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Modern Slavery

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Modern Slavery

We comply with all relevant legislation relating to colleague terms and conditions. We are an equal opportunities employer and offer salaries above the National Living Wage, quality linked incentive schemes and annual bonuses, which are regularly reviewed by our Reward team to ensure they remain competitive. We promote good working practices and conditions as well as the general wellbeing of our colleagues through a number of initiatives. We also focus on the development of our colleagues through a combination of internal training, development and mentoring programmes, external training programmes, apprenticeships and sponsorship of professional qualifications.Working with our suppliers

We require all of our contractors and suppliers, most of whom are UK or EU-based, to work to the same high standards that we apply to our own business. We carry out due diligence on all new suppliers and require our existing suppliers to complete self-assessment questionnaires annually. We also have a supply chain oversight programme which monitors our suppliers’ compliance with their obligations.

As noted in our second modern slavery statement, in 2018 we carried out a risk assessment of our key existing direct suppliers and categorised them as posing a high, medium or low risk of modern slavery taking place in their business. The results of this assessment have now been validated and, in response, we have sought to amend contracts with existing suppliers where appropriate to incorporate robust anti-slavery provisions. We also include such provisions, as a matter of course, into our contractual arrangements with new suppliers.

We will continue to review, update and improve our procurement processes, including our risk assessment, due diligence and oversight of our suppliers in the next twelve months.

Our policies

We have a number of policies in place, which support our anti-slavery work, including our procurement policy, speak up policy (which is our whistleblowing policy), equal opportunities policy, recruitment policy, anti-bribery policy and corporate social responsibility policy.

In particular, our speak-up policy encourages colleagues to report any concerns about malpractice or wrongdoing. We also work with an independent third party provider to provide colleagues with an additional option to raise potential issues and to ensure that they feel able to do so on anonymous basis. We are committed to the highest possible standards of openness, probity and accountability and we expect our colleagues and others that we deal with, who have serious concerns to come forward and voice those concerns.

Objectives and key performance indicators

Our objectives for the next 12 months are to:

maintain and update, as appropriate, our supplier risk assessment procedures to improve our ability to identify and assess potential areas of risk, particularly in relation to modern slavery, in our supply chains
review and update our supplier oversight programme to ensure that an appropriate level of monitoring is applied to our suppliers depending on the level of risk that they pose
continue to incorporate appropriate anti-slavery provisions into our contracts with our suppliers (old and new alike) and
identify any additional training needs for procurement and HR colleagues.
Given the nature of our objectives, we do not believe that it is appropriate at this time to set key performance indicators in respect of our ongoing work in relation to modern slavery. This will be kept under review and we may adopt key performance indicators in the future.

This slavery and human trafficking statement for the financial year ending 31st December 2018 has been approved for and on behalf of all of the companies named at the beginning of this statement.