Social Responsibility 1.0 Overview Pegler Yorkshire is well known and respected as one of the leading manufacturers of advanced plumbing, heating and engineering products in the world. It's a reputation earned through a total dedication to quality, innovation and customer service that's been the hallmark of the companies Yorkshire Fittings Ltd and Pegler Ltd since they were established in the 1890’s. Pegler Yorkshire’s success has been derived from a commitment to a philosophy based on quality, service, investment, competitiveness and innovation. This successful recipe has produced Pegler Yorkshire’s current product portfolio that continues to go from strength to strength with product development playing a vital role in company strategy and reflecting the markets changing needs. Energy and water conservation is very much at the forefront of product development resulting in energy and water saving products being incorporated into Pegler Yorkshire’s impressive line up of valves, taps, mixers, showers, fittings and heating products. Based at sites in Doncaster and Leeds Pegler Yorkshire is one of the largest employers in Yorkshire with approximately 800 people and furthermore is one of the largest brass manufacturers in Europe. Developing export markets has been a key strategy for Pegler Yorkshire for over sixty years. Today, Pegler Yorkshire supplies its products to customers in over 110 countries worldwide. Pegler Yorkshire is part of the Flow Control division of Aalberts Industries N.V. 2.0 Learning & Development Pegler Yorkshire is committed to the development of their people, and actively encourages a learning environment. Every new employee to the business undergoes an induction programme together with an introduction to health and safety and environmental issues. Learning is conducted both on and off the job, and all employees are provided with the skills necessary to undertake their role within the business. Principles such as lean manufacturing or NVQ training are introduced on a formal learning programme to fulfil company initiatives. Employees are encouraged to fulfil personal learning goals, from an introduction to literacy or numeracy skills right through to the development of further education such as diplomas, degrees and doctorates. Dependent upon individual circumstances and business benefits, employees are in turn given time off to complete training. 3.0 Community Investment Pegler Yorkshire is committed to supporting the local community around their factory from an educational and social perspective. The company provides a sports and social club which is open to workers and the local community. It also operates a charities commission that raises funds and supports local charitable causes. With regard to education Pegler Yorkshire is involved with several local initiatives including: 1. Technology Challenge in conjunction with Business and Education South Yorkshire 2. Engineering Education Scheme (England) in conjunction with the Engineering Development Trust 3. Ridgewood School Doncaster's 6th Form Centre of Engineering Excellence In addition Pegler Yorkshire supports several local schools and colleges by providing open days for students and staff, and by inputting to the development and implementation of modern apprentice schemes 4.0 Corporate Governance The Group Structure comprises a chief executive and five other executive directors. They are responsible for determining the strategy of the business and ensuring the successful implementation at an operational level.

5.0 Employment

5.1 Equal Opportunities

Pegler Yorkshire wholeheartedly supports the principle of equal opportunity and is committed to maximising the effective use of people by recognising individual abilities and differences and respecting individual rights. The company believes that by supporting this principle, employees will contribute to and benefit from the continued success of their company.

The companies' policy is intended to ensure that progression and promotion of employees will be determined solely by personal merit and the application of criteria which are related to the effective performance of the job and the needs of the business. No applicant or employee will be treated less favourably than any other on the grounds of sex, marital status, race, colour, nationality, ethnic or national origin, religious belief, membership or non-membership of a trade union, disability, spent convictions or age.

Each employee has the right to be treated with dignity and respect by colleagues and the company has a responsibility to ensure that all employees feel that they are protected from harassment and discrimination by creating a climate of acceptance and mutual respect. The company will not tolerate harassment of an individual on the grounds of sex, race, religion, belief, age or other unjust reason.

5.2 Grievance

Pegler Yorkshire operates a Grievance Procedure in order to settle questions or queries as quickly and as near to the source as possible.

To ensure the success of this Procedure, utmost co-operation by all is essential.

The Management and Trade Unions emphasise the need for prior joint consultation and agreement. In the event of any difference arising which cannot immediately be settled, then whatever practice or agreement existed prior to the difference shall continue to operate pending a settlement or until the agreed procedure has been exhausted.

5.3 Disciplinary Action

Pegler Yorkshire recognises that discipline is necessary for the efficient operation of the business and for the health and safety at work for all employees. In order to provide a fair and effective procedure which is understood by everyone and which will ensure a uniform approach throughout the organisation, a disciplinary action procedure is applied in instances where action is warranted.

 

5.4 Harassment

Pegler Yorkshire will not tolerate harassment - whether on the grounds of sex, race, disability, sexual orientation, age, religious or political belief or for any other reason, as such behaviour is unacceptable. Every employee of Pegler Yorkshire has the right to be treated with dignity and respect. Equally, employees of Pegler Yorkshire must treat employees of customers and suppliers with whom they deal or have contact at work with dignity and respect.

Appropriate disciplinary action, which may include dismissal, will be taken against any employee, of whatever seniority, who contravenes this policy.

Furthermore, the Company will not tolerate retaliation against or victimisation of any employee involved in the bringing of a complaint of harassment under the Company's procedure. Such retaliation or victimisation will itself constitute a disciplinary offence, which may in appropriate circumstances lead to dismissal.

It is the responsibility of all employees to comply with the Company's policy on harassment and the particular responsibility of supervisors and managers to ensure it is carried out, with a view to developing and maintaining a working environment, in which harassment is understood by all to be unacceptable. To this end, a copy of the Policy and Procedure is provided to all employees, who are expected to familiarise themselves with it and abide by its provisions.

5.5 Public Interest Disclosure

Pegler Yorkshire believes that good communications amongst employees at all levels promote better business practice.
The Company will not tolerate wrong doing by employees at any level.

And as such if an employee has a serious concern relating to one of the areas listed below the matter should be reported, without fear of reprisals using the procedure laid down by the company:

1. a criminal offence
2. a failure to comply with any legal obligations
3. a miscarriage of justice
4. danger to the health and safety of any individual
5. damage to the environment; or
6. the deliberate concealment of information tending to show any of the matters listed above

The Company will investigate and deal properly and sensitively with allegations of wrongdoing raised by employees.

5.6 Alcohol & Drugs

It is a mandatory requirement of Pegler Yorkshire that no employee or contractor shall:

1. Report or try to report for duty in an unfit state due to the use of alcohol or drugs of abuse
2. Be in possession of drugs of abuse while in the workplace
3. Consume alcohol or drugs of abuse whilst at work.

Any breach of these rules will be considered gross misconduct and result in immediate and appropriate disciplinary action.
Pegler Yorkshire will support the rehabilitation of employees who voluntarily seek help for alcohol or drug related problems. Such employees must seek assistance at the earliest possible opportunity. Subsequent discovery or a disclosure prompted by impending discovery or screening will be considered to be a breach of this policy.

A programme of screening will be put in place to:

1. Detect the use of drugs of abuse by potential employees
2. Detect the use of alcohol and drugs of abuse by personnel involved in an accident or incident.
3. Detect the use of drugs of abuse and/or alcohol where unusual behaviour prompts management suspicion.
4. Ensure any persons who undergo rehabilitation/counselling do not regress.

All reasonable steps will be taken to ensure that all employees and contractors are made aware of the contents of this document.

6.0 The Environment

The Pegler Yorkshire board of directors recognise that concern for the environment should be an integral and fundamental part of the Company's corporate business strategy.

Pegler Yorkshire's objective is, therefore, to achieve the manufacture and distribution of products to customers, in a manner that is responsible to the environment and in accordance with the appropriate legislation and codes of practice,

As part of Pegler Yorkshire's proactive approach to the environment, we will maintain an Environmental Management System (EMS) that is independently audited to the international standard of ISO 14001. This system will involve all employees within the company, and will provide the mechanism to manage and control aspects of the business that could impact on the environment. The system will focus on preventing pollution by:

1. Minimising and controlling emissions to air, land and water.
2. Managing, and where possible, reducing the consumption of non renewable resources.
3. Controlling and reducing the production of waste.
4. Ensure awareness on global and company environmental issues is communicated to all employees through training and awareness programmes.

Within the framework of the company's EMS, an annual review will be scheduled to review environmental initiatives, and set performance objectives for the coming year.

The Board believes that this approach will enforce an understanding and awareness of these issues within the management team, so that appropriate consideration and resourcing can be applied to environmental issues. This will provide the framework to continuously improve environmental performance whilst achieving our commercial and operational objectives.

7.0 Health And Safety

In the interests of health and safety for all, each employee is required to read the Health and Safety Policy and the relevant Pegler Yorkshire Safety Management Documentation carefully and so be aware of the part he or she has to play. The success of the health and safety policy relies on the full co-operation of each and every person working within the established channels of action and communication.

Pegler Yorkshire employees must therefore co-operate at all times to enable all statutory duties to be complied with. Each individual has a legal obligation to take reasonable care of their own health and safety and the safety of other persons who may be affected by their acts or omissions.

In order to continue to satisfy legislation created by the Health and Safety at Work Act 1974, subsequent legislation under this act and European Law, Pegler regularly reviews and updates its policy statement and Safety Management Documentation.

It is Pegler Yorkshire's policy to do all that is reasonably practicable to ensure a safe and healthy place of work, and to meet all legal requirements. To this end Pegler Yorkshire gives continuous attention to all aspects of health safety and welfare of employees, including the provision of information, training, instruction and supervision.

Pegler Yorkshire aims to identify health and safety risks, assess them and then eliminate reduce or control those risks.

It is also Pegler Yorkshire's policy that Health & Safety is a Line Management Function, and that Business Unit and Department Managers are responsible for all aspects of Health & Safety in areas under their control.

Pegler Yorkshire regards the health, safety and welfare of employees as a prime responsibility that ranks equally with other Company responsibilities.

The Managing Director ensures that the Boards policies and procedures on health and safety are effectively implemented as defined in the Pegler Yorkshire Safety Management Documentation. He ensures that by education, persuasion and discipline all employees comply with their statutory duties and with all Pegler Yorkshire's rules.

The Managing Director delegates health and safety responsibilities and duties and allocates resources in order to implement the policy.  

8.0 Quality

It is the established policy and prime objective of Pegler Yorkshire to provide products which are fit for their intended purpose and fully comply with customer, statutory and regulatory requirements.

Pegler Yorkshire will strive to meet and indeed exceed our customer's expectations throughout all aspects of the company. Whilst at the same time ensuring that our products represent outstanding value for money. All employees are therefore responsible for ensuring that Pegler Yorkshire fulfils our customer's requirements and expectations.

The Pegler Yorkshire Quality Management System is in accordance with the requirements of ISO9001:2000.
Continual improvement is a key ingredient of the standard. It is therefore mandatory that all aspects of the business, strive for improvement year on year to ensure that customer satisfaction is increased with a subsequent improvement in business performance.

The Pegler Yorkshire Quality Management System where necessary identifies procedures that must be followed in order to meet both the company objectives and specific requirements of the ISO accreditation body, these also being inter-related to other support systems such as Environmental Management, Finance, IT, Planning, Marketing and Human Resource Management.

It is therefore important that all Pegler Yorkshire employees must both understand and comply with these procedures at all times. It is the responsibility of line management to clearly communicate the policies and procedures.

The Quality Assurance function has full autonomy over specification and implementation of standards.

The Quality Manager - Pegler Yorkshire is the companies appointed representative and has the authority to insist that all requirements of the Quality Management System are adhered to.

The Quality Manager - Pegler Yorkshire reports directly to the Managing Director – Operations Pegler Yorkshire and has direct access to the Group Managing Director to ensure that all Company standards and procedures are complied with.

The focus of effort regarding the Quality Management System will always be to ensure total customer satisfaction.



9.0 Business Conduct

9.1 Conduct business in accordance with all applicable laws and regulations

Pegler Yorkshire suppliers / partners must comply with all national and other applicable laws and regulations relating to the respective country of operation. This includes ensuring that business transactions with Pegler Yorkshire are fully reported and recorded and ensuring employees are aware and properly trained to meet the requirements. Furthermore, the Company expects all of its suppliers / partners to respect the fundamental International Labour conventions and the Universal Declaration of Human Rights.

9.2 Compliance with acceptable Labour practices

Pegler Yorkshire expects its suppliers / partners to pay at least the minimum wage required by their local law, to provide legally mandated benefits and to compensate employees for overtime consistent with their local law.

Suppliers / partners should not, except in special circumstances or as permitted by local law, expect employees to work more than the lesser of:

• 48 hours
• The limits on regular hours allowed by local law

Pegler Yorkshire recognises that those in management positions may exceed these limits in the course of carrying out their roles and responsibilities. Also, in light of the seasonal nature of business, it is recognised that suppliers / partners employees may be expected in special circumstances to work longer hours for relatively short periods of time.

Where this occurs it should be in compliance with the regulations of the country of employment. Working hours exceeding 48 hours per week should be planned in a way to ensure safe and humane working conditions.

Consecutive working days must be in accordance with local legislation.

Suppliers / partners should not permit the use of any forced labour, whether in the form of prison labour, indentured labour, bonded labour, or otherwise. Forced labour should be considered to include any work or service, which is extracted from any person under the threat of penalty for its non-performance and for which the worker does not offer himself or herself voluntarily. Furthermore no person should be employed at an age younger than 15 (or 14 where the law of the country permits) or younger than the age for completing compulsory education where this is greater than 15 in the relevant country. In addition, employers must comply with all their local legal requirements for young workers, particularly those pertaining to hours of work, wages, health and safety and general working conditions.

Suppliers / partners should recognise and respect cultural differences and employment decisions - including hiring, advancement, compensation, benefits and termination arrangements - should be based on the employee's ability. Furthermore, suppliers / partners should not permit the use of monetary fines, corporal punishment, or other forms of mental or physical abuse, coercion, or intimidation.

9.2 Respect for the environment

Pegler Yorkshire suppliers / partners are encouraged to obtain third party approval to a recognised environmental management system standard e.g. ISO14001 where deemed appropriate, and shall be measured against this policy. Pegler Yorkshire expects its suppliers / partners to provide products to Pegler Yorkshire and to conduct their business operations in a way that protects and sustains the environment in accordance with all applicable laws and regulations.

9.3 Health and safety practices

The company expects its suppliers / partners to provide a safe and healthy environment for their employees in accordance with applicable local laws and regulations. Appropriate procedures should be in place to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of employer facilities. Suppliers / partners who provide residential facilities for workers are expected to ensure these facilities are also safe and healthy in accordance with local laws and regulations.

9.4 Conflict of interest

Employees within the Pegler Yorkshire supply base must deal with Pegler Yorkshire in a manner that avoids conflict between personal interests and those of the employer and Pegler Yorkshire. This requirement applies equally to business relationships and personal activities.

9.5 Protect proprietary information

Any information you receive through business dealings with Pegler Yorkshire must be kept confidential and never used for personal gain. This includes both commercial and technical information. Appropriate nondisclosure or confidentiality agreements are and will continue to be used to formalise the process of protecting proprietary information.

9.6 Gifts and hospitality

Suppliers / partners to Pegler Yorkshire should not offer gifts and favours to Pegler Yorkshire employees that may be seen as an attempt to influence business decisions.

9.7 Supplier/partner selection

Pegler Yorkshire will select and work with suppliers / partners in compliance with the principles in this code of conduct. You should use the same principles within your own supply base and then incorporate these as part of routine improvement, compliance and audit activities.

9.8 Competition

The Directors of Pegler Yorkshire recognise and are compliant with all elements of European commission's guidelines on competition activity. Pegler Yorkshire has actively carried out training to their work force that come into contact with customers and competitors. Any employee requiring clarification on our commitment towards anti competitive behaviour should refer to the Directors for guidance.

Bryan Liddle
Commercial Managing Director - Pegler Yorkshire