Modern Slavery Statement

 

 

Introduction

This statement covers the activities of Pedigree Wholesale Limited.

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

 

Definitions

The Organisation 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 of 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.

 

Commitment

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in Europe, China, India, Japan, Vietnam, USA.

Supply chains

In order to fulfil its activities, the main supply chains of the Organisation include those related to the supply of goods from various suppliers in both the United Kingdom and Internationally. We

understand that the Organisation’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.

 

Potential exposure

The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in its Pet Foods & Accessories supply chains because they involve the provision of labour in a country where protection against breaches of human rights may be limited.

In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

 

Steps

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has started to take the following steps to ensure that modern slavery is not taking place:

  • mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking;

  • evaluating the modern slavery and human trafficking risks of each new supplier

  • working towards reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;

  • conducting supplier audits or assessments through the organisation's own staff/third party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified;

  • creating an annual risk profile for each supplier;

  • beginning to take steps to improve substandard suppliers' practices, including providing advice to suppliers through and requiring them to implement action plans.

  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

 

Policies

The Organisation has the following policies which further define its stance on modern slavery

  • Whistleblowing policy. The organisation 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 riskof 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 contact our HR Department in complete confidence.

  • Employee Code of Conduct. The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation 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 organisation 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 improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.

  • Recruitment Policy. The organisation 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.

We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

 

The organisation's modern slavery training:

  • our business's purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;

  • 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 messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and

  • what steps the organisation 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.

 

Performance indicators

The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is:

  • developing a system for supply chain verification expected to be in place by 1 February 2019, whereby the organisation evaluates potential suppliers before they enter the supply chain; and

  • reviewing its existing supply chains to be completed by 1 April 2019 whereby the organisation evaluates all existing suppliers.

 

Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action regarding the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and will be reviewed for each financial year.

 

Approval for this statement

This statement has been approved by the organisation's Board of directors, who will review and update it annually.

 

Director’s signature:

Director's Name: Steve Brown, Managing Director

Date: 20 February 2019

 

 

 

 

 

 

 

 

 

Always happy to help and advise - Email: sales@petproducts.co.uk  Tel: 0115 982 3900

 

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