The Modern Slavery Act (2015) made the UK the first country to require large businesses to report transparently on the steps they have taken to tackle modern slavery in their operations and global supply chains. Since the COVID-19 pandemic the demand for PPE increased rapidly and therefore there have been increases in legislation throughout the supply chain. Modern slavery is an umbrella term encompassing a wide spectrum of high harm crime, including human trafficking, slavery, servitude and forced labour. Ultimately, employers are obliged, at minimum, to uphold local laws related to working hours, and to strive towards implementation of international standards. Modern slavery is a global issue and requires global action, being part of Bunzl, we are wholly committed to eliminating modern slavery practices and respecting human rights across our operations and supply chain.
How we keep our employees informed
All Bunzl employees understand our policy around eliminating forced labour, child labour and human trafficking. This helps them, regardless of their roles, to recognise and understand potential modern slavery issues and take appropriate action. Our Speak Up policy sets out our internal grievance reporting procedures. We expect our employees to make management aware of all non-compliances to our code of conduct, any applicable law and/or company policies. The Speak Up posters are displayed on notice boards in each facility including information on how to report matters confidentially and anonymously. None of the calls received through the Speak Up line in 2021 related to modern slavery which hopefully demonstrates we are taking the right steps towards making sure modern slavery is not present in our organisation.
How buyers eliminate modern slavery
At Greenham our Category Managers have created and developed our Exclusive Brand ranges. When developing the ranges they go through lots of different stages including; design, specification testing, approval, and certification. They are experts in this field. Procurement teams are responsible for mitigating modern slavery risks throughout the procurement cycle. Below are steps that can be addressed during the following stages of the procurement process to address the issue of modern slavery:
Part 1. Pre-procurement / selection stage: during this stage, procurers identify potential high-level modern slavery risks and select the suppliers they award the contract to base upon this – making sure to ask relevant questions and request evidence related to modern slavery mitigation practices along the way.
Part 2. Contract management: during this stage, the contract manager monitors the performance of the contract, and engages suppliers to ensure that modern slavery risks and issues identified are resolved and remediated effectively.
Part 3. Escalation: during this stage, the contract manager escalates modern slavery related risks to senior management if needed and identifies ways to engage with the supplier. Suspension or termination is considered only once attempts at engaging with the supplier have been exhausted.
Part 4. Encourage communication and continuous improvement: throughout the contract period, the contract manager should encourage suppliers to a) communicate and report transparently about their work to address modern slavery issues, and b) engage in a continuous improvement model. *
Risks across the supply chain
There are risks across the supply chain especially where we source our products from overseas therefore, we must be aware of these risks and assess them to ensure that every worker in our supply chain is treated fairly. One of the key elements is our industry leading sourcing and auditing operation in Shanghai. It plays a critical role in ensuring that our suppliers from Asia (the most high-risk sourcing region) are subject to frequent and stringent labour and quality checks which is an important part of eliminating modern slavery. We are committed to taking what we have learned across Asia and expanding our ethical sourcing principles. We hope by 2025 to be able to ensure products from all high-risk regions are sourced from assessed and compliant suppliers.
We audit suppliers on many topics, child, forced or bonded labour, disciplinary practices, management of homeworkers and foreign migrant workers, freedom of association, wages, working hours and health & safety. When it comes to our overseas suppliers, they operate under the instruction of the global sourcing and quality assurance facility in Shanghai, and they are approved through selection, approval, manufacturing, and inspection testing. The supplier must adhere to statuary and regulatory requirements, and they must meet or exceed local legislative requirements and applicable international requirements for workers welfare and conditions of employment e.g., International Labour Organisation and Ethical Trading Initiative.
Our Ethical sourcing policy ensures that Bunzl sources products in an ethical and consistent manner. A key element is our Supplier code of conduct, which establishes our expectations for suppliers in the areas of labour and human rights, environment, health and safety, ethics, and management systems.
To learn more about our Modern Slavery Policy, read our Quality & Product Assurance document here.
*https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/989252/Tackling_modern_slavery_in_PPE_supply_chains_-_guidance_for_public_bodies.pdf
