Rowan International Ltd Modern slavery statement 2021

Modern slavery is a term used to describe slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking.  Human trafficking is the arrangement or facilitation of the travel of another person with a view to exploit that person. Modern slavery is a crime and a violation of fundamental human rights

We are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our company or in any of our supply chains. We expect that our customers and suppliers hold their own suppliers to these same high standards.

This policy applies to all people working for us or on our behalf in any capacity, including suppliers and agencies.  We strictly prohibit the use of modern slavery and human trafficking in our operations and supply chain.

Company structure and supply chains

We buy and sell residual stock products that include confectionary, snacking, personal care and household products from manufacturers in the UK and across Europe.  Our customers are based in both the UK and across 26 countries, primarily in Europe.  We have approximately 50 registered suppliers and 300 registered customers.

We employee 51 people, 2 being overseas in Europe, the remaining based in Essex or working from home.  We sometimes utilise agency workers to support our warehouse operation and we work with external transport companies to transport products to our warehouse and to our customers. 

We expect everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• A zero-tolerance approach to modern slavery
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain. employees must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy
• Identify the risk of modern slavery in our operations and supply chain as well as during our contracting process

Our policies

To ensure we raise awareness of modern slavery and responsibilities to prevent it amongst our colleagues, we have the following internal policies:

• Code of conduct that includes how we expect colleagues to behave towards each other and outside agencies whilst at work and the requirement to obey the law. This policy also encourages colleagues to speak up about anything they experience or hear that concerns them
• Raising concerns including whistleblowing policy that covers reporting criminal acts, non-compliance with legal obligations, health and safety breaches or modern slavery concerns.
• Health and safety policy that sets responsibilities on working safely and to take care of the safety of others who may be affected by what we do or fail to do
• Our Equality statement that shares our commitment and expectations of promoting fairness and inclusion throughout the company, so our working practises and culture is respectful and encouraging of everyone, so they can give their best.

These policies form part of our employee handbook which is sent to all new starters and is available for current colleagues via our company intranet and information drives.

We plan over the next 12 months to review our internal policies and update our employee handbook where relevant, to include anti-modern slavery commitments and responsibilities.

Due diligence processes

As part of our due diligence processes with new suppliers we commit over the next 12 months to introduce checks to ensure they have undertaken commitments to prevent modern slavery as part of their manufacturing and supply of products. 

In addition, over the next 12 months we commit to checking that new third party organisations (recruitment agencies, contractors, most frequently used logistics companies) have a commitment in place to prevent modern slavery

To ensure our existing external partners are meeting their anti-modern slavery responsibilities, we commit to undertaking an annual review of our top 10 customers, suppliers and hauliers, to ensure they have publicly shared their actions against modern slavery.  We will also check that they have modern slavery statements published on the Modern Slavery Registry.

Risk assessment and management

We commit to acting transparently and disclosing information about any modern slavery risks we have identified and what actions we have taken in response to them. 

We will prioritise our actions on areas where we believe they will have the most impact and will have annual meetings to ensure risks are reviewed and progressed against.

We understand that preventing modern slavery is an ongoing, evolving process and we commit to developing KPIs to measure the effectiveness of our due diligence procedures in preventing risks appearing in our operations and supply chains.

Training on modern slavery and trafficking

Over the next 12 months we will make modern slavery and trafficking awareness training available for all of our colleagues so they are informed of how to identify modern slavery and what action they can take to share their concerns.

The responsible officer for ensuring compliance with our Modern Slavery statement is Mellissa Humphrys, People Director.  The Board of Directors have reviewed and approved this statement on (date)

Signed by Mellissa Humphrys, People Director