At Berger Tools Limited, we have a strong commitment to conducting our business in a lawful and ethical manner. This document supports the implementation of Berger Tool’s policies regarding business ethics, social, safety, health and environmental performance, by providing a brief explanation of the company’s basic expectations of all its business partners.
For the purposes of this Business Code of Conduct, “Business Partners” include suppliers, customers, contractors, employees, consultants, agents, and any other third parties with whom the Company has a business relationship, who are all expected to adhere to these policies.
Berger Tools Limited encourages open communication and expects business partners to report any suspected unethical behaviour, legal non compliance or breaches of this Code within Berger Tools or its supply chain. Reports will be taken seriously, treated fairly and handled confidentially. No business partner will be disadvantaged for raising a genuine concern made in good faith.
Berger Tools Limited expects all employees and business partners to uphold the highest standards of honesty, integrity, fairness and professionalism in all business dealings. Ethical business conduct is fundamental to building trust and long term relationships and is a basic condition of working with Berger Tools Limited.
Business partners are required to:
Berger Tools Limited also expects its business partners to operate in a reliable, professional and responsible manner. This includes:
Repeated failures to meet commitments, poor communication or lack of accountability may be considered a breach of this Code of Conduct.
Berger Tools operates a Management System certified to BS EN ISO 9001:2015 and BS EN ISO 14001:2015
This statement sets out the approach to the Quality and Environmental Management policy adopted by Berger Tools Limited.
The Company is in the business of:
The stockholding and supply of quality standard parts; special parts; mould components, press tool components; tooling components; standard machine elements and related equipment mainly to the manufacturing sector ranging from the automotive to white goods and mechanical engineers.
The Company recognises that sound business management must understand the impacts of its activities and products with regard to the quality of performance, and to the environment.
The Company’s primary objectives, supported by its quality and environmental policy commitments, are also dependent on achievement of secondary objectives as formulated and documented from time to time, are:
1. The continued operation of a viable and profitable business.
2. To meet and fulfil customers’ requirements.
3. To monitor and review its activities for actual / potential impacts on the environment in order to seek continual systems and activity improvements, and the prevention of pollution.
4. To comply with applicable legal, regulatory and contractual obligations and requirements.
In recognition of the importance of clearly documenting its combined quality and environmental policy to employees, and (if requested) to other interested parties, the Company has taken measures to ensure that the policy is readily available for review. The Company recognises that its positive commitment to its policy is of interest to clients, and possibly other parties
The Company is aware that satisfied customers and informed, competent, employees are vital to the realisation of the prime objectives and realises that it has to identify and supply the resources necessary to effect the desired outcomes, while at the same time observe any applicable statutory/regulatory measures.
To achieve its objectives, the Company is committed to the operation of an effective Management System by ensuring that its activities are undertaken in accordance with defined procedures and instructions. To ensure the continuing suitability of the Management System (which is designed to meet the requirements of the ISO 9001:2015 and ISO 14001) and resources employed, activity results are monitored, analysed and reviewed for effectiveness and performance, and for continual improvement opportunities in all areas.
Berger Tools Ltd regards the Health, Safety and Welfare of both the Company’s employees and those who may be affected by its activities as being of prime importance. The following statement recognises our obligations under the Health & Safety at Work Act 1974, including all appropriate regulations and approved codes of practice additional to the Act.
Berger Tools Ltd will therefore conduct its activities in a way that ensures that it:
Berger Tools are committed to supporting human rights and we take seriously our responsibilities under the Modern Slavery Act 2015. We have a zero-tolerance approach to slavery and human trafficking and are dedicated to understanding the risks so that we can work towards ensuring that there is no trace of modern slavery in our business or supply chains.
We have reviewed our purchasing and employment practices and will continue to monitor and assess our practices in this area and encourage improvement. Our commitment to social responsibility is reflected in our employee training programmes and company policies. We encourage our employees to report any ethical concerns and emphasise the importance of a healthy company culture and treating each other with respect. We pay above the National Living Wage to all employees.
We choose our suppliers carefully and, where appropriate, carry out due diligence on these parties and endeavour to contractually require them to comply with applicable laws. To our knowledge, our business and supply chains are free of slavery and human trafficking. We would treat any incident of modern slavery as a breach of our company policies, contractual terms and/or law.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking policy.
Berger Tools is an equal opportunity employer and is committed to a policy of treating all its employees and job applicants equally. The Company will avoid unlawful discrimination in all aspects of employment including recruitment and selection, promotion, transfer, opportunities for training, pay and benefits, other terms of employment, discipline, and selection for redundancy and dismissal.
It is the policy of the Company to take all reasonable steps to employ and promote employees on the basis of their abilities and qualifications without regard to age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality and ethnic or national origins), religion or belief, sex or sexual orientation. The Company will appoint, train, develop and promote on the basis of merit and ability alone.
Berger Tools is committed to conducting business in an ethical and honest manner and implementing and enforcing systems that ensure bribery is prevented.
One of Berger Tools’ core values is to uphold sound, responsible and fair business operations. It is committed to promoting and maintaining the highest possible ethical standards in relation to all of its business activities. The Company’s reputation for maintaining lawful business practices is of paramount importance and this policy is designed to preserve these values.
Berger Tools complies with all applicable anti-bribery and corruption laws, including the Bribery Act 2010. We have a zero-tolerance policy towards bribery and corruption and are committed to acting fairly and with integrity in all business dealings and relationships wherever we operate. We implement and enforce effective systems to counter bribery.
Business partners must not offer, promise, give, request or accept any bribe, kickback, facilitation payment, or gifts and hospitality intended to improperly influence a business decision.
Berger Tools Limited has a zero-tolerance policy of tax evasion and the facilitation of tax evasion and this policy is fully endorsed by our senior management. We are fully committed to complying with the Criminal Finances Act 2017 and applicable guidelines designed to prevent tax evasion and the facilitation of tax evasion in the jurisdictions in which we, our clients, our suppliers and our business partners operate.
Berger Tools and its partners are committed to high standards of information security, privacy and transparency. We place a high priority on protecting and managing data in accordance with accepted standards including ISO 27001 and PCI-DSS. The company will comply with applicable UK GDPR and the Data Protection Act 2018.
We only collect and use data necessary for business operations and managing our relationship with employees, customers, suppliers, and business partners. Data is processed fairly, lawfully, and transparently, ensuring accuracy, security, and compliance with all legal obligations.
We maintain strict safeguards to protect your information, train our employees on data protection responsibilities, and only retain personal data for as long as necessary. We may share your information with approved business partners and service providers but always ensure confidentiality and lawful processing.
For full details see our Privacy Policy
For the purposes of the Berger Tools Business Partners Business Code of Conduct “Confidential Information” shall mean any technical and/or commercial information, including but not limited to any documents, drawings, sketches or designs, materials, samples or data disclosed by Berger Tools or its partners.
Our partners undertake to treat this as confidential and to make use of it for no other purpose than the supply of products and/or services to Berger Tools and not to disclose the same directly or indirectly to any third party except with the prior written consent of Berger Tools.
Detailed confidentiality obligations may also be set out in a separate Non Disclosure Agreement (NDA), which shall prevail in case of conflict.
Berger Tools Ltd strives to maintain high ethical standards in all areas of the business. This includes supporting the ending of violence and human rights violations in the mining of minerals from the area known as the “Conflict Region” in the east of the Democratic Republic of Congo (DRC) and surrounding countries.
We require our suppliers to share this commitment and will undertake and maintain ongoing due diligence to ensure that none of the products we supply contain tin, tantalum, tungsten and gold sourced from the “Conflict Region”.
Berger Tools will not purchase products that contain conflict minerals that directly or indirectly finance or benefit armed groups in the DRC or adjoining countries.
Suppliers shall provide, on request, Conflict Minerals Reporting Templates (CMRT) or equivalent evidence supporting responsible sourcing.
In accordance to Regulation (EU) No. 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine as amended from time to time (including measures relating to Article 3g and Annex XVII) the importation of iron and steel products of Chapters 72 and 73 are prohibited if they originate in Russia, or are made of Russian steel.
Berger Tools and its partners, hereby confirm that all goods delivered to Berger Tools neither originate from Russia nor have been exported from Russia.
Furthermore, we confirm that no input material (iron and steel products) originating from Russia have been used in the manufacture of the goods delivered to Berger Tools.
Suppliers shall retain documentary evidence (e.g., mill test certificates, bills of materials, certificates of origin) demonstrating compliance and provide it to Berger Tools on request.
Berger Tools Limited is committed to full compliance with all applicable European Union and United Kingdom chemical, environmental, and product safety legislation.
This declaration sets out Berger Tools Limited’s compliance expectations of its partners in relation to:
REACH Compliance
Berger Tools Limited confirms that it acts as a distributor and downstream user and does not manufacture or import chemical substances under REACH Regulation (EC) No. 1907/2006.
Our partners confirm and warrant that:
Partners warrant that REACH compliance is maintained on an ongoing basis and will promptly notify Berger Tools Limited of any change in SVHC status, regulatory obligations or compliance position affecting supplied products.
RoHS Compliance
Partners certify that all applicable products supplied to Berger Tools Limited comply with the requirements of Directive 2011/65/EU (RoHS Recast), as amended by Commission Delegated Directive (EU) 2015/863 (RoHS 3).
Berger Tools Limited defines “RoHS compliant” to mean that restricted substances referred to in Article 4 of the RoHS Directive are not intentionally added during the manufacturing process; and the concentration of restricted substances in homogeneous materials does not exceed the maximum concentration values specified in Annex II of the Directive.
Where a product relies on an exemption under Annex III or Annex IV of the RoHS Directive, partners confirm that:
Partners shall, upon request, provide RoHS Declarations of Conformity or equivalent technical evidence demonstrating compliance.
Partners shall notify Berger Tools Limited without undue delay of any changes to RoHS compliance status, including the expiry, amendment, or withdrawal of any applicable exemption.
Business Partners shall:
Concerns regarding legal, ethical or compliance matters may be reported confidentially to Hazel Smeeth or directly to senior management. Reports made in good faith will be handled sensitively, investigated appropriately, and will not result in retaliation.
We are proud to support UK manufacturing and are happy to promote the MTC (Manufacturing Technology Centre) and its initiatives to help manufacturers innovate and grow.
ISO Quality Certificate
ISO Environment Certificate
Carbon Offset Certificate
JOSCAR Registration
Company Insurance
PPMA Affiliate Member
MTA Member
Federation of Small Business Member
Certificate of Incorporation
VAT Registration Certificate
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