2021 UK Modern Slavery Act Statement
Introduction
This Statement is made voluntarily pursuant to Section 54(1) of the Modern Slavery Act 2015 (the “Act”) by General Electric Company on behalf of its affiliates conducting business in the UK and covered by the Act (as listed in Appendix A herein referred to as "GE Reporting Entities"), (together the “Company” or “GE”). The Statement discusses actions GE took in its prior fiscal year to address risks of modern slavery in its own operations and value chain, and which the Reporting Entities participated in as part of GE's human rights program.
GE delivers innovative solutions and services to provide essential infrastructure for the world. GE works with the highest integrity, a compliance-oriented culture, and respect for human rights, while also setting ambitious goals to reduce emissions through operational efficiencies and technology. This statement builds on statements submitted under the California Transparency in Supply Chains Act of 2010 and the Australian Commonwealth Modern Slavery Act 2018 to demonstrate GE's continued commitment to address modern slavery and other human rights risks throughout its global operations and value chain. GE is proud of its efforts on this issue but is mindful that its program must continually improve as it remains vigilant in its fight against this global human rights crisis.
GE continued its extensive efforts to prevent forced labor in the Company's supply chain through on-site audits, employee training, and supplier pre-qualification and education. GE views multi-stakeholder collaboration as critical to winning this battle, and in 2020 continued to engage in joint efforts to drive change in challenging regions and sectors, particularly in the area of ethical recruiting.
Key Information:
- Since 2005, GE businesses have conducted more than 34,000 supplier assessments spanning 100 countries.
- GE is committed to taking steps to prevent acts of modern slavery and human trafficking in its business operations and supply chains.
- For more information, visit: www.ge.com/sustainability/human-rights-supply-chain or email: sustainability@ge.com
GE's Business Segments:
- GE Power ⚡
- GE Renewable Energy ?️
- GE Aviation ✈️
- GE Healthcare ?
Our Structure, Operations & Supply Chain
Structure and Operations
GE is a high-tech industrial company that operates worldwide through its four industrial segments: Power, Renewable Energy, Aviation, and Healthcare, and its financial services segment, Capital. At year-end 2020, GE and consolidated affiliates employed approximately 174,000 people, of whom approximately 8,843 were employed in the UK. A more detailed description of GE's business operations and ambitions can be found in its 2020 Annual Report.
GE serves customers in over 170 countries. Manufacturing and service operations are carried out at 82 manufacturing plants located in 28 States in the United States and Puerto Rico and at 149 manufacturing plants located in 34 other countries. Approximately 12 are located in the UK.
GE owns and controls the GE Reporting Entities listed in Appendix A. GE Company is incorporated in New York, with its principal executive office in Boston, Massachusetts, USA.
Supply Chain
GE's supply chain is expansive and global, spanning 125 countries. GE sources a wide variety of raw materials and components that are incorporated into its products and services. The largest categories of direct material purchases are castings, forgings, electronics, plastics, and machined parts. GE also buys products and services to support its business operations, which are used to develop or create, but are not incorporated into, GE's products or services.
Our Commitments & Programs
GE's commitment to human rights is grounded in the United Nations Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the Ten Principles of the United Nations Global Compact. GE strives to respect the fundamental dignity of everyone it might affect directly through its operations, products, and services and indirectly through its business relationships across the globe. GE's ideals flow from the International Bill of Human Rights, the International Labor Organization Declaration on Fundamental Principles and Rights at Work, and the Sustainable Development Goals.
GE addresses modern slavery risks through specific policies, training and awareness, due diligence, and remediation.
Policies & Standards
The Company's Human Rights Statement of Principles (applicable across GE, including the Reporting Entities) is the cornerstone of its global program, emphasizing the importance of "respect for fundamental human rights." The Statement specifically prohibits reliance on any form of forced, prison, or indentured labor and is embedded in expectations of all businesses and personnel through its Code of Conduct, The Spirit & The Letter. The Spirit & The Letter (“S&L”) sets the Company's expectations regarding ethics & compliance and applies to all GE directors, officers, and employees, including those working for its subsidiaries and affiliates. All new hires are required to review and agree to abide by the S&L during the onboarding process, and employees are further expected to annually acknowledge their commitment to comply. The S&L and its accompanying policies, including a new policy dedicated exclusively to human rights, address the full spectrum of integrity and compliance issues across GE's global value chain. GE expressly prohibits the types of actions associated with the most common forms of modern slavery, including the charging of recruitment fees, the withholding of immigration documents, and the use of misleading recruitment tactics. Violations of this policy can result in disciplinary action, up to and including termination.
The Human Rights Enterprise Standard (applicable across GE, including the Reporting Entities), released in 2020 and intended specifically for GE business compliance professionals, supplements the S&L Human Rights Policy by setting forth the core human rights expectations of the businesses. More specifically, the document outlines auditable controls and requires that the businesses have appropriate mechanisms in place to monitor those controls. The Enterprise Standard further sets out minimum requirements regarding risk assessment and mitigation, due diligence of third parties, and escalation and remediation of any concerns related to human rights. Other related policies and procedures, such as the S&L Environmental, Health, and Safety Policy and the S&L Respectful Workplace Policy, are also embedded through GE's business enterprise through similar enterprise standard and policy documents.
The Company's Integrity Guide for Suppliers, Contractors and Consultants (which is applied by all GE companies, including the Reporting Entities, when applicable) extends the reach of its Code of Conduct and its requirement of "unyielding integrity and high standards of business conduct" to its suppliers and their subcontractors, including labor providers. Beyond compliance with all applicable local laws and regulations, the Integrity Guide mandates third-party adherence to GE standards in areas including fair employment practices, environment, health and safety, and human rights. In the area of forced labor, the Integrity Guide expressly prohibits any form of compulsion, coercion, or human trafficking; lists prohibited activities associated with trafficking, such as withholding passports, charging recruitment fees, and misleading recruitment; and imposes affirmative obligations on suppliers in certain circumstances such as reimbursement of return transportation costs and providing workers with written contracts in a language they understand. The Guide also encourages reports of violations of the policy through telephone, email, and in-person channels by employees and third parties.
Total SRG On-Site Audits in 2020: 1,286
- Onboarding/New Suppliers: 608
- Recertifications/Existing Suppliers: 616
- Suppliers from Acquisition: 62
Governance
GE has embedded respect for human rights throughout its global organization. Its Global Human Rights Counsel is responsible for setting human rights strategy for GE businesses, including its modern slavery program. She works closely with a cross-functional Environmental, Social and Governance ("ESG") Steering Committee, comprised of senior personnel from across the Company, to establish ESG priorities and coordinate GE's global initiatives. The Company's Board of Directors and its committees oversee the execution of GE's ESG strategies and initiatives – including regarding human rights – as an integrated part of their oversight of GE's overall strategy and risk management. The Reporting Entities, through their business divisions, are responsible for operationalizing the Company's governance strategy.
Training & Awareness
GE's human rights program depends on the practical understanding of its people and business partners. GE provides its businesses with learning modules on human rights and forced labor which give employees an easy, efficient way to understand the core principles of human rights; the Company-wide policies and programs; the causes and global footprint of forced labor; and most importantly, how they can serve a role in identifying and reporting possible signs of modern slavery when they are at GE operations, supplier facilities, or customer sites.
GE ensures that this awareness raising is ongoing. GE maintains an internal human rights communications page through which business employees can receive updates and participate in conversations concerning human rights and forced labor. GE has also distributed an internal training video discussing a real wage-withholding scenario one of its businesses confronted with its vendors and using that example to once again educate the workforce on issues that can lead to forced labor.
GE businesses provide their direct material suppliers an online compliance video that includes a module explaining GE's position on human rights, with a more in-depth focus on forced labor – what it is, how extensive the problem is globally, and what suppliers must do or avoid doing to comply with GE's forced labor policy. Suppliers view this video as part of their commitment to abide by GE's Integrity Guide. The Company also provides training on its forced labor prevention expectations to potential Engineering, Procurement, and Construction ("EPC") partners on large GE Power and Renewables construction projects, where low-skilled, migrant labor will likely be working.
In 2020, GE enhanced training modules for its employees and business partners by creating "fast training" learning modules on human rights and forced labor for a brief, practical way to understand indicators of key risks; the Company's policies and programs; the causes and global footprint of forced labor; and most importantly, how they can serve a role in identifying and reporting possible signs of modern slavery when they are at GE operations, supplier facilities, or customer sites.
Processes & Risks: Due Diligence & On Site Supplier Assessments
GE strives to ensure compliance with these policies through a rigorous due diligence program reaching throughout its value chain. One significant way GE advances respect for human rights, in particular in the area of forced labor, is through its well-established, multifaceted ethical supply chain program. Under this program, GE businesses (of which the Reporting Entities are a part) conduct due diligence on their suppliers, known as the Know Your Supplier ("KYS") process, where, based upon the location and type of service engagement, GE will research and review the third party for human rights risks. Additionally, suppliers in high-risk countries will undergo an in-depth, on-site assessment of their manufacturing site, both before they are approved for onboarding and periodically thereafter, to ensure supplier compliance with GE's principles on fundamental human rights. Among other things, these assessments inquire specifically into how workers are recruited into their jobs and treated by their employers to detect any conditions of modern slavery.
In 2020, despite the restrictions and impacts caused by Covid-19, GE businesses, including those within which the Reporting Entities sit, assessed approximately 1,286 new or existing suppliers, generating more than 7,300 findings. About 48% of GE's total assessments in 2020 were reassessments. Since 2005, GE businesses have conducted more than 34,000 supplier assessments spanning 100 countries. GE publishes an annual overview of its businesses' supply chain assessment results on its website. The human rights portion of the assessment focuses significantly on forced labor indicators, such as wage practices, recruitment efforts, and passport handling. The questionnaire and indicators provide GE with a way to assess potential suppliers on their human rights programs, educate them as to the nature of forced labor, and explain what is needed to prevent it.
Supplier Audits by Region (2020):
- China: 527 ??
- Europe, Middle East & Africa: 117 ??
- India: 360 ??
- Latin America: 147 ?
- Mexico: 22 ??
- Rest of Asia: 113 ?
Ensuring Continuous Improvement
GE assesses the effectiveness of actions through the Human Rights Working Group, review & analysis of its supply chain audit results, and learnings from the Open Reporting & Ombudsperson program.
Human Rights Working Group
In 2020, the Global Human Rights Counsel launched a cross-functional Working Group of human rights champions across all GE business units. The Working Group meets regularly to review key findings, share important legal and regulatory alerts, learn best practices, and discuss trends identified through its various due diligence and investigative processes. The Working Group is comprised of different functions – including Human Resources, Sourcing, Legal/Compliance – to address feedback and opportunities. As deemed necessary, the Working Group may partner with local business teams to engage suppliers on their compliance and human rights programs to understand how modern slavery risks are mitigated. The Working Group also focuses on the implementation of the Human Rights Enterprise Standard.
Ongoing Assessment & Effectiveness Review
As GE strives for continuous improvement in all aspects of its operations, an ongoing assessment of the human rights program was conducted in 2020. GE's internal audit team conducted an audit of the human rights program at various businesses and project worksite locations. As a result of the audit and review, GE issued the "Human Rights Guidelines for Project Worksites," a guidance for individuals working at ongoing project sites. The guidance provides workers with an overview of fundamental human rights, an appreciation of how violations of these rights come up in the workplace, and an understanding of how to detect, respond to, and remediate identified issues.
GE Open Reporting & Ombudsperson Program
The GE Open Reporting & Ombudsperson Program, comprised of hundreds of trained employees at the Corporate and business level, is a chief vehicle for the Company to hear from employees regarding any violations of its integrity standards. The program enables employees to raise concerns, including those relating to respect for human rights, confidentially and without fear of retaliation. Consistent with its Human Rights Statement of Principles, and in the spirit of "Eyes Always Open," employees are expected to report unfair employment practices and human rights concerns they observe at GE sites or working with direct business partners.
GE'S PARTNERSHIP WITH THE GLOBAL BUSINESS INITIATIVE
As a founding member of Global Business Initiative on Human Rights (GBI), GE is committed, along with other member multinational corporations, to embed respect for human rights into its business operations. Peer learning and benchmarking enables GE to determine the right strategy and process to address human rights risk in its business area. By connecting with industry leaders and engaging with this business-led group, GE gains insights into emerging trends and issues and examines challenges and potential solutions that other members have experienced.
Our Partnerships
- Beyond its own workers and suppliers, GE and its businesses engage with external stakeholders to identify human rights risks throughout its value chain and to collaborate with peers, experts, and civil society groups to seek practical solutions. The GE Foundation, for instance, has funded the Institute for Human Rights and Business Responsible Recruitment Initiative, focused on addressing modern slavery. GE is also a Participant in the UN Global Compact (including the Human Rights and Business Dilemmas Forum).
- As a founding member of Global Business Initiative on Human Rights, GE is committed, along with other member multinational corporations, to embed respect for human rights into its business operations. Peer learning and benchmarking enables GE to determine the right strategy and process to address human rights risk in its businesses. By connecting with industry leaders and engaging with this business-led group, GE gains insights into emerging trends and issues, and examines challenges and potential solutions that other members have experienced.
GE is actively engaged in the Leadership Group for Responsible Recruitment, a collaboration between leading companies and expert organizations to drive positive change in the way that migrant workers are recruited, with a focus on eliminating fees being charged to workers to secure employment. The aims of this initiative are to:
- Create demand for responsible recruitment by raising awareness about the benefits of ethical practices and developing tools to help companies implement the Employer Pays Principle.
- Increase the supply of ethically sourced labor by creating an enabling environment and supporting the development and implementation of systems to identify and use ethical recruitment agencies.
- Advocate for improved protection for migrant workers by brokering dialogue to promote the effective regulation and enforcement of the recruitment industry.
Conclusion
The UK Modern Slavery Act serves a significant role in driving transparency in global efforts to address the problem of modern slavery. As discussed above, GE and its businesses, including the Reporting Entities, continue to build on the Company's longstanding human rights program to better identify and prevent forced labor in its own operations and those of its suppliers and business partners. This global scourge can only be overcome by a joint effort of states, private enterprises, and civil society. GE has been and remains committed to upholding its fundamental role in this critical effort.
This statement was approved voluntarily by the Board of General Electric Company and pursuant to Section 54(1) of the UK Modern Slavery Act by the Boards of the Reporting Entities as listed in Appendix A.
H. Lawrence Culp, Jr.
Chairman of the Board and Chief Executive Officer
General Electric Company
Appendix A
Company Name
ACAM Overseas Holdings | GE Capital Limited | GE Intelligent Platforms UK Limited |
Altair Filter Technology Group Limited | GE Capital Sigma Holding Ltd | GE Medical Systems Limited |
Altair Filter Technology Ltd | GE CIF Property Nominee Company No 1 Limited | GE Medical Systems Oxford Limited |
Altair Holdings UK Limited | GE CIF Property Nominee Company No 2 Limited | GE Money Consumer Lending Limited |
Blade Dynamics Limited | GE Digital Software Solutions Limited | GE Money Home Finance Limited |
Blade Dynamics Tidal Energy Limited | GE Digital UK Limited | GE Money Home Lending Limited |
Datex-Ohmeda Limited | GE Energy (UK) Limited | GE Money Mortgages Limited |
Drives & Controls Services Ltd. | GE Energy Power Conversion Technology Limited | GE Money Secured Loans Limited |
EFS Los Guindos UK Limited | GE Energy Power Conversion UK Holdings Limited | GE Money Servicing Limited |
EFS UK Holdings Limited | GE Energy Power Conversion UK Limited | GE Oil & Gas Marine & Industrial UK Ltd. |
G.E. C.I.F. Trustees Ltd. | GE Energy Services (UK) Limited | GE Pension Trustees Limited |
G.E. S.P.S. Pension Trustees Ltd. | GE Financial Investments | GE Power Conversion Brazil Holdings Limited |
GE (Holdings) | GE Financial Markets Funding I | GE Power UK |
GE Additive UK and Ireland Limited | GE Grid Solutions (UK) Limited | GE Protimeter Limited |
GE Aircraft Engine Services Limited | GE Healthcare (AB) | GE Renewable UK (Holdings) Ltd |
GE Asset Management Limited | GE HEALTHCARE (NMP) LIMITED | GE Smallworld |
GE Aviation Systems Group Limited | GE Healthcare Clinical Systems (UK) Limited | GE Steam Power Ltd |
GE Aviation Systems Limited | GE Healthcare Finnamore Limited | GE UK Group |
GE Aviation UK | GE Healthcare IITS UK Limited | GE UK Holdings |
GE Bio-Sciences Investments Limited | GE Healthcare Limited | GEAPS PENSION TRUST LIMITED |
GE Boving Himachal Pradesh Limited | GE Healthcare Pension Trustee Limited | GECAS Asset Management Services UK |
GE Caledonian Limited | GE Healthcare Structured Projects (UK) Limited | GECAS UK Limited |
GE Capital Corporation (Holdings) | GE Healthcare UK Limited | GEFM Edinburgh I Limited |
GE Capital EMEA Services Limited | GE Industrial Consolidation Limited | GEH Holdings |
GE CAPITAL EQUIPMENT FINANCE LTD | GE Industrial Finance UK Limited | GEHC (ATL) Limited |
GE Capital Europe Limited | GE Industrial Sterling Treasury Services | GENERAL ELECTRIC ENERGY UK LIMITED |
GE Capital European Treasury Services Limited | GE Industrial Treasury Holdings | General Electric UK Holdings Ltd. |
GE Capital Finance | GE Infrastructure Aviation | Grid Solutions HVDC India Limited |
GE CAPITAL FUNDING SERVICES LIMITED | GE Infrastructure UK Limited | I.G.E. (USA) Pension Trustees Limited |
GE Capital Group Services Limited | GE Inspection and Repair Services Limited | IGE Dollar Treasury Services |
GE Capital International 1 Limited | GE Inspection Technologies Limited | IGE Energy Services (UK) Limited |
GE Capital International 4 Limited | GE Intelligent Platforms (Bracknell) Limited | IGE Euro Treasury Services |
GE Capital International Holdings Limited | IGE Sterling Treasury Services Limited | |
GE Capital International Investments Limited | IGE USA Group | |
GE Capital Investments | IGE USA Holdings | |
IGE USA Investments Limited | Monica Healthcare Limited | UK Grid Solutions Limited |
igroup8 limited | Oliver Crispin Robotics Limited | Vetco Group |
International General Electric (U.S.A.) | One GE Healthcare UK | Vetco International Limited |
Key Leasing Limited | Pignone Engineering | Water Lane Trustees Limited |
MAES Finance Limited | Rapidscan Pharma Solutions EU Limited | Whatman International Limited |
Milestone Aviation UK Ltd | Red Artificial Lift UK Limited | Whatman Limited |
Milestone Aviation UK No. 2 Limited | Smallworldwide Limited |
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