The Group initially assessed its supply chain (including its business introducers) and determined that the risk of slavery, servitude, forced or compulsory labour and human trafficking in this area was low, due to the concentration of these suppliers in the UK and within industries generally considered low risk. This risk assessment remains valid.
During 2018 the Group has continued to follow processes applied since 2016 to assess areas of potential risk in relation to the Act. It identifies which of its suppliers could be considered to be in areas of greatest risk, and then contacts them together with the Group’s larger suppliers determined by invoicing cost, to ascertain whether they have appropriate procedures in place to combat modern slavery. The results of these exercises have not raised any concerns.
In addition to maintaining previously applied standard processes PBG has also recruited a Supply Chain Manager into a newly created role. This appointment has been made as part of the Group’s objective to ensure a consistent approach in the application of outsourcing and supplier management principles across its businesses.
Continued development of the outsourcing and supplier management framework are now managed by the Supply Chain Manager, reporting to the Operations Director, and operating within the governance structure outlined by the Group’s Operational Risk Committee.
The principles of the framework are intended to ensure that the Group continues to:
- identify, assess and monitor potential risk areas in our supply chains;
- mitigate the risk of slavery and human trafficking occurring in our supply chains; and
- protect whistleblowers.
In relation to the requirements of the Act, the objectives of the framework will:
- ensure that each supplier is assessed in respect of Modern Slavery at the point of contracting in order to determine whether the Group’s approach to monitoring that supplier’s compliance with the requirements of the Act should be at a high, medium, or low level;
- enable early identification of supply chain issues, including any relating to modern slavery; and
- ensure each supplier is monitored, in accordance with its risk assessment, throughout the cycle of the business relationship.