WWC SA is required, pursuant to the Modern Slavery Act 2015, to make and publish a statement about the steps we are taking to ensure that slavery and human trafficking is not taking place in any part of our own business and in any part of our supply chains.
Modern Slavery can take various forms, including slavery, servitude, forced and compulsory labour and human trafficking, 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.
Needless to say, we have a zero-tolerance approach to any such activity and we are committed to acting ethically and with integrity in all our business dealings and relationships.
We have a Slavery and Human Trafficking Policy and it will be mandatory for all members of our staff to familiarise themselves with this, and especially our Wine Buyer and all managers involved in hiring and procurement.
We are confident that, in our own business, there is no slavery or human trafficking taking place. Our internal systems, controls and hiring policies are sufficiently strong and robust to ensure this. We are also a small enough business that any evidence of this would be quickly spotted and dealt with.
We do, of course, trade with a wide range of different producers, suppliers and carriers, mostly outside the UK. We always try and ensure that all of these are reputable and carry on business to the same high standard as we do ourselves. We actively encourage them to do so. Our relationships, particularly with wine producers and suppliers, often go back many, many years. We are in regular contact with them.
We will be including an appropriate MSA clause into our Terms of Business for the Supply of Wines and Spirits and will produce model contract provisions, which we are intending, to the extent we are able, to include in all our contracts with producers, suppliers and contractors. These require the other party to ensure that no slavery or human trafficking is taking place in its business.
We have an informal programme of regular contact with suppliers, producers and trading partners and for the most significant of these we intend to assess the degree of risk in trading with each of them and conduct more formal audits as appropriate.
Also, as part of our Slavery and Human Trafficking Policy, all our staff will be encouraged to be aware of the possibility of slavery and human trafficking taking place and must notify one of the WWC SA Team as soon as possible if they believe or suspect, or have concerns, that slavery or human trafficking might be taking place in any part of our business or supply chain, even if they are unsure about whether a particular act, or any treatment of workers or their working conditions, might constitute it. Any such concerns will be investigated.
Will Hancock, July 2018