Modern Slavery (Anti-Slavery and Human Trafficking) Policy

As a family owned business, Scotts of Thrapston Ltd has a strong tradition of doing business in a responsible way, and we therefore acknowledge our responsibilities under the Modern Slavery Act 2015.

Policy purpose / statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as 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.

Scotts of Thrapston has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings, relationships and to implement / enforce effective systems. Control systems are put in place to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

The Company is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners. 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 own suppliers to the same high standards.

Scope / to whom this policy applies

This policy applies to all persons working for the Company or on our behalf in any capacity, including employees at all levels, directors, agency workers, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and Scotts of Thrapston may amend it at any time.

Compliance, due diligence and audit

In accordance with the Timber Trade Federations Responsibly Purchasing Policy (RPP) we have taken steps to ensure that all timber and timber products supplied are in accordance with EU Timber Regulations.

PEFC and FSC standard certification schemes support international conventions to eliminate all forms of forced or compulsory labour, the abolition of child labour and the elimination of discrimination in respect of employment and occupation. We audit our supply chain to ensure they meet the requirements for the chain of custody management systems on an annual basis

Risk assessments

We have reviewed the country of source for all suppliers from 2019 and identified any new suppliers, new products or new supply routes.

We have a process of supplier audits in place for high risk areas of which labour contracts, working conditions, evidence of child labour and working hours are key components.

Related policies

All Company polices and training packs have been modified to confirm compliance with the Modern Slavery Act 2015 including:

• Whistleblowing policy
• Recruitment policy
• Equal Opportunities policy
• Compliance with this policy

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. All staff are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If they believe or suspect a breach of this policy has occurred, or that it may occur, they must notify management or the Legal and Compliance Director, or may report it in accordance with Scotts Whistleblowing Policy as soon as possible.
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. Scotts of Thrapston is 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 business or in any of our supply chains.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

Communication and awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary. 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.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Scotts of Thrapston may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.