Shotton Mill Slavery and Human Trafficking Statement (Nov 2023)
This slavery and human trafficking statement (“Statement”) has been issued by Shotton Mill Limited and pursuant to Section 54 of the Modern Slavery Act 2015. The Statement has been adopted by the Board of Directors. The Statement describes the steps taken during the financial year 2022 to ensure that slavery and human trafficking are not taking place in Shotton Mills business or supply chains. Shotton Mill Limited changed ownership during 2021, so 2022 was the first year that a statement has been produced outside of its former parent company. Shotton Mill Limited will endeavour to continuously improve in this area as its business develops.
Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, human trafficking, and Child Labour all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Shotton Mill Limited has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships. Shotton Mill Limited is committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our own business or in any of our supply chains.
Shotton Mill Limited recognises the power imbalances between adults and children and thus the particular vulnerability of children to modern slavery. In accordance with the conventions of the ILO, the exploitation of child labour is totally unacceptable under any circumstances. As such, the following commitments are established within SML’s Anti-Modern Slavery Policy statement with respect to the use of child labour, including within Shotton Mill’s supply chain.
- No persons under the age of 16 shall be employed by Shotton Mill Limited, contractors, or suppliers, including in countries where the minimum legal working age is below 16 years.
- No persons under the age of 18 will be employed in work that is potentially hazardous, as defined by ILO Convention No. 182 on the Worst Forms of Child Labour. Risk assessments will be performed for all employees aged 16 to 18 and all relevant national legal limitations will be followed as per our Young Workers Policy which also stipulates that no Young Person under the age of 18 will be employed at night.
- Shotton Mill Limited expects contractors or suppliers to have appropriate management systems in place to ensure that child labour is not employed directly or indirectly by one of its partners. Due diligence may be undertaken of contractors or suppliers to verify that this is the case as part of the contracting process.
- Monitoring of contractors and suppliers may be performed by Shotton Mill Limited to verify compliance with the requirements of this Policy Statement. If Shotton Mill suspects or identifies evidence of the use of child labour, Shotton Mill Limited reserves the right to suspend business relations with the relevant entity and undertake investigations to confirm that the entity is acting in accordance with the requirements. Shotton Mill Limited further reserves the right to terminate business relations (if such suspicions or evidence is confirmed).
Shotton Mill Limitedare dedicated to ensuring there is transparency in our own business and in our approach to tackling modern slavery and child labour throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We also expect the same high standards from all our contractors, suppliers, and other business partners.
This policy applies to all persons working for us or on behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
This policy does not form part of any employee’s contract of employment and Shotton Mill Limited may amend it at any time.
Responsibility for the Policy
Shotton Mill Limited has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
Shotton Mill Limited has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery and child labour.
Compliance with the Policy
All employees are responsible to ensure they read, understand, and comply with this policy.
The prevention, detection, and reporting of modern slavery and child labour in any part of the business or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. Employees must notify their line manager or HR as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.
Employees are encouraged to raise concerns about any issue or suspicion of modern slavery or child labour in any parts of the business or supply chains of any supplier tier at the earliest possible stage. If employees believe or suspect a breach of this policy has occurred or that is may occur, they must notify their line manager, HR or report it in accordance with our Whistleblowing policy as soon as possible.
Employees should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own businesses and supply chains.
If employees are unsure about whether a particular act, the treatment of workers more generally or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or HR.
Shotton Mill Limited aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment because of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.
Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If employees believe they have suffered such treatment, they should raise the concern with their line manager or HR. If necessary, raise the concern in-line with Shotton Mill Limited. Grievance Policy.
Our Disciplinary and Grievance Procedures
Details of the Shotton Mill Limited grievance and disciplinary policies and procedures can be found via HR. This includes with whom an employee should raise a grievance – usually their line manager.
Use of the Shotton Mill ’s grievance or disciplinary procedures does not affect an employee’s right to make a claim to an employment tribunal within three months of the alleged discrimination.