Modern Slavery and Human Trafficking Statement

Document title: Modern Slavery and Human Trafficking Statement
Organisation: Thame Engineering Company Limited, trading as Thame Workholding
Statement period: Financial year to 20 August 2026
Version: 1.0
Approved by: Mark Thomas, Managing Director (on behalf of the Board)
Date approved: 20 August 2026
Next review: 20 August 2027

1. Our commitment

Thame Workholding is committed to acting ethically and with integrity in all our business dealings, and to preventing modern slavery and human trafficking in our operations and our supply chain. We have a zero-tolerance approach to slavery, servitude, forced or compulsory labour and human trafficking in any form.

This statement sets out the steps Thame Engineering Company Limited (trading as Thame Workholding) takes to understand and address the risk of modern slavery in our business and supply chains. While our turnover means we are not currently required to publish a statement under section 54 of the Modern Slavery Act 2015, we make this statement voluntarily, in line with the principles of the Act, as a matter of good practice and to give our customers assurance about our supply chain.

It relates to the financial year to 20 August 2026 and will be reviewed and updated at least annually.

2. Our organisation, business and supply chains

Thame Workholding is a British manufacturer of precision workholding equipment and the exclusive UK agent for a number of specialist international workholding brands. We operate from a single site in Long Crendon, Buckinghamshire, and supply customers in the aerospace, defence, automotive, medical, oil & gas and general engineering sectors.

Our supply chain includes:

UK and overseas manufacturers of workholding products and components;
suppliers of raw materials, principally steels and non-ferrous metals;
providers of tooling, cutting fluids, coolants and workshop consumables; and
providers of logistics, facilities and professional services.

As both a manufacturer and an agent for established international brands, most of our spend is with long- standing, reputable manufacturing partners, which we consider to be lower-risk. We remain alert to the fact that risk can arise deeper in the supply chain, particularly in the extraction and processing of raw materials.

3. Our policies

Our approach to modern slavery is supported by a framework of related policies, which are reviewed periodically:

CSR & ESG Policy – setting out our zero-tolerance approach to modern slavery and our wider commitment to responsible business.
Sustainable Procurement Strategy – embedding ethical and social considerations, including labour standards, into how we source.
Supplier Code of Conduct – requiring suppliers to prohibit forced, bonded and child labour, to uphold workers’ rights, and to apply equivalent standards through their own supply chains.
Recruitment practices – we verify and document the identity and right to work of everyone we employ, and pay at least the National Minimum / National Living Wage.
Whistleblowing route – employees and workers can raise concerns, without fear of reprisal, with their line manager, a director, or the Accounts and Quality Manager (who is responsible for HR), with external support available.

4. Due diligence

We take a proportionate, risk-based approach to due diligence across our supply chain. In practice this means we:

approve and monitor suppliers within our ISO 9001:2015 quality management system;
source wherever possible from original manufacturers and franchised or authorised distributors, and from established, long-standing partners;
seek acceptance of our Supplier Code of Conduct from our suppliers, prioritising our key and higher-risk suppliers; and
apply greater scrutiny to any supplier or category assessed as higher-risk.

5. Risk assessment and management

We assess modern slavery risk by supplier category and geography. We consider the following to be relevant to our business:

the origin and processing of raw materials such as metals, which can carry higher inherent risk further up
the chain;
the use of any agency or temporary labour; and
lower-tier suppliers over whom we have less direct visibility.

Where we identify higher risk, we focus our engagement and due diligence there. We have not identified any incidents of modern slavery in our business or supply chain. Should any concern arise, we would investigate it and take appropriate action, including working with the supplier to remediate or, where necessary, ending the relationship.

6. Measuring effectiveness

We monitor the effectiveness of our approach using practical measures, which we will develop over time.
These include:

the proportion of our procurement spend covered by suppliers who have accepted our Supplier Code of Conduct, for which we have set an initial target of at least 80% by 31 August 2027;
the proportion of spend placed with quality-accredited suppliers; and
the number and nature of any concerns raised through our whistleblowing route.

7. Training and awareness

We make relevant staff — particularly those involved in purchasing, recruitment and management — aware of modern slavery risks, the indicators to look for, and how to raise a concern. We will provide further training proportionate to risk as our approach develops.