Introduction
This statement is made on behalf of Whittan Industrial Ltd. It is a statement made in accordance with section 54 of the Modern Slavery Act 2015 and covers the 2020-21 Financial Year.
Whittan Industrial Ltd strives to operate with integrity and we recognise our responsibility to be aware of the risks of modern slavery and human trafficking within our own Group and supply chain. A number of focus areas reported last time have been adversely impacted by the pandemic e.g. supplier visits which have been impossible to carry out in person.
About Us
Whittan Industrial Ltd has 4 core sites in the UK. We employ around 425 staff members undertaking a range of roles including Fulfilment, Sales, Manufacturing, Supply Chain, Technical, Finance, IT, HR and business strategy.
During the pandemic the use of agency labour reduced dramatically but as the business has rebounded more agency labour has one again been used in our manufacturing areas. This category of people will continue to form part of our ongoing resourcing strategy to support the peaks in the production cycle. Individuals are sourced through reputable recruitment agencies and the individuals work alongside our core employee population. Again, following the lifting of restrictions on construction type activities we have, more recently, had third party contractors working on site who provide specialist expertise in areas such as installation. We have maintained the outsourced contractors for services as logistics and cleaning. Appropriate right-to-work checks are conducted in partnership with those agencies.
Within our direct supply chain, there are around 50 different raw material suppliers. Our indirect supply chain currently consists of over 600 active suppliers.
During the last twelve months very little has changed in our supply chain although the spread of orders has shifted due to the challenges resulting from Brexit which highlighted those suppliers who were well prepared for the exit from the EU and those who were less ready. We stand by our previous conclusion that the risks of modern slavery and human trafficking being present in our supply chain are low. However, we remain vigilant to the risks and ensure that our suppliers understand and play their part in ensuring that modern slavery and human trafficking does not take place in our organisation or supply chains. This message will be reiterated to our suppliers via our procurement teams in each supplier review.
Relevant policies and contracts
To reinforce our commitment to combating slavery and trafficking, we maintain the following policies to guide behaviours and set standards internally and externally to the business:
a) Anti-Slavery & Human Trafficking Policy
b) Code of Conduct
c) Bribery & Corruption Policy
Previous revisions to our policies remain relevant including the Whistleblowing Policy which enables employees to raise concerns through our transparent and accessible reporting process. This provides support to our employees in making day to day ethical decisions in addition to the specific Anti-Slavery & Human Trafficking Policy already in place.
Our Supplier Assessment Questionnaire includes a specific section of ethical trading and applies to all existing suppliers in our supply chain. This checklist asks suppliers to confirm they have a stance on modern slavery.
We are reviewing the steps we take when engaging with new suppliers, contractors and business partners to ensure that they are aware of and will adhere to our Procurement Standards & Supplier Requirements Policy, which will be launched later this year. These updated processes will allow our procurement team to assess the likelihood of modern slavery or trafficking existing in those organisations and understand what measures are already in place to combat those risks.
Risk assessment processes
We have considered the risk of modern slavery in our own operations and we have concluded that the status has not changed and as a UK employer subject to UK employment protections and practices we are subject to low risk.
Our internal processes have been adapted further to ensure the impacts of Brexit are well understood and managed in the recruitment and/or ongoing employment of colleagues. We continue to use analysis of employee data to highlight any potential cases of potential slavery.
Our suppliers who fall into the following categories will be encouraged strongly to commit and adhere to the emerging revision to Whittan standards, which include;
• Suppliers of raw materials
• Those involved in the manufacturing of our bought-in products
• Those providers of services supporting the delivery of our overall customer offering
We do not consider the risk level of modern slavery occurring in our use of external labour via employment agencies to have changed as our provider base has remainder stable and their internal checks have been sufficiently robust. Therefore, we have concluded that the risks of modern slavery are low in this area.
Our stated desire for a higher degree of oversight in relation to our direct suppliers remains an area of focus and will be revisited once restrictions are sufficiently relaxed to conduct site checks in a safe manner.
Due diligence processes
The business continues to utilise the Supplier Assessment Questionnaire and we will maintain:
• Our zero-tolerance approach to modern slavery;
• Require suppliers to confirm that they will adhere to the principles set out in our Procurement Standard & Supplier Requirements policy;
We have had no reason to take remedial actions with any suppliers in the last year but will continue to review their responses to assess ongoing due diligence needs and commercial partnerships.
Training
The business introduced mandatory online training modules to complement and raise awareness of modern slavery and trafficking, and to point staff to how our policies and procedures. All compliance modules will be set up so that they are completed by each new starter and by existing employees on a biennial basis.
Our suite of compliance e-learning modules comprise Bribery & Corruption, GDPR, Diversity & Inclusion; which are compulsory courses for all staff.
Measuring effectiveness – performance indicators
During the pandemic, much management focus has been trained on securing a future for the business and some of the intended actions have not been achieved. This is due largely to the unprecedented world we have been operating in. However, we intend to continue with the following in the coming financial year:
• All employees will have completed the relevant training, as referenced above
• We will have review and re-issue our Anti-Slavery & Human Trafficking, Whistleblowing and Code of Conduct policies to our workforce setting out our stance in relation to modern slavery
• In addition, we will reinforce key messages throughout the year through the use of poster campaigns, formal and informal communication channels
• We will establish a process to gain a better oversight of our direct supply chain and consider how best to improve risk assessments, carry out due diligence and communicate with these suppliers in relation to Modern Slavery and Human Trafficking issues
• We will ensure that we continue to refresh and revise our Anti-Slavery and Human Trafficking clauses in our contracts with our suppliers.
• We will assess and consider the appropriateness of developing further measures within our risk assessments
• We will review key performance indicators so we can ensure we are measuring the right outcomes
This statement has been approved by the Whittan Board of Directors who will review and update it annually.
