Following the introduction of the Modern Slavery Act 2015, the Group has adopted a statement, to be reviewed annually, regarding the procedures in place to limit the risk of slavery or human trafficking events occurring within its business and supply chain. This statement sets out Wynnstay’s current approach to understanding the potential risks of such abuses, and the steps in place and to be implemented, to prevent modern slavery or human trafficking events occurring within its own business and associated supply chains. This statement relates to intentions and actions taken during the financial year, and the future development of procedures for identifying risks and preventing abuses.
The Wynnstay Board has committed to preventing modern slavery and human trafficking acts within its corporate activities, and to ensure that its national and international supply chains are free from such abuses. Where possible the organisation prefers to build longstanding relationships with our suppliers, where through a strengthening of trading commitments, we can make clear our expectations of business behaviour. During the year, a review of primary trading partners has been commenced with a view to identifying relationships where a risk may exist. This categorisation approach is intended to allow the Company to prioritise its limited resources initially to any areas of perceived highest threat. Engagement with these suppliers is then planned to ensure that an agreed procurement policy, expressing ethical and supplier codes of conduct, is implemented in addition to any usual commercial contract terms. This process is intended to be rolled out to appropriate supply relationships during 2017.
Our procurement policy is intended to comply with the Modern Slavery Act 2015 and incorporate a risk assessment protocol which identifies and assesses potential risk within that particular supply chain. Appropriate investigative and auditing processes commensurate to the scale of the enterprise and risk, are intended to be executed as necessary. Our staff will be provided with sufficient training enabling them to identify risk and ensure the expectations of the procurement policy and its associated processes are understood at all levels across the Business. All suspected cases of modern slavery and human trafficking are requested to be reported to the Head of Procurement, and any such report will be investigated on a case by case basis, with appropriate remedial action taken immediately. The Board also recognise that concerns about modern slavery are not just limited to the Company’s supply chains, but may also be a risk within the Business’s own employment environment, and particularly with regard to temporary or agency staff use. Therefore a review of such hiring practices was requested during the year, and improvements to employment due diligence processes are expected during 2017.
This statement has been approved by the Company’s Board of Directors, who will review and update it annually.
By order of the Board
30 January 2018