Company Policies

Privacy Policy   Anti-Bribery Policy   Ethical Procurement Policy   Conflict Minerals Statement  

Environmental Policy


Modern Slavery Statement



Privacy Statement

This policy has been developed to allow you to feel confident about the privacy and security of your personal information.

Use of personal information

Because the Elcometer Website is constantly being updated, with new products and information, we want to help you keep informed about the latest developments as soon as they are available. So you do not have to constantly monitor our website in order to keep up we encourage you to register for the Elcometer e-zine so that we can give you quicker and better access to your favourite products and services.

You don't need to register to access any of the Elcometer website

When you register or contact Elcometer via the Contact Form, any details you provide will be stored for use on our secure mainframe at our Head Office in the UK. If you register for the Elcometer e-zine, we will treat you as having consented to our using your personal data in the manner described in this Policy. If you do not register, the personal data we collect from you will be limited to that which you give us in order to contact Elcometer or our Distributors.

Email addresses

Elcometer respect the privacy of personal e-mail accounts and we store your e-mail addresses as secure as other personal information on the Elcometer Mainframe. We will not send you unwanted e-mail messages or junk mail, and your details will not be passed to ANY organisation outside Elcometer or the Distributor in, or closest to your company address, without your explicit permission.

However, we will use e-mail to send you technical information, new product bulletins and any information that we feel will be beneficial to you, as well as anything you show an interest in, either online, or through other contact with Elcometer. If you do not want to be kept informed in this way by e-mail, please let us know. You can do this by sending an e-mail to, writing the words unsubscribe in the description field of your e-mail.

Disclosure of information

Elcometer Limited complies with and is registered under the data protection laws in the United Kingdom and we take all reasonable care to prevent any unauthorised disclosure or access to your personal data. We may share your personal information with any member of the Elcometer Group and Elcometer Distributors.

Third party sites

Third party Internet sites connected to through are not covered by our Privacy and Security policy, so please be careful when you enter any personal information online. Elcometer accepts no responsibility or liability for these sites. Please remember that if you change your e-mail provider, you will also need to inform Elcometer of the change in your e-mail address in order to continue receiving e-mail correspondence.

If you have any additional questions please contact Elcometer at the Elcometer Head Office in the UK



Anti-Bribery Policy


This policy sets out the responsibility of Elcometer Ltd as a corporate entity (including all subsidiary businesses wherever located), and all employees of Elcometer and its subsidiaries (hereafter referred to as the “Group”) in observing and upholding the Group’s position on bribery and corruption.

It also provides information and guidance to all employees of the Group on how to recognise and deal with bribery and corruption issues.

Policy Statement

It is the Group’s policy to conduct all business in an honest and ethical manner. A zero-tolerance approach to bribery and corruption is taken by the Group and it is committed to acting professionally, fairly and with integrity in all dealings wherever it operates. The Group is committed to implementing and enforcing effective systems to counter bribery.


The Bribery Act 2010 became part of UK law on 1st July 2011.

Bribery is now punishable for both individuals (up to ten years’ imprisonment and unlimited fines) and corporate entities (unlimited fines). In addition, it is now an offence for corporate entities to fail to prevent bribery.

This applies to all UK businesses and any other business, wherever registered, if it carries on any business in the UK or is managed by people with a UK connection. As such this applies as much to Elcometer Ltd’s overseas subsidiaries as it does to the UK business.

Who is covered by the policy?

This policy applies to all employees (whether permanent, fixed-term or temporary), consultants, contractors, agency staff or any other person providing services to the Group (collectively referred to as “workers” hereafter).

What is bribery?

A bribe is a financial or other advantage offered or given to a person in order to gain a commercial, contractual or personal advantage. (For the avoidance of doubt, this does not include discounting of product).

Under the Bribery Act 2010, it is an offence to bribe another or to receive a bribe. In addition, however, no money needs to have changed hands for people to be caught under the Act – a person can be guilty of an offence if they offer/promise to pay or request/agree to receive a financial or other advantage.

Gifts and Hospitality

The Group will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence any commercial or public official in the performance of their duties. The Group will not make contributions of any kind to political parties and no charitable donations will be made for the purpose of gaining any commercial advantage.

This policy does not prohibit the giving and receiving of promotional gifts of low value and normal and appropriate hospitality. As stated in the Elcometer Ltd Staff Handbook however, the offer of gifts or entertainment in excess of ?50 must not be accepted without the prior approval of a Director.

Gifts or hospitality given or received must be reasonable and justifiable. The following points are intended as guidelines in this respect:

  • Gifts or hospitality are not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
  • it is not an unlawful gift;
  • it is given in the name of the business and not in an individuals name;
  • it does not include cash or a cash equivalent (such as gift certificates or vouchers);
  • it is appropriate in the circumstances (for example, small gifts given at Christmas time);
  • taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time;
  • it is given openly, not secretly.


The Group will keep financial records and have appropriate internal controls in place which will evidence the business reason for making any payments to third parties.

Workers must ensure all expense claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with the expenses policy in force at each business and must specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties such as customers, suppliers and business contacts must be prepared and maintained with strict accuracy and completeness.  No accounts must be kept "off-book" to facilitate or conceal improper payments.

Workers responsibilities

All workers must ensure that they read, understand and comply with this policy at all times.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Group or under the Group’s control.  All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.

Raising Concerns

Workers are encouraged to raise concerns to a Company Director about any issue or suspicion of malpractice at the earliest possible stage.

No worker will suffer any detrimental treatment as a result of either refusing to take part in bribery or as a result of raising genuine concerns about bribery, even if these turn out to be mistaken. (Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern).


The Board of Directors has overall responsibility for ensuring the effectiveness of this policy.

Internal control systems and procedures will be subject to regular audits to provide assurance that these are effective in countering bribery.

All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.



Ethical Procurement Policy

As an international organisation, Elcometer Limited sources products and components from around the Globe. Our environmental and anti-bribery policies clearly state our position on these two very important issues and go some way to set out our position on how we conduct our business in a sustainable and ethical way.

This Ethical Procurement Policy has been written to further describe how we conduct business with our suppliers, together with the expectations that we have of our suppliers regarding the way that they conduct their business and applies to all Elcometer's purchases of goods and services.

Our aim is to ensure that the whole of our supply chain conforms to our ethical procurement standards.

As a leading supplier of inspection equipment, we understand that our reputation does not simply rest with the quality and service we offer to our customers. We have a duty to ensure that we strive to maintain the highest standards of ethical conduct and corporate responsibility worldwide and seek to influence our suppliers to operate to similar high standards as ourselves.

We support the principles set out within the United Nations Universal Declaration of Human Rights and the principles set out in the Dodd Frank Wall Street Reform and Consumer Protection Act, Section 1502 with regards to the use of conflict minerals.

Elcometer will:

  • expect all our employees to adhere to our environmental, anti-bribery and ethical procurement policies;
  • pay suppliers in accordance with the agreed terms and deal with exceptions in a timely manner;
  • ensure that we will not knowingly purchase product(s) which contain metals derived from minerals defined as 'Conflict Minerals.' Conflict Minerals include columbite-tantalite (coltan, niobium and tantalum), cassiterite (tin), gold, wolframite (tungsten), their derivatives or other minerals determined by International Governments to be financing conflict.
  • ensure an ethical basis to business practice;
  • select and treat our suppliers fairly and objectively at all times;
  • seek to ensure that our environmental, anti-bribery and ethical procurement policies are considered in our supplier appraisal process.

We expect our suppliers to:

  • conduct business without the payment or receipt of inducements, unlawful incentives or other benefits that might be considered an attempt to influence decision makers;
  • respect fundamental human rights;
  • treat employees fairly, never abuse or threaten them and never use forced, bonded or child labour;
  • maintain a safe working environment at all times and provide access to protective equipment and safety training for all employees;
  • confirm they understand and respect our environmental, anti-bribery and ethical procurement policies;
  • maintain effective policies, processes and procedures to manage their environmental impact and to operate their business in a sustainable way;
  • ensure that they do not purchase products which contain metals derived from conflict minerals;
  • comply with all applicable local, national, regional and international laws, regulations and directives at all times; and
  • respect the intellectual property rights of others.


The Board of Directors has overall responsibility for ensuring the effectiveness of this policy.

All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.



Conflict Minerals Statement

The U.S. Securities and Exchange Commission (SEC) has imposed obligations relating to conflict minerals under the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010, brought into effect in January 2013. US Congress has the sense that the exploitation and trade of conflict minerals in the Democratic Republic of the Congo (DRC) is helping to finance conflict characterised by extreme levels of violence.

The Act defines conflict minerals as cassiterite (tin), coltan (tantalum), wolframite (tungsten) and gold, or derivatives of these minerals. Sometimes these minerals are referred to as the ‘three Ts’ - tin, tantalum and tungsten (and gold).

Elcometer Limited supports ending the violence and human rights violations in the mining of minerals from the ‘Conflict Region’ and is working with its customers and suppliers to ensure compliance with these requirements.

We support the aims and objectives of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010 and ask our suppliers to undertake reasonable control with their supply chains. Our due diligence process requires suppliers to provide a written declaration on use of conflict materials and operate in accordance with the Conflict-Free Smelter (CFS) Program.

Elcometer will not knowingly procure specified materials that are not certified as ‘conflict-free’. In the event that suppliers are not following these guidelines Elcometer will act to resolve this and transition products to be ‘conflict free’.


Conflict Minerals Statement



Environment Policy

Protection of our environment is an integral part of Elcometer’s activities.  We take a responsible approach to environmental management throughout our Company, with our Board of Directors being responsible for our environmental performance.

We are committed to the achievement of the expectations of our customers and stakeholders through the alignment of our environmental objectives to our programme of continuous improvement in order to reduce our total impact on the environment.

  • All relevant compliance obligation requirements are met
  • Environmental performance is monitored and reviewed on a regular basis
  • Any emissions to air, releases to water, energy usage or disposal of solid waste to landfill does not cause unacceptable environmental effects
  • Our business is conducted in a way that respects our neighbours



Elcometer ISO14001 Certificate



Modern Slavery and Human Trafficking Statement


This statement sets out Elcometer Limited's actions to understand all potential modern slavery risks related to its business (in pursuant to s.54 of the Modern Slavery Act 2015). It puts in place steps that are aimed at ensuring that there is no slavery or human trafficking across Elcometer’s business or its wider supply chain.

This statement relates to actions and activities during the financial year ending 31 March 2017.

As part of the coatings, concrete and ultrasonic NDT industrial sector, Elcometer recognises that it has a responsibility to take a robust approach to slavery and human trafficking

Elcometer is absolutely committed to preventing slavery and human trafficking in all of its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Countries of operation and supply

Elcometer is a world leader in the design, manufacture and supply of inspection equipment to the coatings, concrete, metal detection and ultrasonic NDT industries. Ever since the first Elcometer gauge was manufactured in 1947, our philosophy has been to provide industry leading, innovative, high quality products; supported by a best-in-class customer experience at a competitive price. By concentrating on these core values, Elcometer has grown into a global network with representation worldwide.

Our headquarters and manufacturing operation is based in Manchester UK. In addition to our UK headquarters, we have direct sales, support and repair facilities in Belgium, France, Germany, Japan, Singapore, The Netherlands, The UAE and USA, together with a global distribution network with representation in approximately 170 countries. We work with approximately 950 suppliers with the majority based in the UK.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Ethical Procurement policy: this policy sets out our approach to conducting business with our suppliers together with the expectations that we have of our suppliers regarding the way that they conduct their business and applies to all Elcometer’s purchases of goods and services.

2. Recruitment policy: we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

3. Open door policy: we operate an open-door policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals

4. Our company values: these values are core to our business and explain the manner in which we behave as an organisation and how we expect our employees and suppliers to act. These hold employees accountable for their actions and require them to act in an ethical manner

5. Supplier assessments: we operate a supplier selection and appraisal programme and maintain an approved supplier list.  We conduct due diligence on suppliers before granting them a preferred supplier status.  This due diligence includes an online search to ensure that the particular organisation has never been convicted of offenses relating to modern slavery and may include on-site audits dependent on risk associated with the nature of supply and supplier location


Responsibility for Elcometer’s anti-slavery initiatives is as follows:

  • Policies: All company policies are developed by Elcometer’s Management Team and approved by the Board of Directors. Policies are audited and reviewed in line with our ISO 9001 procedures.
  • Risk assessments, investigations/due diligence: All relevant assessments are made by the appropriate departmental head, including those in relation to human rights and modern slavery. Any concerns are raised with the Board of Directors.
  • Training: Our procurement team has received training so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain

Due diligence

Elcometer undertakes due diligence during supplier selection and periodic reviews of our existing suppliers. Our processes include:

  • A robust and proportional approach to supplier assessment, considering the nature of the supply into our business and the associated risks;
  • Evaluating the modern slavery and human trafficking risks of our suppliers of products, using information from the Global Slavery Index to identify higher risk industries and countries of supply;
  • Conducting supplier audits and assessments to include Modern Slavery

Any supplier who fails to meet our performance evaluations will be removed as a preferred supplier and we will terminate our business relationship with the supplier until such time as they can provide proof that they adhere to our policies and requirements as listed above.

Performance indicators

Elcometer communicates with our supply chain to ensure that they are in compliance with our policies and to ensure that slavery and/or human trafficking is not taking place within our business or supply chain. Any reports received from the public, employees or law enforcement agencies which indicate that modern slavery practices have been identified will also be acted upon in the appropriate manner.

Awareness-raising programme

Elcometer has raised awareness of modern slavery issues by putting up posters across our premises, circulating this policy via email to all employees and advising staff how they can report any potential issues with regards to slavery and human trafficking.