Modern Slavery Policy
Business Organisation, Structure And Supply Chain
The Stannah Group operates internationally across supply chain, manufacturing and sales distribution. We directly employ a large number of people internationally and maintain relationships with many different organisations.
We are committed to acting ethically and with integrity in all our business dealings. We sum up this approach with the words ‘We take care’. This is the essence of our brand – our central organising principle and we use it to guide everything that we do.
We are committed to opposing modern slavery in all its forms and we expect the same attitude from all other organisations with which we do business.
The Group realises that slavery and human trafficking can occur in many forms, such as forced labour, child labour, domestic servitude, sex trafficking and workplace abuse.
We will ensure that everyone in our business and our business partners know our behavioural standards. We will avoid doing business with those who do not accept our values and who may contravene our policy.
This policy supplements other existing policies and documents to provide guidance and transparency for all employees. These include (but are not limited to):
- Ethical behaviour policy
- Sustainability and environmental policies
- UK Bribery Act policy
- CIPS Code of Conduct for Purchasing Professionals
- Public Disclosure (whistle blowing) policy
The Group Directors and Senior Management have the responsibility for implementing this policy and its objectives and will allocate resources (people, training, time) as required.
We will regularly review, report on and update this policy.
Risk Assessment And Due Diligence
We recognise modern slavery can happen anywhere, which is why we will provide all budget holders and financial decision makers with awareness training.
However, we recognise our extended supply chains present the greatest levels of risk.
Our ethical approach to business infers that we prefer to source as locally as possible.However, we recognise our supply chains are inevitably international by nature and can therefore be challenging to manage.
We invest in relationship management throughout the Group so that we can foster long-term relationships with suppliers and contractors to understand their business, regularly visiting and reviewing key suppliers and mitigating risks where appropriate.
During 2017, we will amend all relevant documentation (including supplier/contractor contracts and general purchasing terms and conditions) to include clauses pertaining to modern slavery and risk factors.
We regularly train relevant employees in ethical business policies, corporate social responsibility and the UK Bribery Act and include whistleblowing policies and procedures. During 2017, we will incorporate modern slavery awareness training into our regular ethical business training programme for all employees.
We train all purchasing professionals to the Chartered Institute of Purchasing and Supply qualification and during 2017, we will add a detailed training module to cover aspects of modern slavery not covered by the above for relevant employees and business leaders.
The Group has reviewed its key performance indicators in light of the introduction of the Modern Slavery Act 2015. As a result, we will ensure that:
- All purchasing professionals and business leaders will receive detailed modern slavery training in February 2017.
- All budget holders and financial decision makers will receive modern slavery awareness training in February 2017.
- All suppliers have bought into our revised policies by February 2017.
- We have amended our standard contracting Terms and Conditions by February
- We have amended other relevant business processes and documentation to account for the requirements of the Modern Slavery Act by January 2017.
- We continue to report the outcomes of supplier visits to business leaders and will continue to act on any resulting actions
Group Managing Director