Modern Slavery and Human Trafficking Statement

Holland & Sherry Ltd Modern Slavery and Human Trafficking Statement 

This statement is made pursuant to the Modern Slavery Act 2015. It sets out the steps that Holland & Sherry Ltd has undertaken and is continuing to undertake to ensure that modern slavery is not taking place within our business or supply chain. This statement relates to actions and activities during the financial year 01 April 2018 to 31 March 2019.   

Holland & Sherry Ltd has a zero tolerance approach to any form of modern slavery, which we consider to include different types of exploitation such as forced labour, servitude, child labour and human trafficking. The Company is committed to acting in an ethical manner with integrity and transparency in all business dealings. We are also committed to putting in place effective systems and controls to safeguard against any form of modern slavery taking place within our business and supply chain. 

 

Our Company 

Holland & Sherry Ltd is a wool merchant. The Company (and subsidiaries) currently has employees based in 12 countries and we also work closely with our suppliers across the world. We believe that our biggest exposure to modern slavery risks lies in our product supply chains in Nepal and India.  Our activities relating to assessing and managing our modern slavery risks accordingly focus on our key suppliers in these geographic regions.

 

Our Policies 

We operate a number of policies designed to ensure that we are conducting business in an ethical and transparent manner. These policies include: 

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

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 company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our confidential disclosure form.

Recruitment Policy: We carry out identity and eligibility to work checks on all new employees of Holland & Sherry Ltd to safeguard against human trafficking or individuals being forced to work against their will.       

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 organisation works with suppliers to ensure that they meet the standards of the code and strive to improve their worker's working conditions. 

 

Site Visits and Inspections: The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:

  • Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking.
  • Evaluating the modern slavery and human trafficking risks of each new supplier.
  • Conducting supplier audits or assessments with a focus on slavery and human trafficking where general risks are identified.
  • Taking steps to improve substandard suppliers' practices, including providing advice and support to suppliers.
  • Invoking sanctions against suppliers that fail to improve their performance or serious violation our supplier code of conduct, including the termination of the business relationship.

 

Training

The organisation requires all staff working within the company to complete training on modern slavery.

The organisation's modern slavery training covers:

  • The basic principles of the Modern Slavery Act 2015.
  • Our Company & Suppliers code of conduct.
  • 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 company.

 

 

Assessment of Effectiveness 

The company is absolutely committed to preventing slavery and human trafficking in its business activities, and to ensuring that its supply chains are free from slavery and human trafficking.

We recognise that our commitment to a zero tolerance approach to modern slavery is a continual journey and we will continue to review and where necessary modify our processes on a regular basis. 

This statement has been approved by the Board of Directors of Holland & Sherry Ltd.  

 

Signed by: 

Name: Frank Clare

Designation: CFO

Date: 02/10/2019