Environmental, Conflict Minerals and Modern Slavery Policies

Morvan Trading aims to operate in an efficient and environmentally sustainable manner, and has set out an environmental policy and employee training to put this into effect.

Emissions reduction Where possible limit use of the fork lift truck, and use fuel additive to limit emissions.  When sending parcels and pallets, we try to favour carbon-neutral courier companies; we also consolidate imports into larger consignments less i.e. to completely fill a 40’ container with mains leads.  Employees are encouraged to walk or cycle instead of driving.  Customers are advised on product-specific applications, for instance recommending low smoke zero halogen (LSZH) cable where fumes from burning cables may be a health risk. 

Waste elimination It is key to Morvan Trading’s culture to operate as efficiently as possible to eliminate waste, following quality procedures to minimise mistakes.  We ensure products are specified correctly to customers and manufacturers including electrical, safety and approvals standards.  We routinely advise and guide customers on the relative merits of standard parts versus custom made.  We limit paper usage in the office, e.g. emailing instead of posting invoices, duplex printing etc.  Recently, we now avoid plastics and disposable items, e.g. pin protectors on the UK plug, leads in individual plastic bags etc.  As an ongoing strategy we involve suppliers and factories, for example redesigning the UK plug to be thinner and therefore use less raw material when manufactured, less space in storage, and less weight in transport.  We have added roof insulation and installed double glazed windows to reduce heating losses in the office.

Recycling We reuse all packaging materials, including box cartons, cardboard, pallets, cellophane shrink wrapping, plastic bags.  We recycle office waste, e.g. using shredded waste paper as a packaging material.  As part of our best practice, we analyse slow moving stock, product end-of-life,  and recycle products, either repurposing mains leads, customising to different specification, or recycle for individual components (copper wire, pvc cable insulation etc).

Renewable energy We promote renewable and clean energy, and in our case particularly photovoltaic (PV) electric supply.  In our supply of moulded mainsleads and rewireable plugs and sockets we regularly support renewable energy companies in the UK and internationally.

Being an environmentally sensitive neighbour We aim to limit local noise pollution, including daily operations and road vehicles, and keep to office hours.  We have planned to limit potential fire risks in warehousing where burning mains cables may release fumes into the local area, e.g. fireproof doors.  We support green areas locally, including wildflowers.

Continuity The environmental policy is to analyse the past, current, future and potential environmental impact of our operations and products.  UK, EU, and other national environmental legislation and updates are to be met and exceeded where possible (for example RoHS even when not required outside the EU, or USA power cables meeting American requirements even if not sold into the USA).  The policy is subject to periodic review, and is intended to be continuously improved.


 

Conflict Minerals Policy Conflict resources or minerals originate in war zones and are sold by the belligerents to fund their cause and perpetuate conflict: the most common example is blood diamonds. 

The 2010 USA Dodd-Frank Wall Street Reform and Consumer Protection Act requires American manufacturers to audit their supply chains and report the use of conflict minerals (some reporting requirements were removed in 2015).

The most important conflict mineral ores are refined to tin, tungsten, tantalite and gold, sometimes summarised by their initials as ‘3TG’.  Generally, these are most commonly found in electronics.

  • Casserite ore is the main ingredient in tin, used in solder and on circuit boards, and also in biocides and paints
  • Wolframite is a major source of tungsten, a very dense metal used where resistance to wear is important, especially as tungsten carbide (e.g. drill bits etc)
  • Columbite-tantalum (ColTan) ore contains tantalum, used in very small high performance tantalum capacitors used in phones etc; tantalum carbide has the same uses as tungsten carbide
  • Gold is used for investment and in jewellery; it is also very conductive and has many uses in electrical contacts within electronics

Mines in the Eastern Congo are generally remote and controlled by paramilitary groups linked to either one of the rebel armies or the Congolese National Army; they are generally controlled by violence and characterised by very dangerous working conditions.

The Dodd-Frank Act applies to these minerals mined in the Democratic Republic of the Congo (DRC), or originating in neighbouring states: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, Zambia, and Zimbabwe.  It aims to prevent the sale of conflict minerals funding armed groups and perpetuating fighting, corruption and human rights abuses in the DRC.  It does not, however, address the root causes of the current Congolese civil war or larger problems since independence.  The European Commission has similar non-binding guidelines in Commission Recommendation (EU) 2018/1149, and the OECD has published due diligence guidance for responsible supply chains of minerals from conflict-affected and high-risk areas.

Conflict Minerals statement As Morvan does not sell electronic equipment, this requirement largely does not apply.  However, in the interests of our customers’ supply chain auditing, we can confirm that Morvan designates products as conflict-mineral free based on information provided by our suppliers, who have advised that these minerals are not used, or that if used they have not originated in the DRC.  Morvan has taken all reasonable steps to confirm suppliers' statements regarding the absence of conflict minerals.


 

Modern Slavery Policy

The UK Modern Slavery Act was introduced in 2015 to combat modern slavery in the UK, and consolidated previous human trafficking and slavery legislation.  The Act includes the offences of “slavery, servitude and forced or compulsory labour; human trafficking.”

The original Bill did not include slavery outside the UK, and as a result of lobbying clause 54, the Transparency in Supply Chain Provision, was added, which requires businesses with turnover over £36M per year to audit their supply chains and produce a publicly available report.

With annual turnover under the specified threshold we are not required to provide a statement, but we recognise that our customers may be required to, and as a result have included this declaration in our company ethics.

We do not allow any form of slavery or human trafficking in any part of our operations. We do not use child labour (cf. Minimum Age Convention), nor do we use forced labour.  We source goods and services from companies that meet, or are willing to meet, our ethical standards.

Other countries with similar legislation: Australia, Belgium, Brazil (the Dirty List), Croatia, France (Duty of Vigilance law), Germany, Nepal, the Netherlands, Portugal, Norway, Qatar, (ending Kafala), Spain, Sweden, Switzerland, USA (Federal Acquisition Regulation); the UN has also published guidelines.

Further definitions may be found in:
Slavery and Servitude: 1926 Slavery Convention
Forced or Compulsory Labour: ILO Forced Labour Convention 29
Human Trafficking: Palermo Protocol