Slavery and human trafficking statement

This is the Company’s inaugural Slavery and Human Trafficking Statement (“Statement”) made pursuant to Section 54 of the Modern Slavery Act 2015 ‘Transparency in Supply Chains’ (“Act”). 

The Act introduced a number of measures to combat slavery and human trafficking and improve the transparency of reporting on modern slavery, including a requirement on companies with an annual turnover of at least £36m to report annually on its workforce and supply chain, and specifically to confirm that workers are not enslaved or trafficked. 

This Statement relates to the Company and its subsidiaries and is made in respect of its financial year ended 31st January 2017. It sets out the steps the Company has taken, and is proposing to take, to address the risk of slavery and human trafficking taking place in our business and within our supply chain. For the purposes of this Statement, the Company’s joint venture arrangements (where we are responsible for those operations and arrangements) are treated as being part of our supply chain. 


Our position on Human Rights 

The Company and its subsidiaries are committed to zero tolerance in regard to human trafficking and slavery.

Everyone working for the Company must follow ethical business practices, be reliable, trustworthy and honest, and have a fair-minded approach. Similarly, all employees have an important role to play in the management of risk and this includes being alert to the risk of slavery, forced labour and human trafficking in our business and in the wider supply chain. 

The Company recognises and safeguards the human rights of all citizens in the business areas in which we operate. We support the principles set out within both the UN Universal Declaration of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. This Policy includes, without limitation, the principles of equal opportunities, collective bargaining, freedom of association and protection from forced or child labour. The Policy embraces the specific requirements of the Act.  The Company operates a robust recruitment programme. We also have in place a range of supporting employment policies, processes, procedures and guidelines which reflect current legislation and best practice and which are targeted at safeguarding the interests of employees and potential employees and other people who work for our business. External advice and training on the identification, understanding and response to the risk of slavery and human trafficking in business will be provided to certain members of the Company. 

We believe that the risk of any slavery or human trafficking in the employment or engagement of our own employees is low. Additionally, we are committed to ensuring that any concerns which employees may have, whether in connection with the organisation or the supply chain, can be reported and will be investigated by the Company and any appropriate third parties. 

Our policy is to source goods and services efficiently and fairly. The method of procuring goods and services complies with legislation, including health and safety regulations, and conforms to the Company’s ethical, environmental and sustainability standards

We are committed to maintaining a diverse supply chain ranging from large conglomerates through to smaller companies and providers of goods and services.  The Company strives to develop long-term partnerships with suppliers whose policies, values and cultures are in keeping with our own. 

We set and expect high standards and work with our suppliers to ensure they understand our requirements and can deliver against them on an ongoing basis.  The Company also reserves a right to carry out periodic compliance audits and/or request additional information and evidence in respect of a wide range of matters. This process and these rights will be extended to cover compliance with the Act (where applicable) and the standards we have set in relation to the risk management of anti-slavery and human trafficking in the supply chain. 

In accordance with the findings of the Global Slavery Index 2016 (“GSI 2016”), where migrant labour is used in the UK or local labour is used in the overseas production of materials, there is a varied level of risk of slavery and human trafficking dependent on the country of origin of the individual or the materials purchased. This is an important area where, from time to time, we may need to seek assurances in advance from our suppliers.  This is due to the inherent nature of the work to be performed by such suppliers and diversity of the labour force employed to carry out these activities. Again, as per the GSI 2016, some migrant workers may be at risk of slavery or human trafficking, with the level of risk dependent on the individual’s country of origin. It is also due to the fact that such suppliers may not be subject to the Act and/or their procurement and employment policies and procedures may fall short of our own high standards and best practice. 



Our ‘continuous improvement’ approach 

We are confident in our management and assessment of the low risk exposure to slavery and human trafficking existing in our operations and with our employees. We are confident that our ongoing engagement with suppliers, coupled with the application of the Company’s existing internal control and risk management systems are capable of ensuring our ongoing compliance with the Act.