ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ Global Inc. Modern Slavery Act Statement 2019-2020
This statement is made by the parent of the ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ Group, ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ Global Inc, on behalf of its subsidiary, ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ Publications Limited (ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼) which does business in the United Kingdom. Pursuant to s. 54 of the Modern Slavery Act 2015, we set out the steps that ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ takes to ensure as far as possible that modern slavery and human trafficking is not taking place within our business or supply chain.
Policies
ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ does not tolerate any form of modern slavery and is committed to acting in an ethical manner, with integrity and transparency in all business dealings.
We are committed to creating effective systems with controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. Our relevant company policies include:
- Ethical policy: used universally by ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼, its employees and partners. ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ will only engage with partners that are fully compliant with the 10 Key Values set out in the Ethical Policy;
- Recruitment policies;
- Anti-bribery policy;
- Whistleblowing policies;
- Supplier code of conduct;
- Editorial Principles.
Suppliers
Our supply chain provides for:
- The production of printed materials;
- Digital platforms;
- App development and hosting;
- Freight & shipping partners;
- Warehousing; and
- Goods and services procurement.
Due Diligence
ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier using he SMETA social audit procedure, or other equivalent reports, which is widely used and respected by responsible organisations.
Due diligence includes regular interviews with partners, annual independent audits and visits to factories not located in low risk territories. We consider our lower risk territories to be EU Countries, Switzerland, Norway, USA, Canada, Australia, New Zealand and Japan. This programme is overseen by our Supply Chain Manager and consists of the following principles:
- Supplier factories must be approved before our products can be manufactured;
- ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ will, where possible, work with those supplier factories to help with the process of implementing appropriate and workable measures for raising standards to meet our ethical code within an agreed period; and
- Where suppliers are not willing to comply with ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼’s ethical programme, or are found to conceal their non-compliance, ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ will immediately terminate any contract and associated sub-contracts.
It is a contractual condition that all direct partners observe the provisions set out in the Ethical Policy and obtain similar compliance from their own partners.
ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ continues to work with initiatives such as the Ethical Trading Initiative and SEDEX to improve our understanding of the risks of modern slavery and how to effectively manage these risks.
Performance indicators
We monitor the effectiveness of the steps that we are taking to ensure that slavery and human trafficking is not taking place within our business or supply chain, by:
- Monitor labour payroll systems;
- Ensuring that employees, the public, and law enforcement agencies are able to contact us in order to report any modern slavery issues or practices;
- On-going independent auditing and site visits; and
- Monitoring the level of communication and personal contact with next link in supply chain.
Looking ahead…
ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ recognises that there are always improvements that can be made to the way we work and regularly review our policies and procedures. We will continue to build on our ethical programme to ensure that modern slavery and human trafficking is not taking place within our business or supply chain.
This statement has been approved by
Name: Theodore Sathananthan
Position: Group Director and Chief Operating Officer
on behalf of the ÀÏ°ÄÃÅÁùºÏ²Ê¿ª½±¼Ç¼ Group
Date: 5th February, 2020