Effective date: 30th April 2017

Purpose

This statement sets out actions taken by Adare SEC to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

This statement relates to actions and activities during the financial year 1 November 2015 to 31 October 2016.

The procedure applies to all employees in Adare SEC.

The company recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The company is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains:

Adare SEC provides Secure and Essential Communications to private and public sector clients who need to control the cost, quality and efficiency of their printed and electronic communications.

Adare SEC specialises in the production of business critical communications such as Transactional Mail, Direct Mail, Document Management and Security Print and has developed solutions that ensure legal compliance, regulatory adhesion and highly personalised messaging.

Adare SEC manages the procurement and provision of printed and sundry items using a network of carefully selected supply chain partners. In addition, Adare SEC has extensive in-house production facilities offering high quality Litho, Digital, Cut Sheet, Continuous and Security print solutions.

Adare SEC is trusted by both Central and Local Government organisations and also by many leading financial and marketing brands to deliver essential communications on their behalf.

Countries of operation and supply:

  • The Company currently operates in the following countries: UK for all operations other than:
    • Envelopes from Northern France
    • A label product from Germany
    • A type of material direct from USA

The process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking is detailed below as our responsibility for the Company’s anti-slavery initiatives:

Policies:

  • The Company’s HR Department is responsible for putting in place and reviewing policies and the process by which they are developed and maintained

Risk assessments:

  • We cover our assessment by the requirement that all vendors receive, read, sign and comply with our supplier agreement (copy available) which incorporates a section on Corporate Social Responsibility including Forced labour, Child labour and discrimination etc.
  • Where necessary we will check any ISO / BSI certification and send by email a Supplier Audit Document requesting details on operations, quality, Finance etc. If anything untoward was suspected and deemed critical an on-site vendor audit would be arranged to check against the provided information.

Investigations/due diligence:

  • The relevant Manager and HR will be responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking. It will be the responsibility of the Manager to report any suspect and then to investigate in conjunction with HR.

Training:

  • The HR Department is responsible for arranging and delivery of training. This will be with the aim to equip necessary parties to better understand and respond to the identified slavery and human trafficking risks.

Relevant policies

The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing policy

  • The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

Employee code of conduct

  • The Company’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

Supplier code of conduct

  • The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship. Adare SEC’s supply chain commitment to an agreement that incorporates Corporate Social Responsibility including employment standards with emphasis on forced labour including Prison labour, Indentured labour, bonded labour or otherwise. These elements are inspected annually during the vendor audit process which includes on-site inspections.

Recruitment policy

  • The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

    As such strict checks are in place with all agencies including vetting, reference checks and endorsements on eligibility to work in the UK documents. Regular audits are also in place to ensure the agencies adhere to required standards.

Due diligence

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence and reviews include

  • Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • Reviews on a regular basis via vendor auditing
  • Conducting supplier audits or assessments
  • Taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans. Any found non-conformance would be given a period of time to resolve. Failure to rectify the non-conformance would result in the supplier being removed from the approved list.

Performance indicators

The Company has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation is:

  • requiring supply chain managers and HR professionals to have completed training on modern slavery by end of 2017

Training
The Company requires supply chain managers and HR professionals to complete training on modern slavery.

The Company’s modern slavery training covers:

  • How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • How to identify the signs of slavery and human trafficking;
  • What initial steps should be taken if slavery or human trafficking is suspected;
  • How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;
  • What steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.

Awareness-raising programme
As well as training relevant staff, the company will raise awareness of modern slavery issues by circulating a series of emails and memo’s to staff by end of 2017.

These explain:

  • The basic principles of the Modern Slavery Act 2015;
  • How employers can identify and prevent slavery and human trafficking;
  • What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Company; and
  • What external help is available, for example through the Modern Slavery Helpline.


Board approval
This statement has been approved by the Company’s board of directors. The HR department will review and update as required.

Barry Crich
Managing Director
Adare SEC Limited

Date: 12.05.2017