Company Policies

Privacy Policy   Anti-Bribery Policy   Ethical Procurement Policy   Conflict Minerals Statement  

Environmental Policy

 

Modern Slavery Statement

 

Privacy Policy

At Elcometer we are committed to protecting and respecting your privacy.

Our privacy policy explains what personal information we collect, why we collect it, how we use it, the control you have over it and how we protect it.  This privacy notice applies to personal information we collect through our Elcometer websites, or which is provided by you in person (for example when you visit our offices, exhibition stands or events).  


It is important you read this privacy notice, together with any terms and conditions we may provide or make available to you from time to time.  This privacy notice supplements the other notices and is not intended to override them.

 

By sharing your personal information with us, or by continuing to use our websites, you confirm that you have read and understood the terms of this privacy policy. We take responsibility for the personal information we collect about you, and we aim to be transparent about how we handle it, and give you control over it. 


For details on Elcometer's Privacy Policy, please click on the drop down list below.

 

Contact us

If you have any questions, comments or concerns about any aspect of this privacy policy, how we handle your personal information, or would like to make a complaint, please contact our Privacy Team by email at registration@elcometer.com or in writing at C/O The Privacy Team, Elcometer Limited, Edge Lane, Manchester M43 6BU.

 

 

Changes to this privacy policy and your information

Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.   It is important that the personal information we hold about you is accurate and current.  Please keep us informed if your personal information changes during your relationship with us.

 

Who are we?

Elcometer is a world leader in the design, manufacture and supply of blasting equipment and inspection equipment to the coatings, concrete and metal detection industry.

Elcometer is made up of different legal entities, details of which can be found here.  This privacy policy is issued on behalf of these entities so when we mention "Elcometer", "us", "we" or "our", we are referring to these companies, and as applicable, the relevant company responsible for processing your information.  We will let you know which entity is the controller of your personal information either in our website terms, or when you purchase a product or service from us.  If you are attending our offices, the controller of your personal information will be the company operating out of such offices.  Where you attend an event, it will be the company that is exhibiting at such event or that is responsible for your country.

 

What personal information do we collect?

Our main reason for collecting your personal information is to provide the products or services you have requested from us and to improve the services, products and experiences that you expect from us.

Personal information is defined slightly differently across the world. To guarantee your privacy and the protection of your information, we define it as any information that could be used to identify you or another living individual.

Through your interactions with us, you may share with us or we may collect the following personal information:

·         Identity  Data - includes full name and title, user name or other similar identifiers, gender;

·         Contact Data - includes your address, country of residence, E-mail address, telephone number, fax number;

·         Financial Data - Bank details and payment card details;

·         Employment Data - includes certificates, qualifications and employment history;

·         Transaction Data - includes your order history, the products you buy and anything else related to your account or orders;

·         Technical Data - includes the Internet Protocol (IP) address, your login data, browser type, time zone, data and time of interaction, browser plug-in types, operating systems, platform and other technology on the devices you use to access the website or app;

·         Profile Data - includes your user name, password, feedback, survey responses;

·         Usage Data - includes information about how and when you use our products, services, website or apps;

·         Marketing Data - includes your preferences in receiving marketing from us and your communication preferences.

In some circumstances, we will need that information to be able to provide you with a product or service that you have asked for; for example, we need your payment information when you buy a product, and your address to deliver it to you. Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide the information requested, we may not be able to perform the contract and in which case we may have to cancel the product or services you have with us, but we will notify you of this at the relevant time.

If you share details of other people with us (for example, if you have bought an Elcometer product for that other person or if you register another person for an Elcometer app), then you will need to check with that person that they are happy for you to share their personal information with us, and for us to use it in accordance with this privacy policy.

 

We also collect, use and share anonymous data and aggregated data such as statistical data or demographic data for any purpose.  Although such data may be derived from your personal information, it is not considered personal information as it does not directly or indirectly reveal your identity.   

 

We do not collect any special categories of personal data about you (this includes details about your race, ethnicity, religious or philosophical beliefs, sexual orientation, political views, trade union membership, information about your health and genetic or biometric data).

 

How we collect your information

We use different methods to collect personal information from and about you, including through:

 

Personal interactions - you may provide us with a variety of personal information, including:  your identity, contact, employment and financial data when you attend our events, offices or correspond with us by post.

 

Electronic interactions -  you may typically provide us with your identity, contact, customer data, financial data, transaction data,  technical data and profile data, when you contact us by: our website, email, telephone, when you order products or services from us, request a quotation, set up a user account, subscribe to our service or publications, request marketing is sent to you, provide feedback to us, register your warranty, complete a survey, update your account information, download Elcometer software, or ask for technical support through our website. 

 

Automated technologies - when you interact with our website, send us an email or use our apps, we may automatically collect your technical data, usage data, the internet address of the website from which you link through to our website and information on how you use our websites or apps.  We use this information so that we can see how well our websites and apps are working, how they are used and what users look at most and to prevent automated spam. We track our emails to review how you engage with them; including whether they are delivered to you, whether you open them, whether you choose to learn more about what's happening at Elcometer (for example, by clicking on a link in our e-mail).

Analytics providers - we use Google Analytics on our site for anonymous reporting of site usage. We use the collected information to compile reports to analyse and further improve our site. We only use this information for statistical analysis purposes and then the data is removed.  Google analytics use cookies as part of their analytical process, please see our cookies policy for more information about this and other cookies that operate on our website.   We do not currently respond to Do Not Track (DNT) signals.

 

Social Media Sites - you may use social media to contact us about your Elcometer products, or to leave a review. We review publicly available social media and online sites to get a better understanding of what people are saying about us, and our products, technology and services and to assist consumers who prefer to contact us through social media.  We only collect information about you that you have made publicly available on such sites (Facebook, YouTube, Twitter, LinkedIn).  We make sure any information we use is properly credited to its source or is made anonymous.

How do we use your personal information?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

·         where we need to perform the contract we are about to enter into or have entered into with you;

·         where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

·         where we need to comply with a legal or regulatory obligation;

·         to provide and improve the service, products and experiences that you expect from us.

 

Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending electronic marketing communications to you or where we are required to transfer your personal information outside of the EEA in order to deal with your enquiry or request.  You have the right to withdraw your consent to marketing at any time by contacting us or [How can you change the way that we contact you about our products, services and support?], see below for further information on how to do this.

 

We have set out below, in a table format, a description of the ways we plan to use your personal information, and which legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information.  Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

 

Purpose/Activity

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

Performance of a contract with you

To process and deliver your order including:

(a) manage payments, fees and charges

(b) collect and recover money owed to us

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) notifying you about changes to our terms or privacy policy

(b) asking you to leave a review or take a survey

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Necessary for our legitimate interests (to develop our products/services and grow our business)

To assist in any disputes, claims or investigations relating to your Elcometer product or warranty matters

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to ensure good customer satisfaction)

To detect and prevent fraudulent transactions

Necessary for our legitimate interests

To provide support with technical issues

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to ensure customers are aware of updates to our products and systems and help grow our business)

 

Elcometer contact promise

We would like to keep you posted, whether it’s on our latest product announcements, upcoming events or opportunities to test new Elcometer products.

We do this in various ways, including e-mail, post, via social media platforms and by phone, but only if you are happy for us to do so.
Ultimately, we want to make sure you’re happy with the communications you receive from us.
We therefore promise to:

·         Only send you marketing communications when you have told us it is ok to do so;

·         Only allow another Elcometer Group company or Approved Distributor in your country to send you marketing communications if you have told us it is ok to do so;

·         Never pass your personal information to anyone outside the Elcometer Group or our Approved Distributor network for them to use for their own marketing purposes; and

·         Give you the option to stop receiving support or marketing communications at any time.

 

How can you change the way that we contact you about our products, services and support?

You can change the way that we contact you in the following ways:

Opt-In/Start Contacting Me
If you hadn’t previously asked us to send you marketing communications, you can ask us to start contacting you (sometimes called an "opt-in") by:

·         Contacting Elcometer stating that you would like to receive communications from us;

·         If you have an online trading account, logging into your account and changing your preferences.

·         Completing and returning our online Contact Us Form.

Opt-Out/Stop Contacting Me
If you want to stop receiving marketing or support communications from us (sometimes called "opting out"), you can do so at any time by:

·         Contacting Elcometer or our approved distributor in your country stating that you no longer wish to receive such communications;

·         Using the unsubscribe option included in all our e-mail marketing and support communications;

·         If you have an online trading account, logging into your account and changing your preferences.

·         Emailing our privacy team at registration@elcometer.com

What personal information does Elcometer share with third parties?

Most importantly, we never sell your personal information to anyone and only share it as outlined in this privacy policy or when you ask us to. In addition to the specific third parties set out below, we may share your personal information with third parties whom we may sell, transfer or merge parts of our business or assets to.  If any change happens to the Elcometer Group, the new owners or entities may use your personal information in the same way as other members of the Elcometer Group.

Sharing within the Elcometer Group 

Most of Elcometer's processes, procedures and systems are shared across the Elcometer Group, which means that we may need to share your personal information between us. We make sure that access to your personal information is limited to those of our staff who need it, and that all staff understand how and why we protect your personal information.

Third party service providers

We share your personal information with certain third party service providers. They only have access to the personal information they need to perform those services. They are required to keep your personal information confidential and may not use it other than as we ask them to and always in accordance with this privacy policy. Those third party service providers fall into the following categories:

 

·         Approved Distributors, who help us to sell our products in certain countries;

·         Those helping us to deliver products to you;

·         Third parties that help us with mailing services, processing product purchases, financial services, IT technologies (e.g. data storage), security services and insurance claims;

·         Professional advisers including lawyers, bankers, auditors and insurers;

·         HM Revenue and Customer regulators and other authorities.

 

Please note: If you purchase a product from us, your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure electronic capture and processing of credit/debit card transactions.

International Transfers

Personal data in the European Union is protected by data protection laws but other countries do not necessarily protect your personal data in the same way. 

 

We are a global group with companies and offices operating throughout the world, we also work with a global network of Approved Distributors so that we can provide dedicated support in your own country therefore your personal information may be transferred, stored and processed outside of the European Economic Area (EEA), we will only do this with your explicit consent.  When you submit your personal information to us, you will be asked whether you agree to this transfer, storing and processing.  If you do not wish for your personal information to be treated in this manner, please do not tick the “I agree” box and do not proceed with your query.  If you proceed with your query, then an automatic communication will be sent to the relevant member of the Elcometer Group or Approved Distributor (as applicable) who will be responsible for dealing with your query.

 

Whilst we will take all steps reasonably necessary to ensure that your personal information is treated securely, we do not guarantee that the countries your information may need to be transferred to, treat personal information with the same level of protection as is required by companies operating within the EEA.  You should also note that if you do not wish for your personal information to be transferred to a third country or third party then we may not be able to deal with your query.

 

A member of the Elcometer Group or an Elcometer Distributor will use your personal information to further your enquiry, provide you with information, products and services connected with your enquiry, and carry out any obligations arising from any contract entered into between you and a member of the Elcometer Group or an Approved Distributor.

 

If you would like further information about the global handling of your personal information, please contact us at registration@elcometer.com.

 

Other third parties

We will share your personal information if we are required to do so by law, including in response to a legal process, such as a court order or subpoena, or to comply with other national, state, provincial or local laws.   If you would like more information on how we share your personal information, please email our Privacy Team at registration@elcometer.com.

Links to third party websites

We provide links to other websites such as our Approved Distributors which are not operated and controlled by Elcometer. We have no control over and are not responsible for the content of those sites or how the third parties responsible for them collect and use your personal information. We do not endorse or make any representations about third party websites.

Third party websites usually have their own privacy policies explaining how they use and share your personal information. You should carefully review those privacy policies before you use these websites to make sure that you are happy with how your personal information is being collected and shared.

How long do we keep your personal information?

We only keep your personal information for as long as we need to, to be able to use it for the reasons given in this privacy policy, and for as long as we are required to keep it by law. The actual period for which we store your personal information will vary depending on the type of personal information and how it is used. For example, when you buy a product from us, we will store information about you and your purchase for at least the term of your warranty or guarantee.

 

Your controls and choices

You have the right to access, update and amend personal information that we hold about you; you can do that in relation to some of your personal information if you have an online account. If you would like to change the way that we contact you, see the section above titled 'How can you change the way that we contact you about our products, services and support?'. 

In certain circumstances, you can also: [Click here for more details.]

·         Ask to access your personal information;

·         Ask us to correct your personal information;

·         Request erasure of your personal information;

·         Object to our processing of your personal information;

·         Ask us to limit or restrict our use of your personal information;

·         Ask us to remove or delete your personal information; or

·         Ask us to provide your personal information to a third party provider of services;

·         Withdraw your consent.

 

Please note that those rights do not always apply and there are certain exceptions to them. We will also need to confirm identity before acting on certain requests.

If the law in your country allows us to impose a fee for giving you access to your personal information, or to exercise any of your other rights in relation to your personal information, we will let you know.

If you would like to exercise any of your rights in relation to your personal information, please email
registration@elcometer.com.

 

How do we protect your personal information?

We are committed to protecting your personal information. We use appropriate technical and organisational measures, including encryption, to protect your personal information and privacy, and review those regularly. We protect your personal information using a combination of physical and IT security controls, including access controls that restrict and manage the way in which your personal information and data is processed, managed and handled. We also ensure that our staff are adequately trained in protecting your personal information. Our procedures mean that we may occasionally request proof of identity before we share your personal information with you.

Children

Elcometer's websites, apps and products are not directed at children. We do not knowingly collect any personal information from children. If you are a child, please do not attempt to become a registered user of our websites, apps or products or otherwise provide us with any personal information. If we learn that we have inadvertently obtained personal information from a child, we will delete that information as soon as possible.

If you are aware of a child who has provided their personal information to us, please contact us at
registration@elcometer.com.

 

Translations of this privacy policy

This privacy policy has been translated from English into the official language of a number of different countries. We have done this to make sure that the policy is clear and accessible to all users of our websites and apps.
If there are any conflicts or inconsistencies between the translated versions of this privacy policy, the English version will prevail.

This privacy policy was last reviewed and updated in May 2018.

 

access your information

you can ask for access to and a copy of your personal information and can check we are lawfully processing it

correction

you can ask us to correct any incomplete or inaccurate personal information we hold about you

erasure

you can ask us to delete or remove your personal information where:

(a)      there is no good reason for us continuing to process it;

(b)     you have successfully exercised your right to object (see below);

(c)      we may have processed your information unlawfully; or

(d)     we are required to erase your personal information to comply with local law.

We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request.

object

you can object to the processing of your personal information where:

(a)      we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal information, if you feel it impacts on your fundamental rights and freedoms;

(b)     we are processing your personal information for direct marketing purposes.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms and in such circumstances, we can continue to process your personal information for such purposes.

restrict processing

you can ask us to suspend or restrict the processing of your personal information, if:

(a)      you want us to establish the accuracy of your personal information;

(b)     our use of your personal information is unlawful, but you do not want us to erase it;

(c)      you need us to hold your personal information (where we no longer require it) as you need it to establish, exercise or defend legal claims; or

(d)     you have objected to our use of your personal information, but we need to verify whether we have overriding legitimate grounds to use it.

request a transfer

you can request a transfer of your personal information which is held in an automated manner and which you provided your consent for us to process such personal information or which we need to process to perform our contact with you, to you or a third party. We will provide your personal information in a structured, commonly used, machine-readable format.

withdraw your consent

you can withdraw your consent at any time (where we are relying on consent to process your personal information). This does not affect the lawfulness of any processing carried out before you withdraw your consent.

 
 

 

 

Anti-Bribery Policy

Purpose

This policy sets out the responsibility of Elcometer Ltd as a corporate entity (including all subsidiary businesses wherever located), and all employees of Elcometer and its subsidiaries (hereafter referred to as the “Group”) in observing and upholding the Group’s position on bribery and corruption.

It also provides information and guidance to all employees of the Group on how to recognise and deal with bribery and corruption issues.

Policy Statement

It is the Group’s policy to conduct all business in an honest and ethical manner. A zero-tolerance approach to bribery and corruption is taken by the Group and it is committed to acting professionally, fairly and with integrity in all dealings wherever it operates. The Group is committed to implementing and enforcing effective systems to counter bribery.

Legislation

The Bribery Act 2010 became part of UK law on 1st July 2011.

Bribery is now punishable for both individuals (up to ten years’ imprisonment and unlimited fines) and corporate entities (unlimited fines). In addition, it is now an offence for corporate entities to fail to prevent bribery.

This applies to all UK businesses and any other business, wherever registered, if it carries on any business in the UK or is managed by people with a UK connection. As such this applies as much to Elcometer Ltd’s overseas subsidiaries as it does to the UK business.

Who is covered by the policy?

This policy applies to all employees (whether permanent, fixed-term or temporary), consultants, contractors, agency staff or any other person providing services to the Group (collectively referred to as “workers” hereafter).

What is bribery?

A bribe is a financial or other advantage offered or given to a person in order to gain a commercial, contractual or personal advantage. (For the avoidance of doubt, this does not include discounting of product).

Under the Bribery Act 2010, it is an offence to bribe another or to receive a bribe. In addition, however, no money needs to have changed hands for people to be caught under the Act – a person can be guilty of an offence if they offer/promise to pay or request/agree to receive a financial or other advantage.

Gifts and Hospitality

The Group will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence any commercial or public official in the performance of their duties. The Group will not make contributions of any kind to political parties and no charitable donations will be made for the purpose of gaining any commercial advantage.

This policy does not prohibit the giving and receiving of promotional gifts of low value and normal and appropriate hospitality. As stated in the Elcometer Ltd Staff Handbook however, the offer of gifts or entertainment in excess of ?50 must not be accepted without the prior approval of a Director.

Gifts or hospitality given or received must be reasonable and justifiable. The following points are intended as guidelines in this respect:

  • Gifts or hospitality are not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
  • it is not an unlawful gift;
  • it is given in the name of the business and not in an individuals name;
  • it does not include cash or a cash equivalent (such as gift certificates or vouchers);
  • it is appropriate in the circumstances (for example, small gifts given at Christmas time);
  • taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time;
  • it is given openly, not secretly.

Record-keeping

The Group will keep financial records and have appropriate internal controls in place which will evidence the business reason for making any payments to third parties.

Workers must ensure all expense claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with the expenses policy in force at each business and must specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties such as customers, suppliers and business contacts must be prepared and maintained with strict accuracy and completeness.  No accounts must be kept "off-book" to facilitate or conceal improper payments.

Workers responsibilities

All workers must ensure that they read, understand and comply with this policy at all times.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Group or under the Group’s control.  All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.

Raising Concerns

Workers are encouraged to raise concerns to a Company Director about any issue or suspicion of malpractice at the earliest possible stage.

No worker will suffer any detrimental treatment as a result of either refusing to take part in bribery or as a result of raising genuine concerns about bribery, even if these turn out to be mistaken. (Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern).

Monitoring

The Board of Directors has overall responsibility for ensuring the effectiveness of this policy.

Internal control systems and procedures will be subject to regular audits to provide assurance that these are effective in countering bribery.

All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

 

 

Ethical Procurement Policy

As an international organisation, Elcometer Limited sources products and components from around the Globe. Our environmental and anti-bribery policies clearly state our position on these two very important issues and go some way to set out our position on how we conduct our business in a sustainable and ethical way.

This Ethical Procurement Policy has been written to further describe how we conduct business with our suppliers, together with the expectations that we have of our suppliers regarding the way that they conduct their business and applies to all Elcometer's purchases of goods and services.

Our aim is to ensure that the whole of our supply chain conforms to our ethical procurement standards.

As a leading supplier of inspection equipment, we understand that our reputation does not simply rest with the quality and service we offer to our customers. We have a duty to ensure that we strive to maintain the highest standards of ethical conduct and corporate responsibility worldwide and seek to influence our suppliers to operate to similar high standards as ourselves.

We support the principles set out within the United Nations Universal Declaration of Human Rights and the principles set out in the Dodd Frank Wall Street Reform and Consumer Protection Act, Section 1502 with regards to the use of conflict minerals.

Elcometer will:

  • expect all our employees to adhere to our environmental, anti-bribery and ethical procurement policies;
  • pay suppliers in accordance with the agreed terms and deal with exceptions in a timely manner;
  • ensure that we will not knowingly purchase product(s) which contain metals derived from minerals defined as 'Conflict Minerals.' Conflict Minerals include columbite-tantalite (coltan, niobium and tantalum), cassiterite (tin), gold, wolframite (tungsten), their derivatives or other minerals determined by International Governments to be financing conflict.
  • ensure an ethical basis to business practice;
  • select and treat our suppliers fairly and objectively at all times;
  • seek to ensure that our environmental, anti-bribery and ethical procurement policies are considered in our supplier appraisal process.

We expect our suppliers to:

  • conduct business without the payment or receipt of inducements, unlawful incentives or other benefits that might be considered an attempt to influence decision makers;
  • respect fundamental human rights;
  • treat employees fairly, never abuse or threaten them and never use forced, bonded or child labour;
  • maintain a safe working environment at all times and provide access to protective equipment and safety training for all employees;
  • confirm they understand and respect our environmental, anti-bribery and ethical procurement policies;
  • maintain effective policies, processes and procedures to manage their environmental impact and to operate their business in a sustainable way;
  • ensure that they do not purchase products which contain metals derived from conflict minerals;
  • comply with all applicable local, national, regional and international laws, regulations and directives at all times; and
  • respect the intellectual property rights of others.

Monitoring

The Board of Directors has overall responsibility for ensuring the effectiveness of this policy.

All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

 

 

Conflict Minerals Statement

The U.S. Securities and Exchange Commission (SEC) has imposed obligations relating to conflict minerals under the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010, brought into effect in January 2013. US Congress has the sense that the exploitation and trade of conflict minerals in the Democratic Republic of the Congo (DRC) is helping to finance conflict characterised by extreme levels of violence.

The Act defines conflict minerals as cassiterite (tin), coltan (tantalum), wolframite (tungsten) and gold, or derivatives of these minerals. Sometimes these minerals are referred to as the ‘three Ts’ - tin, tantalum and tungsten (and gold).

Elcometer Limited supports ending the violence and human rights violations in the mining of minerals from the ‘Conflict Region’ and is working with its customers and suppliers to ensure compliance with these requirements.

We support the aims and objectives of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010 and ask our suppliers to undertake reasonable control with their supply chains. Our due diligence process requires suppliers to provide a written declaration on use of conflict materials and operate in accordance with the Conflict-Free Smelter (CFS) Program.

Elcometer will not knowingly procure specified materials that are not certified as ‘conflict-free’. In the event that suppliers are not following these guidelines Elcometer will act to resolve this and transition products to be ‘conflict free’.

Certificates

Conflict Minerals Statement

 

 

Environment Policy

Protection of our environment is an integral part of Elcometer’s activities.  We take a responsible approach to environmental management throughout our Company, with our Board of Directors being responsible for our environmental performance.

We are committed to the achievement of the expectations of our customers and stakeholders through the alignment of our environmental objectives to our programme of continuous improvement in order to reduce our total impact on the environment.

  • All relevant compliance obligation requirements are met
  • Environmental performance is monitored and reviewed on a regular basis
  • Any emissions to air, releases to water, energy usage or disposal of solid waste to landfill does not cause unacceptable environmental effects
  • Our business is conducted in a way that respects our neighbours

Certificates

 

Elcometer ISO14001 Certificate

 

 

Modern Slavery and Human Trafficking Statement

Introduction

This statement sets out Elcometer Limited's actions to understand all potential modern slavery risks related to its business (in pursuant to s.54 of the Modern Slavery Act 2015). It puts in place steps that are aimed at ensuring that there is no slavery or human trafficking across Elcometer’s business or its wider supply chain.

This statement relates to actions and activities during the financial year ending 31 March 2017.

As part of the coatings, concrete and ultrasonic NDT industrial sector, Elcometer recognises that it has a responsibility to take a robust approach to slavery and human trafficking

Elcometer is absolutely committed to preventing slavery and human trafficking in all of its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Countries of operation and supply

Elcometer is a world leader in the design, manufacture and supply of inspection equipment to the coatings, concrete, metal detection and ultrasonic NDT industries. Ever since the first Elcometer gauge was manufactured in 1947, our philosophy has been to provide industry leading, innovative, high quality products; supported by a best-in-class customer experience at a competitive price. By concentrating on these core values, Elcometer has grown into a global network with representation worldwide.

Our headquarters and manufacturing operation is based in Manchester UK. In addition to our UK headquarters, we have direct sales, support and repair facilities in Belgium, France, Germany, Japan, Singapore, The Netherlands, The UAE and USA, together with a global distribution network with representation in approximately 170 countries. We work with approximately 950 suppliers with the majority based in the UK.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Ethical Procurement policy: this policy sets out our approach to conducting business with our suppliers together with the expectations that we have of our suppliers regarding the way that they conduct their business and applies to all Elcometer’s purchases of goods and services.

2. Recruitment policy: we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

3. Open door policy: we operate an open-door policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals

4. Our company values: these values are core to our business and explain the manner in which we behave as an organisation and how we expect our employees and suppliers to act. These hold employees accountable for their actions and require them to act in an ethical manner

5. Supplier assessments: we operate a supplier selection and appraisal programme and maintain an approved supplier list.  We conduct due diligence on suppliers before granting them a preferred supplier status.  This due diligence includes an online search to ensure that the particular organisation has never been convicted of offenses relating to modern slavery and may include on-site audits dependent on risk associated with the nature of supply and supplier location

Responsibility

Responsibility for Elcometer’s anti-slavery initiatives is as follows:

  • Policies: All company policies are developed by Elcometer’s Management Team and approved by the Board of Directors. Policies are audited and reviewed in line with our ISO 9001 procedures.
  • Risk assessments, investigations/due diligence: All relevant assessments are made by the appropriate departmental head, including those in relation to human rights and modern slavery. Any concerns are raised with the Board of Directors.
  • Training: Our procurement team has received training so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain

Due diligence

Elcometer undertakes due diligence during supplier selection and periodic reviews of our existing suppliers. Our processes include:

  • A robust and proportional approach to supplier assessment, considering the nature of the supply into our business and the associated risks;
  • Evaluating the modern slavery and human trafficking risks of our suppliers of products, using information from the Global Slavery Index to identify higher risk industries and countries of supply;
  • Conducting supplier audits and assessments to include Modern Slavery

Any supplier who fails to meet our performance evaluations will be removed as a preferred supplier and we will terminate our business relationship with the supplier until such time as they can provide proof that they adhere to our policies and requirements as listed above.

Performance indicators

Elcometer communicates with our supply chain to ensure that they are in compliance with our policies and to ensure that slavery and/or human trafficking is not taking place within our business or supply chain. Any reports received from the public, employees or law enforcement agencies which indicate that modern slavery practices have been identified will also be acted upon in the appropriate manner.

Awareness-raising programme

Elcometer has raised awareness of modern slavery issues by putting up posters across our premises, circulating this policy via email to all employees and advising staff how they can report any potential issues with regards to slavery and human trafficking.