MODERN SLAVERY ACT COMPLIANCE STATEMENT FOR THE YEAR ENDED 31 DECEMBER 2016
This statement applies to all UK operating companies within the Advantage Smollan Group as at 31 December 2016 (referred to in this statement as “The Group”).
GROUP BACKGROUND AND ORGANISATIONAL STRUCTURE
Founded in 2015, Advantage Smollan is a jointly-owned holding company of Advantage Solutions (Advantage) and Global Smollan Holdings (Smollan) that provides unified sales, marketing, and technology solutions for consumer goods manufacturers and retailers across Europe. The Group has its head office in Winnersh, UK with a number of offices across UK and Europe.
The Group considers that modern slavery encompasses:
- Human trafficking;
- Forced work, through mental or physical threat;
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
- Being dehumanised, treated as a commodity or being bought or sold as property;
- Being physically constrained or to have restriction placed on freedom of movement.
The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group does not knowingly enter into business with any other organisation, in the UK or abroad, which supports or is found to involve itself in slavery, servitude and forced or compulsory labour. No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under the relevant employment legislation.
Our working practices respect and uphold all human rights for our employees and contractors. This approach also extends to the employees of suppliers working on our sites. We have a Code of Conduct and Whistle-blowers Policy, both of which are published on our intranet site.
If there are any genuine concerns about any wrongdoing or breaches of law, these concerns can be raised in confidence through the Whistle-blower process.
SUPPLIER DUE DILIGENCE
Key / first tier suppliers have been identified and asked to complete a questionnaire documenting their compliance with Modern Slavery Act requirements. As the Act is still relatively new, there is an ongoing education process to ensure that all of the suppliers in our supply chain are aware of the requirements and are then pro-actively monitoring their business operations / supply chain for instances of non-compliance. To date, we have not identified any act of non-compliance with the requirements of the Modern Slavery Act.
We are currently reviewing our supply chain protocols and will be implementing specific measures to ensure that our obligations under the Modern Slavery Act are disseminated through our supply chain. These measures will include:
- Continuing work to identify and assess any key risk areas in our supply chains.
- Contacting all critical suppliers to affirm our zero tolerance approach to human rights abuses and requesting details of their due diligence procedures both for internal compliance and within their own supply chains.
- Making available a supplier Code of Conduct setting out the Group’s standards including our commitment towards human slavery and trafficking laws, anti-corruption, environmental protection, ethical conduct and diversity and inclusion.
- Implementing an Anti-Slavery Policy.
- Adapting our employee training programmes to include key elements / requirements from the Modern Slavery Act 2015.
- Including a specific requirement in our procurement vetting process for prospective suppliers to disclose their position on human slavery and trafficking and provide policies/statements as appropriate.
- Ensuring appropriate contractual wordings are included in Group’s supplier contracts.
- Continuing to safeguard whistle-blowers via our ‘Whistle-blowers’ Policy.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group’s slavery and human trafficking statement for the financial year ending 31 December 2016.
Director, Advantage Smollan Limited