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.
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 four companies operating from three locations across the UK and Ireland, currently employing over 577 direct employees and 90 agency workers:
Wasdell Packaging Ltd: Swindon, UK: approx. 450 permanent employees and 90 agency workers;
Wasdell Manufacturing Ltd: Newcastle, UK: approx. 70 permanent employees;
Wasdell Europe Ltd: Dundalk, Ireland: approx. 30 permanent employees;
Honeywood Ltd., Wellingborough, UK: approx. 27 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 tailored to customer needs, and our pharmaceutical manufacturing site in Newcastle offers flexible solutions to customers with non-sterile manufacturing requirements. The facility in Ireland will offer QC import testing, a variety of current and novel packaging technologies as well as storage and distribution, and the recent acquisition of Honeywood Ltd. will increase capacity and service offerings in the UK an enable better service to a growing client base in the US.
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 three suppliers of labour resource in the form of three agencies across the UK.
The Wasdell Group has a number of internal HR policies which are available to all staff, and these can also be accessed by third parties on request by contacting Darren Radford at firstname.lastname@example.org. These policies include Equal Opportunities, Dignity at Work and Whistleblowing. Our whistleblowing procedures encourage anyone who might have concerns, for example, about how staff or our supplier partners are behaving, to raise them in a confidential manner. This procedure can also be used in respect of any suspicions an individual might have in relation to modern slavery. Our policies are reviewed annually by the organisation’s 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.
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 three 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 them.
Signed agency supplier contracts are issued which obliges the agencies to comply with eligibility to work checks, national minimum wage compliance, MSA compliance and anti-bribery compliance.
Furthermore, all tier 1 suppliers, including our agency suppliers are 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.
We have rolled out a new induction programme within which there is a greater emphasis on conducting right to work checks and ensuring that all new starters remain eligible to work in the UK. Inducting managers have received expert coaching in this process and have received training in modern slavery and human trafficking.
We are continuing to increase visibility of modern slavery and human trafficking across our sites and have put information posters up in our communal areas. These provide our employees with general information about the issues, and provide them with support and guidance and an impartial helpline number.
Work is still being undertaken to develop a procedure as part of our Quality Audits with our tier 1 suppliers to assess their compliance with the MSA 2015, and risk assessments will be carried out our tier 2 suppliers throughout the next 6 – 12 months.
As part of our procurement process with suppliers, we now request suppliers to certify that they do not participate in any forced or involuntary labour with their workers, subcontractors, agents or associates.
This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 for the financial year ended 31st March 2018. It has been approved by the Board of Directors, who will review it on an annual basis making updates as necessary.
31st May 2019