MODERN SLAVERY POLICY

Introduction


This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that St Austell Brewery Company Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour and St Austell Brewery Company has a zero tolerance approach to any of these practices. We are committed to acting 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 our business or supply chain and which allow us to deliver financial success whilst conducting our business strategy and operations in a responsible manner.

 

Our business


Founded in 1851 by Cornishman Walter Hicks, today St Austell Brewery remains 100% independent and family owned. St Austell Brewery operates a growing and diverse business incorporating brewing a wide range of award winning beers sold throughout the UK and overseas, running a sizeable tenanted and managed estate along with supplying the hospitality and licensed sector throughout the South West via its wholesale and distribution business.

St Austell Brewery directly employs around 1300 to 1800 staff depending on the time of the year, servicing all areas of the business and with each sector and department headed up by a member of the Senior Management Team.

 

Our policies


We have adopted a Code of Conduct which sets out a number of principles with which we comply and with which we expect our suppliers to comply.  These include statements that all employees shall be free to choose their employment and shall not be forced to work against their will, strict provisions for any child under 16 years of age engaged in the workplace and a commitment to a safe working environment, terms and conditions no less than required by law, a work culture which promotes equality and respect and which allows for whistleblowing and freedom of association.

For our employees, failure to comply with the provisions of the Code may result in disciplinary action which could result in their immediate suspension or the termination of their employment.

In relation to our suppliers and sub- contractors, we believe that transparency is vital to a successful business relationship. St Austell Brewery Company is committed to building long-term relationships with suppliers and promotes open and honest communication.  In the event of non-compliance with our Code of Conduct we expect our suppliers to agree and commit to timely corrective action.  St Austell Brewery Company reserves the right to terminate any agreements in line with any contractual obligations should a supplier be unable, for whatever reason, to comply with the Code or where a supplier shows repeated disregard for the its provisions . 

 

Our supply chain


Our supply chain includes in the region of 3,000 suppliers covering food and drink suppliers for our pubs, raw materials for our beers, as well as goods and services not for resale such as equipment used in our pubs, point of sale materials, IT equipment, utilities and waste services, contractors engaged in building and maintenance, marketing, advertising, recruitment and training and a wide range of other professional services.

Our suppliers vary enormously in terms of their size, structure and mode of operation and many of those will themselves be reliant on their own supply chain, potentially across many countries, in order to be able to supply relevant goods or services to us.

 

Our current and proposed due diligence


We have started work on establishing a range of due diligence processes to enable us to identify and assess potential risk areas in our business and our supply chain.

Our Code of Conduct now forms part of our contract with all new suppliers and they are required to confirm that no part of their business operations contradicts this policy through signing a Supplier Confirmation Form. We intend to communicate our Code and expectations in relation to it to our largest suppliers and those operating in what is commonly considered high risk industries over the coming months along with any other suppliers whose contracts are due for renewal. We anticipate that all suppliers will have been communicated to by the end of 2017.

Within our production, distribution, head office functions and managed pub estate we have optimum control of the work environment, including labour scheduling and pay rates, thus reducing the risks within our own business.  Nevertheless, training will be developed and delivered to appropriate individuals across the business to ensure that they are aware of the issues and able to assess the risks in their area of responsibility.  In respect to our tenanted estate, whilst these pubs are operated as independent businesses, we will nevertheless offer training and support to raise awareness and will require them all to commit and adhere to our Code of Conduct.

 

Monitoring our performance and effectiveness


We intend to regularly review our practices, processes and procedures both in relation to our own business operations and the way in which we engage with suppliers  to ensure we mitigate any risk of non- compliance with the Modern Slavery Act.

In the event of any report received from an employee, member of the public or authoritative body pertaining to a suspected breach of the Code by St Austell Brewery Company or one of its suppliers, the matter will be communicated to the Board, a full investigation launched and any necessary remedial action taken without undue delay.