FENDER MUSICAL INSTRUMENTS EUROPE
UK MODERN SLAVERY ACT STATEMENT 2019
Fender Musical Instruments Corporation, and its subsidiaries, including Fender Musical Instruments Europe (collectively "Fender"), expects our suppliers and subcontractors to do business in a manner that aligns with our values, treating their employees with dignity and respect, and providing safe workplace and dormitory conditions.
We are publishing this statement in response to the Modern Slavery Act 2015 (the "Act"). In substance, the Act applies to corporations, wherever incorporated or formed, that reach a certain annual revenue threshold regarding business in the United Kingdom. The Act seeks to address the role of businesses in preventing slavery and human trafficking from occurring in their business and supply chains and Fender is proud of the steps we have taken to combat slavery and human trafficking described in this statement and supporting documents. We are committed to improving our practices to ensure that our preventive and remedial efforts continue to be relevant, timely and effective.
This statement has been approved by the Board of Directors of FMIE. It summarizes the steps taken by the company during the fiscal year ending 31 December 2019 to address risks of modern slavery in its business and supply chains.
Liam Cunnah - VP, Managing Director EMEA
1. Organization's Structure, Business and Supply Chains
Fender works with independent third-party manufacturers for the manufacture and supply of many of our products. Together with these businesses and the people who work for them, our supplier teammates, we work as a single global team. Our principal business activities are the development, marketing and distribution of branded musical instruments. Our products are sold worldwide and are used by players at all levels, from youth to professional, around the globe. Our product offerings include guitars, basses, and amplifiers, to name a few.
2. Policies in Relation to Slavery and Human Trafficking
The Fender Code of Conduct includes provisions on Forced Labor, Compensation, Hours of Work, Child Labor, Nondiscrimination, and Health and Safety. These provisions set forth expectations for the protection of workers and seek to mitigate risks including forced labor/slavery, human trafficking and risks related to our supplier's employment of migrant workers. Suppliers and their employees may report violations of the Fender Code of Conduct directly to Fender using grievance mechanisms, including a hotline mechanism featured in the Fender Code of Conduct that provides an option to report anonymously.
3. Due Diligence Process
All of Fender's direct suppliers have received a bulletin as well as a presentation that not only summarizes the Act, but announces Fender's policy of enforcing and supporting the purpose of the Act. A copy of this presentation may be obtained upon request through contact information below. Standard purchase order (PO) terms require all direct suppliers to represent and warrant that products made for and on behalf of Fender, are in compliance with laws prohibiting forced, or child labor, slavery and human trafficking.
Senior supply chain managers in Fender have personally met with some of Fender's most critical OEM partners, to instill ongoing cooperation in Fender's commitment against unlawful labor in its supply chain. Master agreements with these critical OEMs contain prohibitions against child or forced labor.
In territories around the world where Fender does not sell direct and instead relies upon third party distributors, written distributor agreements are used that contain specific provisions against the use of forced or child labor, slavery and human trafficking.
Fender maintains internal accountability standards and procedures for employees failing to meet company standards regarding slavery and trafficking. Fender's Code of Conduct holds personnel accountable for ensuring compliance and ethical standards in Fender's international business.
4. Areas of Risk
Fender is aware of the risks of modern slavery and human trafficking in global supply chains and have been actively monitoring and assessing the potential for adverse human rights impacts of human trafficking, forced labour and bonded labour for many years. We have clear and well-defined policies on human trafficking and slavery, and well-established due diligence processes for our own business and our supply chain.
Fender has previously provided its employees and management, who have direct responsibility for supply chain management, with training on slavery and human trafficking, particularly with respect to seeking to mitigate related risks within the direct suppliers of products. Additionally, Fender expects to provide additional training to employees and management individuals on slavery and human trafficking issues and risks in the future. Finally, with respect to employees who may not be formally trained, we expect to provide materials for their review.
Fender has a zero tolerance approach to slavery and human trafficking. To ensure all those in our supply chain and our contractors comply with our values, each year we invite all of our suppliers and conduct a presentation regarding the Act and the importance of eradicating human trafficking, forced labour and child labour and we actively engage in preventing, mitigating and, when necessary, remediating issues that are linked to modern slavery and human trafficking.
If any consumer has a concern or question related to Fender's approach to tackling human trafficking and slavery, please write to us at: [email protected]
This statement is made pursuant to s54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2021.