Policies including Modern Slavery Statement

Coronavirus Risk Assessment

Action 1

Office-based working will be reduced to essential attendance only.

Our investment in cloud-based solutions has seen all of our admin and communication functions moved to virtualised and platform-independent systems. Our teams can effectively work from anywhere at any time.

Guidance suggests that some may be carriers without displaying symptoms. Although none of our team are currently symptomatic nor have been recently exposed to high-risk sources, ‘social distancing’ will reduce the potential for inter-personnel transmissions to a minimum.


Action 2

Personnel quarantine will be imposed where applicable.

All our company activities are allocated with primary and reserve responsibility, ensuring cover in absence or incapacity.

Any member of our team who becomes symptomatic or is suspected or found to be a carrier or infected, or is known to have been exposed to someone who is a carrier or infected, will be isolated to reduce the potential for inter-personnel transmissions to a minimum.


Action 3

Enhanced personal hygiene will be adopted by our team

Regular hand and face washing plus adherence to local customer protocols will be ensured.

We will not be mandating the use of facemasks, because guidance suggests that this is of negligible benefit. However, adopting advice on mitigation and a common-sense approach to general hygiene, will reduce the potential for inter-personal transmissions to a minimum


Action 4

On-site attendance to customer service and response activities will be reduced to essential actions only and only where expressly authorised by our customers.

Our ability to support users and equipment remotely, allows us to resolve a large proportion of reactive service requests in a timely and effective manner, without a physical presence. Non-essential can be rescheduled to a mutually agreed future date, mindful of any foreseeable detriment to equipment performance

Whilst regular proactive maintenance is important, responsibility for safeguarding our customers and our own team members is paramount. Reducing on-site attendance will proportionally reduce the potential for inter-personnel transmissions.


Health & Safety

We recognise that the health and safety of employees, and others who may be affected by our operations, is of primary importance in the successful conduct of our business.

It is our policy that:

  1. Adequate resources are assigned to ensure the proper provision of Health and Safety at work and compliance with the provisions of the Health & Safety at Work Act 1974.
  2. Plant and work equipment is provided and maintained in a safe condition and without risk to health and that systems of work which are safe and without risk to health are established and followed.
  3. Arrangements are made and complied with for the safe use, handling, storage and transport of articles and substances for use at work.
  4. Employees are provided with such information, instruction, training and supervision as is necessary to secure their safety and health at work and the safety of others that may be affected by their actions.
  5. Where appropriate health surveillance will be provided for employees.
  6. Employees' place of work is safe and provided with adequate means of access, and the working environment is safe and without risks to health.
  7. Arrangements are in place for effective employee consultation regarding health, safety and welfare matters.
  8. Monitoring activities are undertaken to maintain agreed standards and that steps are taken to reduce the incidence rate of days lost from work related injury and ill health.
  9. Competent assistance is provided to assist in applying the provisions of health and safety law.
  10. Updating and Amendment: This policy is a “working” document and may be subject to amendment from time to time to allow for alterations in working practices and the requirements of new legislation, code of practice etc.
  11. This document will be supplied to any new employee on commencement of employment. Subsequent updated versions will be supplied to all employees if and when any amendments take place. This policy is also displayed on all employee notice boards and will be published on our website during the course of this year.
  12. The policy document and the way in which it operates will be reviewed regularly.

Waste Management & Environmental Policy

The following statements of principles and intentions comprise the Waste Management and Environmental Policy of W. V. Howe Ltd, which applies to all activities.


  • We are committed to delivering service in the areas of the stock holding the Supply of Catering Equipment to the Public Sector and Related Markets.
  • We recognise that our activities result in both direct and indirect impacts on the environment.
  • We are committed to minimising the impact of our operations on the environment by means of a programme of pollution prevention and continuous improvement in environmental performance.


  • To comply with all relevant environmental legislation and regulations, and with all other codes of practice and industrial standards to which we subscribe.
  • To implement industry waste management and environmental best practice where applicable.
  • To set waste management and environmental objectives and targets, and to implement an action plan, addressing those aspects of our activities that have significant environmental impacts.
  • To minimise the amount of wastes we dispose of, seek to recover through re-use or recycling as much as is economically practicable and ensure that the remainder is disposed of properly.
  • To minimise the use of energy, water and other materials through monitoring and increasing the efficiency of use.
  • To communicate to our employees, customers and suppliers our policy and achievements in improving our waste management and environmental performance. To ensure that all employees are aware of their individual responsibilities for acting in accordance with the policy.
  • To review periodically our objectives, targets, action plans and overall environmental performance.


Equal Opportunities

We comply with the Sex Discrimination Act 1975 (as amended by the Sex Discrimination Act 1986), Race Relations Act 1976 as amended by the Race Relations (Amendment) Act 2000, The Race Relations Act (Amendment) Regulations 2003, The Race Relations Code of Practice for the elimination of racial discrimination and the promotion of equality of opportunity in employment, as approved by Parliament in 1983, The Disability Discrimination Act 1995 and the Equal Pay Act 1970, Employment Equality (Religion or Belief) (Amendment) Regulations 2003, The Equal Pay Act 1970 (Amendment) Regulations 2003, Employment Equality (Sexual Orientation) Regulations 2003.

It is our policy as an equal opportunities employer to comply with our statutory obligations under the above Acts and, accordingly, our practice is not to treat one group of people less favourably than others because of their sex, colour, creed, race, nationality, ethnic origin, marital status or disability when deciding to recruit, train or promote employees. We advertise all employment opportunities whether through local press advertisements and/or via local job centres to try to ensure that our workforce is diverse and representative of the local community and monitor the responses to ensure that we are reaching all sections of the community. We ensure that staff are treated equitably in all areas of employment including career development, pay, training and promotion. All staff are required to ensure fairness towards colleagues, customers and members of the public in carrying out their duties. All employees should help to promote the Policy in the workplace in all aspects of service delivery and to work towards the elimination of discrimination. All staff have a duty to report any instances of discrimination to their manager at the earliest opportunity so that appropriate action can be taken to remedy the situation. Any instances of victimisation, harassment or discrimination of any kind would be dealt with by disciplinary action.

Overall responsibility for overseeing implementation of this Policy and monitoring it’s progress is with the company’s Sales Director; John Hill.

Regular reviews of the Policy will take place and to ensure that it is consistent with current legislation and codes of practice. Amendments will be made as and when required.

This Policy is made freely available to all members of staff.


Information Security Policy

Please contact us for a copy of the above policy


Modern Slavery Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) for the financial year ending 31 May 2019.

Established in Birmingham over 65 years ago, we are a national business supplying a wide range of catering equipment across the UK. 

Modern Slavery in all forms, whether slavery, servitude, forced or compulsory labour, or human trafficking (collectively, “Slavery”), is a crime and a fundamental violation of human rights. As a company we remain absolutely committed to ensuring that there is no form of Slavery in our business and supply chain. We share this ethos with our suppliers and business partners and we are dedicated to sustaining open and transparent relationships with them to ensure that the highest ethical standards are maintained regardless of where they are located. 

The prevention, detection and reporting of human rights violations in any part of our business or supply chain is the responsibility of all those working for W.V. Howe Limited and we expect our Directors and Employees to maintain the utmost standards in conformity with these principles.

We source products from across the globe and recognise that this may involve sensitive countries and industries. Our suppliers play a critical role in our business, and our relationships with them are based on achieving the best performance, product delivery times, service and total cost in an ethical and sustainable manner. We undertake a mapping exercise of our supply chains by collecting information about our tier 1 suppliers. We should then seek to collect information on lower tiers to help understand where risks may be greater.

  • W.V. Howe Limited has a zero-tolerance approach to any form of Slavery. We recognise that our responsibilities extend to our supply chain and are committed to enforcing and maintaining a supply chain process which sets out the minimum standards we expect our suppliers to abide by in connection with how they treat their workforce, legal and regulatory compliance, health and safety, business ethics and environmental standards. We propose setting targets for training and capacity building of staff about modern slavery issues, measuring changes in awareness of risk, appropriate decision making and swift action as appropriate, grievance procedures and whistle-blowing procedures for workers if cases or suspected cases are found, visibility, leverage and oversight of suppliers in relevant goods and services supply chains. 

As a minimum, we expect our suppliers to comply with the following requirements:

  • All workers are treated equally and without discrimination, migrant workers should be treated no less favourably than other workers performing the same or similar work. They should also be protected from any discrimination that would constitute a violation of human rights.
  • All workers enjoy the protection of employment law. Migrant workers should have a legally recognised employment relationship with an identifiable and legitimate employer in the country where the work is performed.
  • No fees are charged to migrant workers The employer should bear the full costs of recruitment and placement. Migrant workers are not charged any fees for recruitment or placement.
  • All migrant worker contracts are clear and transparent. Migrant workers should be provided with written contracts in a language each worker understands, with all terms and conditions explained clearly, and the worker’s assent obtained without coercion.
  • Policies and procedures are inclusive. Migrant workers’ rights should be explicitly referred to in employer and migrant recruiter public human rights policy statements, relevant operational policies and procedures addressing human rights responsibilities.
  • No migrant workers’ passports or identity documents are retained. Migrant workers should have free and complete access to their own passport, identity documents, and residency papers, and enjoy freedom of movement.
  • Wages are paid regularly, directly and on time Migrant workers should be paid what they are due on time, regularly and directly.
  • The right to worker representation is respected. Migrant workers should have the same rights to join and form trade unions and to bargain collectively as other workers.
  • Working conditions are safe and decent. Migrant workers should enjoy safe and decent conditions of work, free from harassment, any form of intimidation or inhuman treatment. They should receive adequate health and safety provision and training in relevant languages.
  • Living conditions are safe and decent. Migrant workers should enjoy safe and hygienic living conditions, and safe transport between the workplace and their accommodation. Migrant workers should not be denied freedom of movement, or confined to their living quarters.
  • Access to remedy is provided. Migrant workers should have access to judicial remedy and to credible grievance mechanisms, without fear of recrimination or dismissal.
  • Freedom to change employment is respected, and safe, timely return is guaranteed. Migrant workers should be guaranteed provision for return home on contract completion and in exceptional situations. They should not, however, be prevented from seeking or changing employment in the host country on completion of first contract or after two years, whichever is less.

For any supplier who is found to be noncompliant with our policies, we will terminate our relationship unless conditions are immediately improved and compliance is restored. 

W.V. Howe Limited is committed to training its employees on an ongoing basis. We provide training and guidance on what Slavery is, what preventative measures must be implemented and what steps should be taken in the event that any concerns are identified in our supply chain.

W.V. Howe Limited’s expectation and aim is to not tolerate any business that does not respect basic human rights.


John Hill


30 December 2021


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