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Modern slavery statement

We are publishing this statement in accordance with the UK Modern Slavery Act 2015 to detail actions we have taken during the financial year to ensure that modern slavery is not taking place in our operations. 

We continue to take our social responsibilities seriously and have introduced various practices and initiatives during the year intended to combat slavery and human trafficking in our business or supply chain, including:

  • Policies and procedures: this is the primary document outlining how our employees should operate to ensure respect for human rights and labour rights across the business.
  • Workshop: we held a cross functional workshop, with senior management participation across our UK trading entities and operations, to build awareness and achieve a better understanding of the potential modern slavery risks throughout the business.
  • Directly Employed Workforce: we analysed the risk of modern slavery in our directly employed workforce. We consider this to be low because (i) the majority of our employees are employed on permanent contracts; (ii) geography of our operations; (iii) type of work carried out; and (iv) the type of labour being used. Importantly we also have established pre-screening practices and our employees undertake work in a controlled environment with established policies and procedures in place.
  • Risk Mapping: we have mapped out the supply chain for all UK trading entities and operations and consider the risk to be low based on (i) where our suppliers are based; (ii) the products and services being supplied and (iii) our volume of spend. The vast majority of the suppliers assessed are based in the UK and/or are operating in low risk industries.

During the next phase of our compliance programme we intend to take the following steps:

  • International Workshops: we intend to work with our international businesses to identify and mitigate against modern slavery risks.
  • International Risk Mapping: we intend to roll out risk mapping of suppliers across all of our international subsidiaries and operating divisions in order to assess the risk of modern slavery throughout the entire business.
  • High Risk Suppliers: we intend to consider proportionate next steps in connection with those suppliers that we have identified as high risk, in order to further detect and mitigate modern slavery risks.
  • Continuous Monitoring: we intend to continuously monitor and re-evaluate assessment results.

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