiate a process to review the operations of major suppliers identified as being most at risk.
- Initiate a process to review trading relationships from time to time to scrutinise the supply, sourcing, and distribution agreements.
5.7 Performance Indicators
5.7.1 In order to understand the effectiveness of the controls which ensure that modern slavery does not exist within Calor’s business or supply chain, several targets have been introduced in areas such as:
- Supply chain verification.
- Audits.
- Employee training.
- Strengthening of work in areas of greatest risk.
- Improving levels of communication and personal contact with the next link in the supply chain.
5.8 Training
5.8.1 Calor will arrange training for key personnel across our business who engage with procuring our suppliers to ensure that our Risk Assessment Process is met and to ensure that this statement is complied with.
5.9 Our Business
5.9.1 Calor recognises that the greatest risk of modern slavery is with those not in permanent employment and work closely with service providers to ensure this risk is being managed appropriately. Calor’s relationships with all service providers are reviewed regularly and are subject to normal procurement processes and contracts.
5.10 Suppliers
5.10.1 Calor has set standards that it expects its new and existing suppliers to meet in relation to compliance and ethics which includes (but is not limited to) modern slavery.
5.10.2 Calor regularly reviews its Tier 1 suppliers (those most significant in terms of spend) assessing the potential for incidences of modern slavery. On this basis, Calor considers third parties adhere to the highest risk areas are suppliers that operate internationally in countries of concern with regard to human rights. To manage this risk, we continue to work closely with our parent company to regularly audit suppliers and evaluate the effectiveness of existing controls.
5.10.3 Chartered vessels transporting LNG and LPG were identified as another area of risk. To manage that risk Calor confirmed that all agreements include terms of employment for the vessels’ staff and crew, which conform to the standards outlined in the International Transport Workers Federation.
5.10.4 Calor is committed to ensuring that its third parties adhere to the highest standards of ethics as enshrined in Calor’s Supplier Code of Conduct and Procurement Policy. Calor reserves the right to terminate its relationship with a supplier(s) working with/for/on behalf of Calor in the event they breach any Calor policies and have been found to have committed acts in contravention of Modern Slavery legislation referenced above.
5.11 Reporting
5.11.1 All employees are encouraged to report any suspected wrongdoing to their Line Manager and the Legal Department at Legal.Department@calorgas.ie. Calor’s policies set out the protections for employees in reporting serious malpractice at work.
