Slavery and Human Trafficking Statement

The Modern Slavery Act 2015 requires commercial organisations supplying goods or services with a turnover of above £36 million to prepare and publish an annual ‘Slavery and Human Trafficking Statement’. The Statement must set out the steps an organisation has taken, if any, during its financial year to ensure that slavery or human trafficking is not taking place in its supply chain.


What is Modern Slavery

Modern slavery is an international crime, affecting an estimated 29.8 million slaves around the world. It is a growing global issue that transcends age, gender and ethnicities. It includes victims who have been brought from overseas and vulnerable people in the UK, who are forced to illegally work against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing.

Our Policy

Wasdell Group is working towards establishing a zero-tolerance position on violations of anti­human trafficking and anti-modern slavery laws. This statement explains the steps we intend to take, to ensure that slavery and human trafficking is not taking place in any of our supply chains or any part of our business. If we do find breaches of these laws within our supply chain, we will look to support companies in their efforts to comply with the legislation or change our suppliers if necessary.

Our Structure and Supply Chains

The Wasdell Group is composed of principally 3 companies operating from 3 locations across the UK, employing over 590 direct employees and 80 agency workers:

Wasdell Packaging Ltd: Swindon, UK: approx. 440 permanent employees and 60 agency workers;
Wasdell North: Burnley, UK: approx. 80 permanent employees and 20 agency workers;
Wasdell Manufacturing Ltd: Newcastle, UK: approx. 70 permanent employees.

The Wasdell Group is one of the largest and most experienced contract packaging suppliers to the pharmaceutical and healthcare industry in Europe. It provides a full range of storage, fulfillment and distribution services (operating from Swindon and Burnley) tailored to customer needs, and our pharmaceutical manufacturing site in Newcastle offers flexible solutions to customers with non-sterile manufacturing requirements.

Our supply chain is predominantly the UK domestic market {500 suppliers) together with some European suppliers (20) and 2 or 3 suppliers from the US.

Our suppliers are usually pre-approved suppliers dictated by our customers. For example, our suppliers in the US provide a health and nutritional product dictated by a specific customer.

The Wasdell Group use only 3 suppliers of labour resource in the form of 3 Agencies across the UI<.

Our Procedures

Employment

The Wasdell Group has numerous internal HR policies which are available to all staff and these can be accessed by third parties on request by contacting Martyn Burchall at info@wasdell.co.uk for a copy. These policies include Equal Opportunities, Dignity at Work and Whistle Blowing. Our whistle blowing procedures encourage anyone who has concerns, for example, about how supplier partners or staff including agency workers are behaving, to raise their concerns confidentially. Through the modern slavery training we intend to conduct, employees will also be encouraged to report any suspicions that they may have regarding modern slavery. Our policies are reviewed annually by the organisations’ legal advisors to ensure we remain compliant.

As part of the organisation’s induction process and throughout our employees’ employment with us, we train all employees to treat others with respect and courtesy as well as ensuring they adhere to all relevant laws, regulations and standards. This is an ongoing due diligence process. We offer a training and development programme for all staff. We focus on ensuring our management team is not only aware of the requirements to be alert to modern slavery but can also address concerns raised by their team or any suppliers. If any employee is found in breach of our policies, we ensure suitable disciplinary action is taken which can include termination of employment.

All right to work documentation is checked for permanent employees, contracts of employment are provided to all new starters and market-related pay is provided to all employees which will at all times meet national living and minimum wage rates set by the government.

Suppliers

In relation to our supply chains, we have carried out a risk assessment to identify our tier 1 suppliers and main providers of agency workers.

With regards to Agency suppliers, all Managers within the Group are aware of the agreed list of 3 Agency supply companies. Managers are not permitted to engage with any other labour resource suppliers without express permission of the Finance Director who will ensure relevant due diligence is carried out before engaging.

Signed agency supplier contracts are to be issued which obliges the Agencies to comply with eligibility to work checks, national minimum wage compliance, MSA compliance and Anti­Bribery compliance.

Furthermore, all tier 1 suppliers, including our Agency suppliers will be issued with a letter requesting a response confirming their own modern slavery and anti-human trafficking policies. If any risks are identified then further investigations will be carried out and any necessary action will be taken.

Going Forward

Our aim for the forthcoming financial year, is to:

  • Develop an employee training module that will be undertaken by all Wasdell Group employees. This training will outline what modern slavery is, how to identify it and what individuals should do if they suspect there are any cases of slavery occurring. Completion of this training will form a compulsory part of new starter induction processes.

Wasdell Group shall take responsibility for this statement and its objectives which will be reviewed and updated as appropriate.

March 2018

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