Swish Integra Sunlover Harrison Drape
Modern Slavery Policy
Wednesday, 22 August 2018 00:00



Sunflex, a division of Hunter Douglas, is the UK’s leading supplier of window fashion to the UK DIY Market. The Swish, Universal, Harrison Drape and Integra Curtain Poles, Curtain Tracks and Blinds are known throughout the UK for their quality, ease of installation and reliability. Based in Staffordshire, Sunflex employs around 150 people in a variety of roles and is a major employer in the area




Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Sunflex has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.


Sunflex is also committed to ensuring that there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of the contracting processes, Sunflex includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards.


This policy applies to all persons working for Sunflex or on its behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and other business partners.


This policy does not form part of any employee’s contract of employment and Sunflex may amend the policy or sections of the policy at any time.




The Managing Director has overall responsibility for ensuring this policy complies with all of Sunflex’s legal and ethical obligations, and that all those under its control comply with it


The Quality and Technical Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.


Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.




Individuals must ensure that they read, understand and comply with this policy.


The prevention, detection and reporting of modern slavery in any part of Sunflex’s business or supply chain is the responsibility of all those working for Sunflex or under its control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.


You must notify your manager OR Quality & Technical Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.


You are encouraged to raise concerns about any suspicion of modern slavery in any parts of Sunflex’s business or the supply chains of any supplier tier at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager immediately or report it in accordance with the Whistleblowing Policy, a copy of which can be found in the employee handbook, as soon as possible.


If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your manager or the Quality & Technical Manager. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.


Sunflex is committed to ensuring that no one suffers any detrimental treatment as a result of reporting their suspicion that modern slavery in whatever form, is or may be taking place in any part of our own business or in any part of our supply chain. If you believe that you, or any of your colleagues, have suffered any such treatment, you should inform your manager or the Quality & Technical Manager immediately.




Training on this policy, and on the risk the business faces from modern slavery in its supply chain will be given where needed.


Sunflex’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter.




Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.


Sunflex may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.




This Policy has been developed and approved by the Senior Management Team and signed on its behalf by the Managing Director




J. Martin

Managing Director