OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Procurement Policy and Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
The policy has been built around and adopts elements of the of Ethical Trade Initiative (ETI) Base Code as a means of evaluating suppliers and contractors who may be considered high risk in terms of modern day slavery and selected sections of the Ten principles of the United Nations Global Compact.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we have established an industry based risk matrix, developed an assessment tool, mapped our first tier supply chain, identified those suppliers who accounted for 90% of our total spend along with those identified as operating in High Risk Industries.
This process identified number of suppliers who have been or will be over the next 12 months assessed against the Procurement Policy criteria to ensure that these principles are upheld.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our ethics we have in place a Compliance team, which consists of from the following departments who will be responsible for developing and implementing policies, assessments and remediation with non-conforming suppliers.
The compliance team will be led by the Head of Purchasing & Contracts and the Head of Human Resources.
TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff with key procurement personnel undertaking an independent and certified (Chartered Institute of Purchasing) yearly assessment on Ethical Procurement.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We will use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
- Number of Supplier Assessments completed
- Number of Assessment Non Compliance Notices issued
- Number of Ethical Procurement certificates obtained in the year
Following a review of the effectiveness of the steps we have taken [this year] to ensure that here is no slavery or human trafficking in our supply chains we intend to extend the scope of the assessment to those suppliers outside the top 90% and those who are in the second tier of our supply chain.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31st December 2018.
