MODERN SLAVERY STATEMENT

Transcription

1 MODERN SLAVERY STATEMENT Communisis plc is committed to conducting business responsibly. We also seek to ensure that our supply chains operate to those same high standards, including in relation to employment practices, workplace conditions and, more specifically, the prevention of forced, bonded and trafficked labour. This is upheld through the company s policies and processes, and is supported by the Executive Board. This statement has been published in accordance with Section 54 of the Modern Slavery Act It sets out the steps taken by Communisis plc and its subsidiaries during year ending 31 December 2016 to taken as we seek to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. OUR BUSINESS Communisis plc is a provider of marketing and communication services across UK, Europe and the Middle East. Our clients are large national, multi-national or global business based across a number of industry sectors, including Retail, FMCG, Pharmaceuticals, Telecommunications, Banking, Insurance and Utilities. We service our client requirements through business operations employing 2100 people across 16 countries - across the UK, Europe and the Middle East and using supply chains in those same locations plus also in North America and the Far East. This statement covers all of these operations. As a Group, Communisis have many specialist areas which produce services utilised by the Group as well as clients. This includes creative agency services in the UK, which includes software development, film and film production, social media and agency services - creative conceptual work and graphic design. In Europe, this includes artwork studios and film production and in India, this includes IT software development. OUR SUPPLY CHAINS Communisis 250m supply chain is enormously diverse. We trade with some of the largest global corporations in the world and also with small owner-managed business with just a handful of employees. We trade with suppliers in the UK, North America, Western Europe, Eastern Europe, Middle East and China. We buy things ranging from services and technology, through to bespoke manufactured / printed / fabricated marketing materials. This diversity is a huge strength for our business, however it is also something we need to be mindful of when we manage our supply chains. We have various classes of risk that need managing so that our business, together with the reputations of our clients, are properly 1

2 protected. In the case of modern slavery this means that our processes need to be able to identify areas of greatest risk so that we can focus our proactive attention in those places. For example there are different characteristics across our five largest areas of direct spend: Marketing Print (highly automated, lower labour content, predominant material content is paper / substrate, usually manufactured in the country of end use) Temporary Point-of-Sale Displays (partially automated, approximately 40% unskilled labour requirement, predominant materials paper, cardboard, substrates, usually manufactured in the country of end use) Permanent Point-of-Sale Displays (less automation, high level of unskilled labour requirement, diverse types of materials including metals, acrylic, wood, glass and plastics, often manufactured in the country of end use but also subject to some manufacture in - and export from - Eastern Europe and Turkey) Premiums & Merchandising (a more complex and diverse category, generally high automation, but also often with high unskilled labour, primary manufacturing locations are Asia and specifically China) Paper (highly automated, low use of unskilled labour, typically produced in countries with stronger employment controls) Even within each of these spend areas the diversity is considerable, and so we have taken time to ensure that we understand where our greatest risks are so that we can prioritise our efforts accordingly. OUR POLICIES Communisis has always had a zero tolerance approach to forced, bonded or compulsory labour, human trafficking and other kinds of slavery. While this is our first public statement addressing these issues in line with the requirements of the new UK Modern Slavery Act (2015), we have been focused on the rights and well-being of the people who work for Communisis and concerned for workers at our suppliers for many years. Communisis Modern Slavery and Human Trafficking policy was launched in November 2015 and brought Communisis stance on these issues fully in to line with the Modern Slavery Act 2015 (the Act ). This policy is owned and monitored at Executive Board level and works alongside existing group policies on each of Procurement, HR & Recruitment, Ethics and Whistleblowing to give us a comprehensive control environment in this important area. OUR APPROACH Communisis has established processes and procedures that are designed to prevent modern slavery and human trafficking from operating within our own business and a toolkit that seeks to ensure that our supply chains are also free from these practices. 2

3 Our Recruitment Policy and processes are regularly reviewed and learnings applied. Our dedicated Recruitment partner ensures that whatever channel we recruit through, we are operating in the best possible way and adhering to all relevant legislation and best practice. Whenever we use 3 rd party agencies, these businesses are fully on boarded and made aware of our expectations and obligations before we begin working with them. Any candidates who enter the recruitment process in this way, are treated in exactly the same way as anyone coming directly to us and benefit from the same thorough recruitment processes. We do not charge individuals fees in the event of joining Communisis, and would not tolerate Agencies doing so either. Additionally we train all of our hiring managers, to again ensure they are fully aware of their responsibilities and operate in an appropriate way. All new recruits into Communisis are vetted by external security experts as to their right to work in our business and in the relevant employing country, alongside a series of other personal, financial and identity background checks. The same vetting and transparency requirements apply to staff working on a temporary employment basis either contracting with Communisis directly or through external labour providers. When new colleagues join the business, we will ensure that they receive a thorough induction which outlines how we expect them to behave and operate within the business. Our new colleagues, permanent and temporary, are supported in this through a suite of mandatory training around key issues and risk areas. Non-compliance with this training, or the topics it covers, is taken very seriously and managed through our disciplinary process if required. This training is repeated on an annual basis which allows us to update and improve, and ensure our people are regularly reminded of our expectations. For managing our supply chain, Communisis has built upon its pre-existing due supplier diligence processes to create a toolkit aimed specifically at dealing with modern slavery and its associated issues. Our approach provides for a mix of education, development and enforcement across our supply chains. The foundation of our due diligence approach is a comprehensive supplier Pre-Qualification Questionnaire, which gathers lots of information about the supplier, including related to employment and human resources approaches and policies. We now also require our suppliers to sign up to our Modern Slavery Code of Conduct in addition to our pre-existing Supplier Code - which outlines the values we seek to uphold and the principles we wish to see operating throughout our supply chains. We are currently going through a programme of getting acceptance of this Modern Slavery Code from all previously approved suppliers (who will have already signed the existing Supplier Code covering working practices). Finally, our standard terms and conditions of supply outlaw anything that would fail to comply with the Act. All of these building blocks need to be in place before a supplier is fully approved for use by Communisis. 3

4 We recognise however that it is not possible to assert that our supply chains are free from modern slavery just because suppliers have signed up to these principles and these terms. So we have further activities which help us to assess risk on an ongoing basis. One is our programme of supplier audit. Whilst this audit is broad in its nature, as is the case with any supplier visit, it provides our team with the ability to observe what is happening in factories that form part of our supply chain. Any concerns raised by such an audit will trigger a detailed Supplier Self-Assessment Questionnaire (see below). Another detective activity is supply chain mapping. This is a desk-based risk assessment which seeks to overlay on to our supply chains the generic indicators of slavery (such as geography, demographics, prevalence of manual/unskilled and/or migrant labour), industry-type, peer performance and material content). We supplement our desktop analysis with existing indices, including Walk Free s Global Slavery Index and the Transparency International Corruption Index. Where we assess the risk to be medium or high a detailed Supplier Self-Assessment Questionnaire is required. This questionnaire extends to 14 questions, the answers to which will provide a strong indicator as to whether poor employment practices might be present in that business. If the completed questionnaire raises cause for concern then a specialist audit of employment practices at that supplier is triggered, which involves observing and interviewing staff. In the event that modern slavery is detected in our supply chain our first thought will be to the workers involved in that situation. To that end we will work with the supplier to raise awareness of the issues, seek a commitment to resolve them and a commitment to the sort of transparency that we require of them. A case-by-case decision will be made as to whether to continue or suspend trading with that supplier, or indeed whether to remove them from our supply chain altogether. Our preference will always be to eliminate slavery from that business, rather than eliminate it only from our supply chain. EVALUATING OUR PROGRESS During 2016 we have undertaken a considerable amount of activity aimed at tackling modern slavery, including: Had all suppliers sign up to our new terms and conditions including the modern slavery provisions, and also to our standard supplier code of conduct which includes employment rights and ethical working practices Conducted a desktop risk assessment of more than 950 suppliers; and based on these have Triggered detailed self-assessment questionnaires for more than 50 of those suppliers, who are predominantly based in Eastern Europe, Turkey, the Middle East and Asia. 4

5 Had more than 500 suppliers sign up to our recently updated Modern Slavery Code of Conduct Conducted a site-based audit of 67 suppliers Asked our tier one suppliers of high volume merchandising Premiums products (these are usually agents or brokers) to flow our Modern Slavery Code of Conduct throughout the depth of their entire supply chains that provide goods for Communisis and our clients. We have also asked that same group of suppliers to provide us with copies of their own supplier audit processes and reports for added assurance. Engaged with an NGO, Unseen, to understand more about the co-ordinated approaches to tackling modern slavery that have become more possible since the arrival of the Act. Collaborated with the professional body (Chartered Institute of Procurement and Supply) on sharing good practices Collaborated with procurement teams at our client organisations, again sharing good practices In 2016 we found no instances of modern slavery in our supply chains, however we are confident that we are well placed to address any that may be identified as we move in to 2017 and beyond. TRAINING During 2017 Communisis employees will receive mandatory training in how to be vigilant for signs of modern slavery or trafficking and what to do if there are suspicious of any activity. Should an employee have concerns about raising an issue then they are be encouraged to utilise and achieve the protection provided by the Whistle-blowing Policy. Our Sourcing team have already received awareness training on Modern Slavery, with a particular focus on potential warning signs. This will be further deepened in 2017 and will be rolled out supplier-facing staff in other departments. LOOKING AHEAD Whilst Communisis has built on its existing policies, processes and practices to make a great start in this first reporting year as designated by the Act, we must not lose our focus from this important area. In 2017 we expect to be able to measure our continued progress, including in the following areas: Carefully targeted site-based supply chain audits 5

6 Continued roll-out of the Modern Slavery code and associated toolkit deeper in to our extended supply chains Complete staff training and engage with suppliers around its content Establishment of a governance forum to oversee activities, prioritise resource and monitor completion of corrective actions Approved by the Communisis Executive Board on 15 th February Andy Blundell Chief Executive 6