This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and outlines the practices that the applicable Williams Lea and Tag group of companies (the “Group”) have taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. This statement on slavery and human trafficking is made on behalf of the applicable companies within the Group for the financial year ending 31 December 2020. The corporate structure of the Group is illustrated in the attached schedule.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. the Group has a zero tolerance approach to any form of modern slavery. We are strongly committed to playing our part in eradicating modern slavery by ensuring we act ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
The Group is the leading provider of marketing and communications supply chain services. We help organizations transform business processes, enhance customer conversations and realize the potential of their brands. Our solutions combine re-engineered processes, leading technologies and highly experienced collaborative client teams. Our financial strength and global reach enable us to deliver these solutions anywhere in the world.
Our internal policies ensure that we are conducting business in an ethical and transparent manner, such as:
- Recruitment policy– This includes vetting, eligibility to work, safeguards our employees against human trafficking or individuals being forced to work against their will.
- Code of Conduct– Our code defines the objectives and rules that reflect our commitment to responsible, ethically irreproachable and legally compliant behavior from all employees and contractors.
- Whistleblowing policy– where there are concerns regarding any unethical conduct within our business, including any forms of modern slavery, we strongly encourage our employees to report the concern so we may properly and quickly resolve the situation. An external and independent whistleblowing hotline service operates 24 hours a days 365 days a year, across approximately 40 countries enabling our employees to report matters anonymously, without fear of reprisal and includes a translation service.
The Group works with a wide and varied network of suppliers to execute and support solutions that we design for our clients. Supplier due diligence is a critical part of what we provide for our clients and essential for the security and performance of our own business.
All suppliers to the Group must go through our due diligence process at the on-boarding stage and are then subject to regular audits and reviews. These audits are based on perceived risk (i.e. country of supplier, strategic importance of supplier, and handling of confidential data) with a tiered approach taken to ensure each supplier’s corporate social responsibilities are aligned with that of the Group and, most importantly, United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labour Organization Declaration on Fundamental Principles and Rights at Work in addition to full compliance with the UK legislation, including the Modern Slavery Act.
Our Supplier Code of Conduct sets the minimum standards for doing business with the Group, and we request is signed by each supplier as part of the onboarding process, with follow up to ensure our policies are adhered to. We also review supply chain contracts to ensure they contain the appropriate legislative requirements.
If we find breaches of our code and/or the Modern Slavery Act within our supply chain, we will investigate the issues in detail. Whilst we shall, of course look to support companies in their efforts to comply with the legislation, in the event of a serious breach, termination of the supplier relationship would also be considered.
Key Performance Indicators
We will know and understand the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
- Completing annual due diligence, where necessary, on our supplier’s code of conduct.
We will periodically review the effectiveness of our processes and systems and any changes will be reflected in future annual statements.
This Modern Slavery Statement was approved by the Board of Directors of Wertheimer UK Limited on behalf of Group on 6 July 2020.
Group Chief Executive Officer