Wincanton and Pullman is committed to the highest possible ethical standards and corporate conduct and we expect our suppliers to adhere to these same standards. The Group requires companies across our extended supply chain to understand and meet our expectations on anti-bribery, corruption, legal compliance and ethical conduct.
To this end, the following statement is offered in compliance with the Modern Slavery Act 2015 and sets out the Group’s approach to the prohibition of any form of forced labour or slavery within our supply chain.
Once the law came into effect in 2015, Wincanton carefully reviewed its employment and procurement practices to ensure they were in line with the new legal requirements. The Group laid down four strategic measures that the Company had taken or was in the process of taking to meet the requirements of the new law, specifically:
produce and communicate a Modern Slavery Strategy Statement and Policy;
carry out a compliance assessment of current suppliers;
embed additional due diligence into our procurement activities; and
review our Group-wide employment practices and processes, including the use of agencies.
Following on from the activities set out in our statement last year, there has been continued progress and activities to deliver the four strategic steps during the year ended 31 March 2018 as set out below:
Strategy statement and policy During the year ended 31 March 2018 the Group’s HR function, in conjunction with our external legal advisers, have reviewed the Statement and Policy and related policies to ensure they remain compliant and fit for purpose. They have also continued to oversee, communicate and provide training on the Group’s expectations and responsibilities of employees.
Assessment of current suppliers During the year, the Group completed an assessment of its current suppliers by size and risk, and all suppliers were sent a letter setting out the Group’s requirements for their compliance with the legislation. Those suppliers identified as being of highest risk were also requested to provide details of their strategy and approach to compliance with the legislation. Responses from these suppliers were reviewed and a continued assessment of suppliers is being undertaken.
Procurement due diligence This year saw the launch of the Supplier Code, designed to drive higher ethical standards, above and beyond compliance requirements as Wincanton have chosen to apply the standard to all suppliers regardless of size. All suppliers must comply with the Supplier Code in order to provide goods and services to the Company, and it is now a standard part of Wincanton’s supply contracts and terms of purchase (as issued on all purchase orders). The Supplier Code can be downloaded on the Group’s website. In addition, the Procurement function continues to incorporate due diligence into its pre-qualification process, when tendering and procuring new suppliers and undertaking renewals of all types and sizes. Supply areas identified as specifically high risk are continually assessed with suppliers asked to provide details of their policies to ensure compliance with the legislation.
Employment practices The Group’s employment practices and processes have been thoroughly reviewed and updated where necessary with the support of external legal advice. These updated policies and practices have been communicated and cascaded throughout the Group. The designated HR teams have also provided localised training and support to all Group employees. In addition, the Group HR function is currently working on an enhanced Code of Conduct that will summarise all of the Company’s key policies and standards with the intention of delivering a Group-wide roll out of the new Code in 2018. The Group has also started a project to consider the specific risks associated with the use of agencies and new standards in this area have been agreed. Further revisions to the Group’s employment policies and practices are underway and the work will be completed and rolled out throughout the Group and its network of agency suppliers in 2018. The delivery of these four strategic measures is a core component of the ongoing legal compliance of our practices and processes. These measures are also underpinned by the Group’s established processes for corporate governance. The Group reviews its policies and process at least annually, to ensure they remain relevant, up-to-date and compliant with prevailing legislation. Moreover, all of our policies and procedures are designed to recognise and further elevate the importance of the highest behavioural standards and ethical conduct for all of our stakeholders, as a reflection of the Group’s values and the prominence of social responsibility within our business and our extended supply chain.
In common with all other regulatory and legal requirements, as a Group, we expect and are prepared for the fact that the nature, root causes and circumstances that cause instances of modern slavery and human trafficking will change over time. The Group will continue to be vigilant and proactive in this area and will closely monitor and regularly review the four strategic measures and any influencing factors, to ensure our Group policies and practices remain fit for purpose and address any new risks that may emerge.
The Directors approved the above statement on 16 May 2018.
Raj Sharma Group Legal Director & Company Secretary Wincanton plc Registered in England and Wales No. 4178808