MODERN SLAVERY AND HUMAN TRAFFICKING POLICY STATEMENT
DATE OF CREATION: February 2018
DATE OF REVIEW: February 2018
DATE OF NEXT REVIEW: February 2019
OWNER: Human Resources
This statement sets out Radstock Co-operative Society’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st March 2017 to 28th February 2018.
Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking. The Society has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015. The Society also expects the same high standards from all of its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.
Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, the Society accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.
As part of retail and farming sectors, the Society recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
The Society is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
This statement covers the activities of Radstock Co-operative Society and applies to all individuals working for the Society or on the Society’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.
The Society operates in the retail, property rental and farming sectors with its businesses further categorised as follows:
- The retail estate comprises of a number of convenience stores and a superstore with the majority of its grocery range supplied by The Co-operative Group Limited, a separate independent co-operative based in Manchester, via a joint buying arrangement managed by Federal Retail and Trading Services. The Society supports a number of local suppliers of product and services from cleaning services, maintenance and shop fitting contractors, stationery and security suppliers etc, the majority of which are UK based. Our supply chain of locally produced products and goods operate within our trading areas.
- The farming operation consists of a 1,000 acre dairy farm supplying milk under a national co-op contract.
- The property portfolio consists of a number of commercial and residential properties which the Society rents or leases to business or private clients.
Countries of operation and supply
The Society currently operates within the United Kingdom only with the majority of its activities operating out of the Somerset and Wiltshire areas.
The following is the process by which the Society assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
- We have analysed our supply chains, and although no business or country is immune from the risk of modern slavery, the vast majority of our suppliers are based in the UK.
- The Society’s main supplier to the food retail business is The Co-operative Group Limited which has a robust and rigorous anti-slavery policy consistent with its ethical trading stance as set out its annual Sustainability Report.
The following activities are considered to be at high risk of slavery or human trafficking:
- The use of casual labour at the farm as workers are not contracted or employed directly by the Society. Due to the seasonal nature of the farm’s operation and a requirement for night working during some months, casual labour is considered the most cost effective and efficient method of meeting the staffing requirements in peaks and troughs in farming activities. Much of this labour is supplied by employment agencies who utilise Eastern European workers to meet the demand.
To reduce the risk the Society has audited the recruitment processes of the employment agencies it utilised and is satisfied that they have a robust recruitment policy which includes eligibility to work in the UK checks to safeguard against human trafficking or individuals being forced to work against their will.
Responsibility for the Society's anti-slavery initiatives is as follows:
· Policies: Head of HR and Communications is responsible for putting in place and reviewing policies and will conduct comprehensive research and refer to best practice in the development of such policies. It is the Board of Directors who are ultimately responsible for signing off all Society Policies relating to people.
· Risk assessments: [Explain the process and broad Society responsibility for human rights and modern slavery risk analysis.]
· Investigations/due diligence: The Head of HR and Head of Retail will determine and initiate investigations and due diligence in relation to known or suspected instances of slavery and human trafficking and will recommend suspension or removal from the Society’s supply of products and services for approval by the Chief Executive.
· Training: The Head of HR and Communications is responsible for ensuring that all relevant individuals are trained in the aspects of the Modern Slavery Act 2015 and will ensure delivery by 31st March 2018.
The Society operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
Whistleblowing policy The Society encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Society. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Society's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can raise concerns in confidence to The Society’s Secretary or the Head of Human Resources & Communications.
- The Diversity Policy Statement outlines the Society’s expectations in terms of acceptable actions and behaviours expected of colleagues in terms of treating employees and customers with respect. The Society strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
- Supplier/Procurement code of conduct The Society is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Society plans to meet with all local suppliers to ensure that they meet these standards. However, serious violations of the Society’s supplier code of conduct will lead to the termination of the business relationship.
- Recruitment/Agency workers policy The Society has a robust recruitment policy and procedure which includes eligibility to work in the UK checks and explores other personal circumstances in an endeavour to safeguard against human trafficking. The Society, when appropriate, uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
The Society undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Society's due diligence and reviews include:
- mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
- evaluating the modern slavery and human trafficking risks of each new supplier;
- reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
- invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct.
The Society has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the Society is:
· requiring supply chain managers/HR professionals to have completed training on modern slavery by 31 March 2018.
· developing a system for supply chain verification expected to be in place by 30th April, whereby the Society evaluates potential suppliers before they enter the supply chain; and
- reviewing its existing supply chains expected to be completed by 30th April 2018, whereby the Society evaluates all existing suppliers.
The Society requires supply chain managers/HR professionals within the Society to complete training on modern slavery.
The Society's modern slavery training will cover:
· our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
· how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- how to identify the signs of slavery and human trafficking;
- what initial steps should be taken if slavery or human trafficking is suspected;
- how to escalate potential slavery or human trafficking issues to the relevant parties within the Society;
- what steps the Society should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Society's supply chains.
As well as training staff, the Society has formulated a raised awareness of modern slavery issues by distributing flyers to staff/putting up posters across the Society's premises/circulating a series of emails to staff.
The flyers/posters/emails explain to staff:
- the basic principles of the Modern Slavery Act 2015;
- how employers can identify and prevent slavery and human trafficking;
- what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Society; and
- what external help is available, for example through the Modern Slavery Helpline.
This statement has been approved by the Society's board of directors who will review and update it annually.
Director's name: Jeremy Fricker
Date: February 2018