Slavery and Human Trafficking Statement

POL 047 Slavery Policy and Human Trafficking

This statement has been published in accordance with the modern Slavery Act 2015 and sets out the steps and activities taken by Robinson Young Ltd, and Holdings, to ensure that there is no slavery or human trafficking in its own business or supply chains. This statement relates to activities during the financial year 1^st April 2024 to 31^st March 2025.

As part of the distribution sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Our organisation is absolutely committed to preventing slavery and human trafficking in its activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Robinson Young Ltd (and Holdings):

Robinson Young is a UK dedicated large scale specialist distributor of non-food FMCG products. We provide a cost effective sales, marketing and distribution service for manufacturers from around the world of both branded and private label products for supply to multiple retailers, convenience stores, discount retailers, online retailers, pharmacies, wholesalers and food service operators across all key market channels. We are members of Sedex and also hold ISO 9001 and 14001 accreditation. We have a WDA(H) for the storage and distribution of MHRA products.

Countries of operation and supply

As a distributer, our products are sourced globally, currently from Asia, Australia, Europe and North America.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking;

Responsibility

Responsibility for the organisations anti-slavery initiatives are as follows;

Policies – The HR team along with key internal stakeholders, particularly the technical and quality team, will ensure that existing and any new legislation introduced is adhered to as and when necessary.
Risk Assessments – A Supplier Audit Questionnaire (SAQ), incorporating questions relating to slavery & human trafficking, is completed and reviewed for every new supplier to identify any risks before we incorporate the supplier into our supply chain.
Investigations/due diligence – The HR team, along with the relevant internal support, are responsible for carrying out any investigations in relation to human trafficking or slavery.
Training – Key stakeholders will attend any relevant training activities, as part of ‘Stronger Together’ or as identified.

Relevant Policies

Robinson Young operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing Policy – The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can bring this to the attention of Senior Managers or the HR Manager
Employee code of conduct – The organisations handbook and policies make it clear to employees the behaviours and actions of them we expect when representing our company. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating either inside or outside the UK and its supply chain
Supplier/Procurement code of conduct – The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship. As an organisation we follow stringent checks using our internal SAQ process and verification of ethical compliance with SEDEX if applicable
Recruitment/Agency Workers Policy – The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. The organisation ensures that any recruitment of temporary or permanent employees follows UK legislation. All applicants/candidates are asked to provide evidence of eligibility to work in the UK

Due diligence

Robinson Young commits to developing and adopting a proactive approach to tackling hidden labour exploitation.

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include;

Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
Evaluating the modern slavery and human trafficking risks of each new supplier
Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping
ensuring completion of our supplier audit questionnaire (SAQ) and any other assessments with new and existing suppliers, which have a greater degree of focus on slavery and human trafficking where general risks are identified. This supplier SAQ is given to all our suppliers to complete as an integral part of the Supplier Approval Process and renewed every 3 years, or sooner if there are any changes to the production facility or processes, or if a new facility is utilised
Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking – in particular participation in “Stronger together” initiatives
Using SEDEX database where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular
Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship
Requiring labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with legislation
Adopting a proactive approach to reporting suspicions of hidden worker exploitation to the Gang masters Licensing Authority and police

Performance indicators

The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation;

Has a system for supply chain verification in place, whereby the organisation evaluates potential suppliers before they enter the supply chain
Continues to review existing suppliers, on an annual basis reviewing SMETA or BSCI (Business Social Compliance Initiative) ethical audit and compliance report data
New employees who join the company are required to complete a ‘modern slavery & human trafficking’ questionnaire

Training and Raising Awareness

As well as highlighting risks to company employees, the organisation has raised awareness of modern slavery and human trafficking issues by;

Displaying various literature in key staffing areas around the company premises which highlights how employees can raise concerns and what external help is available such as the modern slavery helpline or Gang masters and Labour Abuse Authority
Employees participate on Webinars, podcasts or any on line training relating to modern slavery and human trafficking that is applicable
Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility, along with HR, for developing and operating company procedures relevant to this issue

This statement was approved on 29^th May 2024 by the organisation’s Managing Director, who reviews and updates it annually.

Managing Director Name: Kevin Sperling

Date: 29/05/24

Managing Directors Signature: