Modern Slavery & Human Trafficking Statement 2021
1. MODERN SLAVERY
- 1.1 Modern slavery is a crime and a gross violation of fundamental human rights and as such is not compatible with H&W’s company values. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
- 1.2 H&W has a zero-tolerance approach to modern slavery and is committed to ensuring that H&W acts ethically and with integrity in all our business dealings and relationships. In order to achieve this H&W needs to implement and enforce effective systems and controls within the business to ensure modern slavery is not taking place anywhere in the business or in any of our supply chains.
- 1.3 H&W is also committed to ensuring transparency through the business and in its approach to tackling modern slavery throughout H&W’s supply chains, consistent with the disclosure obligations under the Modern Slavery Act 2015. H&W expects the same high standards from all of its team members, officers, contractors, suppliers, agents, business partners and any other person contracted by or on behalf of H&W. H&W also requires that no one will use forced, compulsory or trafficked labour, and that no one is held in slavery or servitude, whether adults or children, and H&W expects that its suppliers will hold their own suppliers to the same high standards.
2. COMPANY STRUCTURE
- 2.1 H&W is a manufacturer of beer and a provider of pub, restaurant and accommodation facilities. H&W has its head office in the UK and all trading outlets are in the UK.
- 2.2 The group has an annual turnover in excess of £36m.
- 2.3 H&W’s business is organised into two principal business units: Pubs and Drinks.
3. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
- 3.1 As part of H&W’s initiative to identify and mitigate risk -
- (a) the geographical scope of H&W’s licenced premises are limited to ensure optimum supervision of the use of its properties;
- (b) long standing relationships are built with local suppliers and business partners which whom H&W makes clear its expectations of business behaviour;
- (c) H&W’s preferred point of contact with national or international supply chains is with a UK company or branch and H&W expects these entities to address anti-slavery and human trafficking issues.3.2 H&W has in place systems to encourage the reporting of concerns and the protection of whistle blowers.
- 3.2 H&W has in place systems to encourage the reporting of concerns and the protection of whistle blowers.
4. SUPPLY CHAINS
- H&W’s supply chains include the sourcing of raw materials principally related to the provision of food and drink, some of which are from overseas.
5. SUPPLIER ADHERENCE TO H&W VALUES
- 5.1 H&W has a zero tolerance to slavery and human trafficking. H&W expects those in its supply chain and other contractors or agents to comply with H&W’s values. We collate and review Modern Slavery Statements from our suppliers as part of our process. For those suppliers who are not covered by the legislation and do not have statements, we have shared our Modern Slavery Policy and asked them to confirm adherence to its principles. We also conduct regular visits to our suppliers, and include visits to the production lines to observe the working environment.
- 5.2 The Directors are responsible for compliance in their respective teams and for their team’s supplier relationships.
We consider the principles of the Modern Slavery Act throughout our recruitment process. Where we recruit from overseas, we only deal with agencies with whom we have an existing relationship or who have been through our vetting and verification process and we speak to recruits to ensure that they have not paid any fees to agencies to get to the UK. We have in place mandatory and robust systems to check the Right to Work of all new starters, which we believe will stop any undocumented workers from being engaged and therefore assist in the prevention of illegal working.
- 6.1 We continue to check in with new team members regularly, and operate an open policy to address any concerns.
- 6.2 We have developed a Guide to Modern Slavery and how to spot potential victims, which we share with our Regional and General Managers, and our Business Partners, to enable them to identify indicators of Modern Slavery and to provide contact details for the UK Slavery Helpline.
7. OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
- 7.1 We use the following methods to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
- (a) Public house visits by Area Managers and Regional Managers;
- (b) Monitoring of recruitment and payroll systems within H&W; and
- (c) Open communication with Suppliers regarding H&W’s values and expectations.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group's slavery and human trafficking statement for the current financial year.
Hall & Woodhouse Limited