mila-ai4h/AIMS.au huggingface dataset:
[SID_544] To ensure that modern slavery does not exist within SGNs own direct operations, SGN undertakes a robust approach in our recruitment processes, ensuring that all employees within SGN have the appropriate rights to work in the UK
[SID_544] The UK Governments right to work checklist outlines simple right to work checks to be conducted before an individual is employed and this is strictly adhered to by SGN
[SID_544] Following this guarantees that the right to work is evidenced for all direct workers and relevant verification and vetting checks are carried out
[SID_544] Further to this, all new and existing employees are subject to prescribed right to work checks to ensure that SGN does not employ illegal workers thereby ensuring compliance with UK immigration laws and regulations
[SID_544] SGNs Vetting and Verification procedure provides details on what levels of checks are carried out as standard and the expectation is set that contractors and staffing agencies are subject to the same standards
[SID_544] Living Wage
[SID_544] In addition, all staff directly employed by SGN are paid the Living Wage or above and in 2020 SGN achieved the goal of becoming an accredited Living Wage employer through the Living Wage Foundation
[SID_544] SGNs commitment to paying the Living Wage and its accreditation as a Living Wage employer includes no unlawful deductions of wages or working extended periods of time without breaks
[SID_544] Procurement
[SID_544] SGN issue our Sustainable Procurement Code to all current suppliers
[SID_544] This is clear that we expect all our suppliers to respect basic human rights as established by the European Convention on Human Rights, and to adhere to legislation against child labour, forced labour, modern slavery, and discrimination
[SID_544] Supporting this expectation, our procurement contracts contain two clauses to mitigate the risk of modern slavery and hold suppliers accountable for ensuring they are taking appropriate action
[SID_544] Public document 6
[SID_544] Our modern slavery clause is included in all new goods, works and services contracts and requires that the service provider (and procure that its supply chain) shall comply with modern slavery legislation and take all reasonable steps to ensure that slavery and human trafficking are not taking place in its business or its supply chain
[SID_544] Our living wage clause is included in all new works and services contracts and requires that the service provider agrees to pay all its directly employed personnel (in respect of the services) not less than the living wage and ensure all employees of its contractors and subcontractors performing the services are paid not less than the living wage
[SID_544] In addition to the above, our onboarding process and annual assurance checks include validation that a Modern Slavery Statement is published by all vendors who meet the threshold for publishing a Modern Slavery Statement
[SID_544] Speak Up
[SID_544] SGN has a Speak Up (Whistleblowing) Policy whereby SGN employees or those working on our behalf can raise concerns in confidence about wrongdoing through both internal and external mechanisms
[SID_544] Within the Policy we specifically encourage reporting on slavery and human trafficking, as well as other ethical matters
[SID_544] If an individual would prefer not to raise their concern with an SGN manager or HR, then they can use SGNs Speak Up Hotline or directly contact one of the key contacts outlined in the Policy
[SID_544] When incidents are reported, they are referred to SGNs Compliance team (and Safety team if applicable) for investigation with outcomes reported and fed back through our Ethics and Compliance Committee to the Audit Committee
[SID_544] Public document 7
[SID_544] Classified as Internal 4 Training on Slavery and Human Trafficking Modern Slavery is included within our Compliance Training Strategy and SGN is partnered with the Supply Chain Sustainability which provides high quality training and resources on various topics, including modern slavery
[SID_544] In 2023/24 we implemented risk-based training internally to 4,580 of our people to help them to understand and identify the risks of modern slavery as part of an ongoing training programme
[SID_544] Modern Slavery training forms part of our mandatory compliance training package for all new starters
[SID_544] Across the compliance area of Modern Slavery, we have delivered a total of 3,879 training completions to date
[SID_544] We run on a two-year cycle and in 2022/23, all high-risk groups had F2F / Teams training
[SID_544] The training educates employees on the issues and risks surrounding modern slavery and what to do if they suspect that modern slavery is happening internally or within our supply chain
[SID_544] The training programme is risk based and includes enhanced training material for our Procurement and Supply Chain (P&SC) and Human Resources colleagues
[SID_544] For example, our training for P&SC professionals highlights the obligations that the P&SC function must explore, alongside areas of expenditure that represent a higher risk of modern slavery
[SID_544] Public document 8
[SID_544] Classified as Internal 5 Due Diligence and Risk Assessment Processes In terms of managing the risk of modern slavery existing within our supply chain, SGN operates several mechanisms to deter this from occurring
[SID_544] Supplier Registration
[SID_544] All suppliers are required to register on to our Supplier Registration System (SRS), which is externally managed by Achilles Information Ltd (Achilles)
[SID_544] This informs SGN that suppliers are committed to our core values and objectives
[SID_544] The suppliers who intend to tender for regulated procurement activity through the Achilles database are also required to register on the Utilities Vendor Database (UVDB), which is a utility industry pre-qualification system widely used across the UK and EU
[SID_544] UVDB is also operated by Achilles, who conduct independent audits of certain suppliers registered on the system against the information they have provided in the questionnaire
[SID_544] The use of the UVDB ensures that the highest standards of supply chain assurance are achieved
[SID_544] Our pre-qualification (PQQ) template includes robust questions on modern slavery for potential suppliers, which are consistent with the questions being asked by others in the utility sector
[SID_544] The Procurement function is supported by a centralised Standards and Assurance team who manage several audits which cover modern slavery compliance from time to time
[SID_544] Supplier Engagement
[SID_544] We have now engaged with those suppliers which represent the top 80% of our annual spend specifically on modern slavery and confirmed 97% of those suppliers comply with our requirement to publish a Modern Slavery Statement, indicating the measures they have in place to manage this risk
[SID_544] Through continuous engagement with our suppliers and issuing our Sustainable Procurement Code, we are striving to hold our entire supply chain to the same high standards, regardless of the type of supplier/operation and country of operation
[SID_544] Public document 9
[SID_544] Classified as Internal 6 Ongoing Commitment SGN understands that we have a responsibility to continue to assess and mitigate the risk of modern slavery in the long-term and we fully intend to do so
[SID_544] As part of our commitment to continual improvement we achieved several of our objectives for 2023/24, including
[SID_544] Continued to invite suppliers to participate in the Supply Chain Sustainability School
[SID_544] The school provides thousands of learning resources on all aspects of sustainability, which our suppliers can access for free
[SID_544] Implemented awareness training for all SGN employees
[SID_544] In 2024/2025 we aim to progress with the following activities
[SID_544] Further review the nature of the risk of modern slavery within SGN and our supply chain
[SID_544] Review the current controls in place to manage these risks and put plans in place to improve these, if necessary
[SID_544] Engage further with suppliers, to develop targets and agree specific steps expected towards a transition to achieve sustainability goals
[SID_544] Develop our broader Environmental, Social and Governance (ESG) reporting to align further with the World Economic Forum (WEF) framework, which includes the following metric/disclosure: Risk for incidents of child, forced or compulsory labour
[SID_544] An explanation of the operations and suppliers considered to have significant risk for incidents of child labour, forced or compulsory labour
[SID_544] Such risks could emerge in relation to a) type of operation (such as manufacturing plant) and type of supplier; and b) countries or geographic areas with operations and suppliers considered at risk
[SID_544] Conduct risk-based assurance activity to ensure that our joint ventures comply with the provisions of the Modern Slavery Act and take all reasonable steps to ensure that slavery and human trafficking are not taking place in their business or supply chain
[SID_544] Public document 10
[SID_544] Classified as Internal 7 Governance Framework The SGN Board has reviewed and signed off this Statement
[SID_544] The Board will continue to annually review and sign off SGNs Modern Slavery Statement
[SID_544] Modern Slavery falls under SGNs Principal Risk Legal and Regulatory Compliance
[SID_544] Modern Slavery is included within the Legal Services, HR and Procurement and Supply Chain Operational Risk Registers and is considered at regular Operational Register Review meetings
[SID_544] This statement was approved by the SGN Board of Directors on 25 September 2024
[SID_544] SIGNATURE
[SID_544] Nicola Graham-Shand Chief Legal Officer and SGN Group Company Secretary Date: 25 September 2024
[SID_545] MODERN SLAVERY ACT 2015 Statement of compliance for the year to 31 December 2023 This statement is made pursuant to section 54, Part 6 of the Modern Slavery Act 2015 (the Act) and is published on behalf of Camellia Plc ("the Company")
[SID_545] This statement sets out the steps the Company has taken to prevent modern slavery and human trafficking in its supply chains as well as commenting on steps being taken by the operating companies in which it is invested
[SID_545] OVERVIEW The Company is the ultimate holding company of a diverse group of companies (the Group)
[SID_545] Within the Group, the Company has interests in several agricultural, engineering and food service companies ("the Operations"), as well as other investments
[SID_545] The Operations are in Bangladesh, Brazil, India, Kenya, Malawi, South Africa, Tanzania and the UK
[SID_545] The majority of the Groups turnover is derived from the Operations in the agricultural sector through the growing of tea, avocado, macadamia, apples, pears, cherries, plums, rubber, wine grapes, blueberries, arable crops, forestry and the raising of cattle
[SID_545] The agricultural Operations have the greatest exposure to risk of modern slavery and human trafficking
[SID_545] The Operations are fundamentally connected to the welfare of the communities and the environments in which they operate
[SID_545] Consistent with the Group's long-standing commitment to high legal and ethical standards, the Operations prohibit slavery, human trafficking or forced labour in any form in their businesses
[SID_545] It is recognised that modern slavery exists in many different forms and can be difficult to detect, particularly in the supply chain
[SID_545] The agricultural Operations have substantial undertakings in the UK, India, Bangladesh, Brazil, Kenya, Malawi, Tanzania and South Africa
[SID_545] As is common in the sector, it is necessary to employ a large number of seasonal employees to harvest, process and transport crops at peak times
[SID_545] The Operations pay wages, benefits and allowances in accordance with local legislation and Trade Union agreements
[SID_545] The Operations have received and maintain certifications with challenging ethical standards from, inter alia, Fairtrade, WIETA, SMETA-ETI and Rainforest Alliance which require detailed audits of employment practices in the Operations and of key suppliers
[SID_545] Responsibility for legal and ethical compliance is devolved to the leadership of each of the Operations
[SID_545] Ultimately, the individual Operations have the local experts who are best
[SID_545] placed to identify relevant needs and apply the processes and practices that allow them to operate responsibly and ethically over the long term
[SID_545] TRAINING The Company has undertaken and continues training of its directors and relevant employees
[SID_545] Likewise, the Operations have undertaken and continue training of their relevant employees to raise awareness of the Act and assist in identifying risks in their given businesses and the supply chains
[SID_545] The Operations look to work with their tier one suppliers and some tier two suppliers in managing these risks
[SID_545] To date, no concerns have been identified
[SID_545] SUPPLY CHAIN RISKS The Company itself has only limited direct supply chains which are predominantly in the UK
[SID_545] The goods and services the Company purchases to deliver its services primarily relate to information technology, professional services, travel, catering, property, facility management and maintenance
[SID_545] The Operations in which the Company has interests have more involved local supply chains
[SID_545] The majority of the tier one suppliers for the agricultural operations are outgrowers and smallholders
[SID_545] The agricultural operations purchase product from these growers at a market related price which they then process, pack and sell via their own channels to market
[SID_545] The Operations have set up programs to support local outgrowers and smallholders to help them with their farms and crops
[SID_545] All product purchased is paid for in a timely manner
[SID_545] Operations also provide advice to these farmers on how to improve yields and adopt sustainable cultivation practices
[SID_545] These efforts have been beneficial both to the farmers and the Group over recent years through achieving increased volumes and quality
[SID_545] Operations have also undertaken training within their outgrower and smallholder groups on the provisions of the Act and will continue this process
[SID_545] Some of the tea smallholders are Fairtrade and Rainforest Alliance certified
[SID_545] Where applicable, the Operations will undertake risk assessments on their other major tier one and two suppliers in 2024
[SID_545] SUPPLY CHAIN STANDARDS The ethos of the Group is very clear whereby the Operations consider themselves as custodians of their assets and businesses, respecting the local laws and the environment
[SID_545] in which they operate
[SID_545] In that context, the Operations continue their efforts to grow and nurture their businesses in a sustainable way with respect for human rights as defined by the UN Guiding Principles on Business and Human Rights, the environment and the wider communities in which they operate
[SID_545] The Operations' relationships with their suppliers have their roots firmly embedded in this ethos
[SID_545] Respecting human rights and environmental issues in the supply chain is ultimately a suppliers responsibility
[SID_545] However, as customers, the Operations play an active role in supplier development and communicate these expectations
[SID_545] Whilst neither the Company nor the Group can guarantee that these supply chains are completely free of slavery, human trafficking or forced labour, we believe that the steps being taken by the Operations will give greater visibility of the employment practices of the supply chain network which in turn will allow the Company to ensure compliance with the Act
[SID_545] IMPLEMENTATION The Company will continue to oversee the implementation and monitoring of the Companys compliance with the Act
[SID_545] The leadership of the individual Operations will take responsibility for managing slavery and human trafficking risks in their jurisdictions
[SID_545] The Company's MSA statement will be posted on both the Business and Human Rights Resource Centre and Transparency in Supply Chains MSA registries
[SID_545] The Company has also registered the nominated contact on the Home Office's Modern Slavery Contact Database
[SID_545] NEXT STEPS Further training of the Company's key personnel
[SID_545] Operations to undertake further risk assessments of the key tier two suppliers
[SID_545] In addition, agricultural operations to promote further training of the smallholders and outgrowers
[SID_545] BOARD APPROVAL This statement was approved by the Board of Camellia Plc on 25 April 2024
[SID_547] Modern Slavery Policy Page 1 of 2 IMS 1128.03 Publicly Available
[SID_547] POLICY STATEMENT Modern slavery is a crime and a violation of fundamental human rights
[SID_547] It takes various forms, such as slaver, 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
[SID_547] We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains
[SID_547] SUPPLY CHAIN Onnec Group is committed to ensuring transparency in our business and our approach to tackling modern slavery throughout our supply chains which is consistent with our disclosure obligations under the Modern Slavery Act 2015 (the Act)
[SID_547] We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their suppliers to the same high standards
[SID_547] Our company is made up of several limited company subsidiaries, supported by a central services function
[SID_547] As a provider of information technology and associated services we operate across largely regulated markets in the private and public sectors, primarily our employees work across our operations in the UK & Europe, with service provision across other continents such as Asia, Africa, North America, South America and Australia
[SID_547] This policy has been published on behalf of the above parent company and its subsidiaries
[SID_547] The policy applies to all persons working on behalf of Onnec Group or one of its subsidiaries 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
[SID_547] All goods and services procured go through a central team, which is responsible for assessing the suitability and any associated risk of suppliers and ensuring the relevant due diligence checks are conducted
[SID_547] Preferred suppliers are also highlighted on a purchasing platform and the procurement team within each subsidiary is responsible for maintaining awareness of preferred supplier relationships across the business
[SID_547] RESPONSIBILITY FOR THE POLICY The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it
[SID_547] The compliance team have 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 however ultimate responsibility for the implementation and compliance with this policy firmly remains with the CEO and board of directors
[SID_547] Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains
[SID_547] OUR POLICIES IN RELATION TO MODERN SLAVERY The following company policies support us in ensuring that modern slavery is not taking place in our supply chains or business
[SID_547] Equal Opportunities and Diversity Policy: Ensures appropriate procedures are in place to prevent any breaches to international human rights standards, including the United Nations Universal Declaration of Human Rights (UDHR), the International Labour Organisation (ILO) core conventions on Labour Rights, and the Act
[SID_547] Ethical Purchasing Policy: Sets out our strategic approach and the key principles and priorities that apply to all procurement activities, ensuring we have control over our supply chain and potential risks
[SID_547] The policy is complemented by our Ethical Code which sets out our expectations of suppliers in terms of ethical procurement, human rights and governance
[SID_547] It also details the due diligence and assessment is conducted on all suppliers ensuring compliance to relevant legislation
[SID_547] These policies apply to the Group and are available to all employees via our intranet site and website
[SID_547] The policies are managed by relevant functional heads, our company-wide risk management framework and reporting processes support the escalation of policy issues and the effective management of issues where identified in our business
[SID_547] COMPLIANCE WITH THE POLICY Employees must ensure they read, understand and comply with this policy
[SID_547] The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control
[SID_547] You are required to avoid any activity that might lead to, or suggest, a breach of this policy
[SID_547] You must therefore notify your manager, compliance team or the CEO as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future
[SID_547] You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage
[SID_547] If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible
[SID_547] Modern Slavery Policy Page 2 of 2 IMS 1128.03 Publicly Available
[SID_547] If you 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 manager or the compliance manager
[SID_547] We aim 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
[SID_547] We are committed to ensuring no one suffers any detrimental treatment as a result 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
[SID_547] COMMUNICATION AND AWARENESS OF THIS POLICY Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary
[SID_547] Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter
[SID_547] BREACHES OF THIS POLICY Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct
[SID_547] We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy