Legal

ABC / Anti-competitive practices

TWI is committed to adhering to the highest standards of ethical conduct and integrity in its business activities, and as such does not tolerate bribery in any form. To this end, TWI fully supports the principles and aims of the Bribery Act 2010, and takes a zero-tolerance approach to bribery and corruption in any form.
 
Every employee and individual acting on TWI’s behalf is responsible for upholding our reputation and for conducting TWI’s business in a transparent, honest and professional manner. If TWI knows or suspects that anyone acting on its behalf has been [convicted of bribery/the subject of a bribery investigation/proceedings], it shall take any appropriate measure, which may include the termination of any business relationship

TWI is committed to ensuring its directors and employees act in full compliance with all applicable competition laws and TWI’s competition compliance policy. TWI takes seriously and will investigate claims of anti-competitive behaviour by its employees and directors, and will take disciplinary measures when appropriate.

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2017-2018

• 1. INTRODUCTION FROM BEN GILLAM
•     1.1 -  At ThirdWay Interiors Limited (“ThirdWay”) we are committed to promoting the highest standards of ethical conduct and always strive to continually improve our working practices. We also see it as our responsibility to encourage appropriate ethical baselines in our supply chains, including the prevention of modern forms of slavery and human trafficking.
•     1.2 - This statement constitutes the modern slavery and human trafficking statement for ThirdWay (a subsidiary company of ThirdWay Group Limited) for the financial year 2017-2018. It sets out an overview of our business and supply chains and the steps we have taken as a company to ensure that modern slavery and human trafficking are not taking place in our business or supply chains. 

• 2. BUSINESS MODEL AND SUPPLY CHAINS
•     2.1 - ThirdWay Interiors Limited, a UK based company, is a leading commercial design and build business. We specialise in design, workplace consultancy, build projects and  refurbishments. ThirdWay is committed to helping all of its clients to achieve an effective and bespoke office space that is effortlessly functional and future facing.
•     2.2 - Founded in 2010, ThirdWay Group employs more than 100 professionals operating in the UK.
•     2.3 - Owing to the nature of our business, ThirdWay’s upstream supply chains are primarily the supply of building supplies, office furniture, fixtures and fittings, IT equipment and software.  In the main these are sourced from low risk jurisdictions for the purposes of modern slavery and human trafficking.

• 3. STEPS TAKEN TO ENSURE MODERN SLAVERY AND HUMAN TRAFFICKING ARE NOT TAKING PLACE IN OUR BUSINESS OR SUPPLY CHAINS
•     3.1 - The Company is currently reviewing its supply contracts and it is adding modern slavery and human trafficking related provisions to make the Company’s expectations about the issue clear and to ensure compliance by its subcontractors and suppliers.
•     3.2 - Employees of ThirdWay are required to subscribe to the Group’s Code of Ethics and Business Conduct. The Code sets forth the high standards of ethical business conduct expected of all directors, officers and employees of ThirdWay, including those working in our procurement teams. The Code expressly requires fair dealing and compliance with all applicable laws, rules and regulations, which includes those prohibiting modern slavery and human trafficking.
•     3.3 - ThirdWay employees can also utilise ThirdWay’s whistleblowing procedures, which facilitate the voicing of concerns our staff may have regarding the ethical standards applicable to our supply chains.
•     3.4 - ThirdWay, as well as ThirdWay Group Limited, remain committed to improving our processes to ensure that our business and supply chains are free from modern slavery and human trafficking.

• 4. APPROVAL
•     4.1 - This modern slavery and human trafficking statement for the financial year 2017-2018 has been approved by the board of directors of ThirdWay Interiors Limited.

For and on behalf of the board of directors of ThirdWay Interiors Limited