Slavery & Human Trafficking Statement FY 2019

1. Our Structure:

PEI/Genesis, Inc. (“PEI”) is a privately- held company founded in 1946 by Murray Fisher and Bernard Bernbaum. Together with its affiliated companies, PEI is one of the world’s fastest assemblers of precision connectors and cable assemblies and maintains one of the world’s largest inventories of electronic components. PEI is still owned by the Fisher and Bernbaum families, with Steven Fisher leading the company as Chairman and CEO.

PEI’s global head office is in the United States in Philadelphia, Pennsylvania and the European head office is in Southampton, Hampshire, UK. PEI has factories in the United States in Chandler, Arizona and South Bend, Indiana, and in Zhuhai China. PEI also has 15 sales offices throughout out the United States, Europe and Asia.

2. Our Commitment and Policy:

At PEI we know we have a responsibility to ensure that our business is conducted in an ethical way. PEI is a truly global business and takes a proactive approach to ensure we comply with all laws and regulations concerning slavery and human trafficking. We take seriously our responsibility to comply with such requirements in each of the jurisdictions in which we are located, such as the United States Federal Acquisition Regulation (“FAR”), the United States Defense Federal Acquisition Regulation Supplement (“DFARS”), the California Transparency in Supply Chains Act of 2010, and The Modern Slavery UK Act 2015. PEI monitors its internal practices in relation to its employees and its supply chain partners and customers to ensure compliance with these laws and regulations.

PEI procures electronic connectors, cables and components from suppliers and manufacturers located around the world. We have zero tolerance to slavery in all its forms and our commitment to ensuring that Modern Slavery does not take place within our own business operations extends to our suppliers. Specifically, PEI’s Terms and Conditions of Purchase obligate our suppliers to undertake all necessary actions to ensure that all their employees and supply chain are compliant with all relevant legislation.

PEI does not obtain labour by means of slavery or human trafficking. PEI strictly adheres to the standards set out in the relevant employment legislation in each country in which it operates. PEI’s Human Resources department ensures that PEI is up to date with all employment legislation and works closely with country specific lawyers to track updates and changes to legislation. This includes all levels and types of employment including permanent, fixed term, part time, remuneration, and benefits. PEI does not employ anyone on zero-hour contracts.

We also have a strong values-based philosophy called ICARE which underpins all our business activities. ICARE is an acronym that stands for:

Innovation & Integrity

Continuous Measurable Improvement

A Team Approach (Teamwork)

Respect

Excellence to Others

This is the ‘heartbeat’ of PEI Genesis and a set of values that all employees must uphold.

3. Risk Assessment:

PEI considers its exposure to modern slavery to be very limited; however, we have taken steps (which are regularly reviewed) to ensure that we fully comply with all legislation globally.

4. Our Due Diligence Process:

As part of our commitment to identify and mitigate the risk of slavery and human trafficking occurring in our supply chain we have in place:

  • Regular assessments of our suppliers
  • Conditions of purchase requiring our suppliers to warrant that they have thoroughly investigated their labor practices and those of their supply chain, to ensure that there is no slavery or forced labor used anywhere in their organization or by any suppliers or subcontractor to their organization.
  • An internal Code of Ethics
  • A specific policy to protect whistle blowers
  • A Corporate Social Responsibility policy
  • Internal Slavery and Human Trafficking policies
  • Adequate and regular training to relevant employees on identifying modern slavery in supply chains
  • Education to all employees on commencement of their employment that outlines all relevant polices
  • A Compliance Team, ensuring our suppliers and customers are trading ethically, and capabilities allow PEI to refuse to work with any supplier or customers if they are found to be in breach of laws.

5. New in the Past 12 Months:

  • Full online training for all employees as part of their induction regarding Slavery and Human Trafficking. This will be repeated to all employees on an annual basis and is mandatory.
  • Appointment of a Corporate Ethics officer who is PEI’s Chief Financial Officer. There is also an Ethics Portal for any PEI employee to report any unethical behavior by fellow employees, suppliers or customers.

6. Review/Measuring Effectiveness:

  • This statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2010 and the relevant legislation in the other countries and will be reviewed and resubmitted each financial year based on PEI’s Fiscal Year which runs from September through August. This statement if for the period from 1 September 2018 through 31 August 2019.

Gregory Warshaw
Senior Vice President and Chief Financial Officer
March 2019

UK modern slavery act compliance and anti-slavery statement central register

tiscreport.org is the World's largest Open Data Register committed to ending Modern Slavery and supply chain labour abuses, joining up Transparency In Supply Chains (TISC) reporting globally. As an open data initiative, it meets the compliance requirements of section 54 of the Modern Slavery Act 2015 of the Home Office, and was announced at the Home Office TISC event on the 21st March 2016.