Policies
This page provides you with all the Morvan Trading policies – click on a subject to jump to that section.
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Learn more about Morvan Trading, our experience and international power-cable services.
Code of Conduct
Key Statement
A pivotal point of our company philosophy is a conscious individual and collective ethos to do the right thing.
Applicability
This code of conduct lists our general expectations. Rather than a comprehensive and categoric list of dos and don’ts, it should be viewed as a framework to operate within, like a conscience. It applies to all our stakeholders: suppliers, subcontractors, staff, and customers, with variations depending on context.
Ethical operations
We have built our reputation as a customer service-centred independent family business that keeps its word. This is due in large part to our adherence to a moral code to be ethical and honest in all our dealings, and expect the same standards from others. We will avoid conflicts of interest; failing that we will notify one or both parties should one arise, and if necessary decline the job. We pay our suppliers in a timely fashion, and expect the same from our clients.
Legal and regulatory compliance
As a company registered in England and Wales, we will conform to UK legislation and applicable international rules. An example is the Modern Slavery Act (2015) against supply chain “slavery, servitude and forced or compulsory labour; human trafficking.” When reasonable we will endeavour to also comply with the regulations in the jurisdictions of our non-UK commercial partners. Due to the international nature of our business these may sometimes be incompatible.
We shall not breach UK, UN, or certain other economic sanctions by exporting to embargoed countries without the proper permits, and expect our customers to do the same with our products.
We provide substance and material declarations to local editions of RoHS, REACh, PFAS, toxic substances, and conflict minerals based on supplier declarations to us.
Products will comply with national or international standards, and are usually certified by at least one independent approvals body.
Just Culture
We believe in accountability for our actions. Blame may be apportioned, but mistakes should be viewed as a learning experience for all involved, with a suitable response being: 1) why did it go wrong, 2) we’ll do this to fix it, 3) how do we stop it happening again. This is applicable both internally and externally, including whistleblowing and notification of relevant bodies.
Workplace, Health and Safety, and Environment
Our working environment should be inclusive, respectful, and safe, with fair treatment and equality for all. This means no discrimination, harassment (physical, sexual, verbal). Outwardly we project calm, respect, professionalism, and courtesy. We expect the same with everyone with whom we deal.
Our premises should be safe for all users: employees, couriers, and visitors. This is effected through risk assessment and threat and error management. This should be the case up and down the supply chain. This similarly applies to our products, to protect stakeholders throughout the supply chain, from raw material extraction to end-of life recycling.
We believe in protecting the environment, and do this through limiting waste, conserving natural resources, and avoiding hazardous materials. Cf. our Environmental policy.
Record keeping, data protection
Morvan Trading records are kept for minimum of 10 years. In some cases, involving continuing quality assurance or legal requirements, this may be longer or indefinite. Your records may be removed at request, although a bare minimum may be retained for quality or legal reasons. We will keep safe, protect, and back up our data, including not divulging proprietary or confidential information. If in doubt, it’s safer to not share information.
In the case of consultancy, we provide an opinion based on information provided; on the assumption no key points are withheld, this usually means the more information the better quality reply. If things change, please inform us, as this may have consequences on the product or application.
Reporting mechanism
We have a formal complaints procedure. Breaches of this code of conduct should be reported to senior management. This may be anonymously if desired.
Penalties
Non-conformance to this code of conduct has penalties including but not limited to: removal of business, account closure, disciplinary action.
Environmental Policy
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
Head Office
Morvan Trading Ltd,
Westover Farm,
Goodworth Clatford,
Andover, Hampshire,
SP11 7LF