Modern Slavery Statement
We do not tolerate slavery or human trafficking in any part of our business and are committed to ensuring that it does not take place in our supply chains.
Slavery and Human Trafficking Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.
Our Policy on Slavery and Human Trafficking
Our anti-slavery policy reflects our aim to act transparently, respectfully and with integrity in all our business relationships. We do not tolerate slavery or human trafficking in any part of our business and are committed to ensuring that it does not take place in our supply chains. We implement and enforce effective systems and controls to mitigate this risk.
Our Supply Chains
We have reviewed our purchases to understand the nature of our suppliers. These include multinational and national suppliers, providing a wide range of goods and services to help us deliver our products.
Risk Assessment and Due Diligence Processes for Slavery and Human Trafficking
We have in place systems to mitigate the risk of slavery and human trafficking occurring in our supply chains, allowing us to assess, identify, address and monitor risk areas. We assess the risk of slavery or human trafficking occurring in our supply chains and apply enhanced checks where higher-risk areas are identified.
Existing supply chain
As part of our risk management process, we asked all heads of department to carry out a risk assessment to consider any existing or future arrangements with third parties. This included identification of:
We assessed the responses and identified risk areas so that we could review those relationships in more detail. Our legal team are working with relevant heads of department to consider each situation individually. This is an ongoing exercise.
We will carry out risk assessments for new suppliers to consider the likelihood of maltreatment of staff or other unsatisfactory factors. This may mean that we decide not to work with them or seek further information, or assurances, before proceeding. For new suppliers where a higher risk is identified:
Supplier Adherence to Our Policy
To ensure all those in our supply chain and contractors comply with our policy, we have in place a supply chain compliance programme. This consists of contractual warranties in our agreements with suppliers, site visits (where deemed appropriate and practically possible) and regular audits to check compliance with our policies and procedures. Representatives from our Compliance Department support and uphold the programme.
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 updates to our staff via our intranet and internal newsletters/briefings and by providing both written and oral reminders of good practice.
Changes to this statement
If we modify this statement, we will post the revised statement here, with an updated revision date. If we make significant changes to the statement that materially alter our practices, we may also notify you by other means, such as sending an email or posting a notice on our corporate website and/or social media pages prior to the changes taking effect. This policy was last updated on 29th July 2021.