MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
Introduction
Modern slavery is a heinous crime and a
morally reprehensible act that deprives a person's liberty and dignity for
another person's gain. It is a real problem for millions of people around the
world, including many in developed countries, who are being kept and exploited
in various forms of slavery. Every company is at risk of being involved in this
crime through its own operations and its supply chain.
Zeus (the
“Company”) acknowledges the provisions of the modern slavery act 2015 and will
ensure transparency within the organisation and with suppliers of goods and
services to the organisation. The Company is satisfied from its own due
diligence that there is no evidence of any act of modern-day slavery or human
trafficking within our own organisation.
As part of the Company’s due diligence processes into
slavery and human trafficking, the supplier
approval process
incorporates a statement of compliance.
Zeus
have a zero-tolerance approach to modern slavery and are fully committed to
preventing slavery and human trafficking in our operation and supply chain. We
have taken concrete steps to tackle modern slavery, as outlined in our
statement. This statement sets out the actions that we have taken to understand
all potential modern slavery risks related to our business, and to implement
steps to prevent slavery and human trafficking during the financial year 2020.
Our business and supply chains
Zeus
Provides a one stop shop for all your packaging supply needs in the UK as well
as Ireland and various locations around the world inside and outside of the EU
We
establish a relationship of trust and integrity with all our approved
suppliers, which is built upon mutually beneficial factors. Our supplier
selection and on-boarding procedure includes due diligence of the supplier's
reputation, respect for the law, compliance with health, safety and
environmental standards, and references.
We
haven't been made aware of any allegations of human trafficking/slavery
activities against any of our suppliers, but if we were, then we would act
immediately against the supplier and report it to the authorities.
Policies
Zeus operates the following policies for identifying and preventing
slavery and human trafficking in our operations:
·
Whistleblowing Policy - we
encourage all employees, customers and suppliers to report any suspicion of
slavery or human trafficking without fear of
retaliation.
·
We provide an open door policy
to protect the identity of the whistle-blowers.
·
Code of Conduct - our code
encourages employees to do the right thing by clearly stating the actions and
behaviour expected of them when representing the business. We strive to
maintain the highest standards of employee conduct and ethical behaviour when
operating abroad and managing our supply chain.
·
Purchasing Code - we have
updated our approved supplier SAQ to make explicit reference to slavery and
human trafficking.
Supplier due
diligence
Zeus
conducts due diligence on all new suppliers during on-boarding and on existing
suppliers at regular intervals. This includes:
·
Assessing risks in the
provision of particular services
·
Auditing the suppliers, and
their health and safety standards.
·
Requiring improvements to
substandard employment practices.
·
Sanctioning suppliers that fail
to improve their performance in line with our requirements
We require all
suppliers to attest that:
·
They don't use any form of
forced, compulsory or slave labour
·
Their employees work
voluntarily and are entitled to leave work
·
They provide each employee with
an employment contract that contains a reasonable notice period for terminating
their employment
·
They don't require employees to
post a deposit/bond and don't withhold their salaries for any reasons
·
They don't require employees to
surrender their passports or work permits as a condition of employment
Business Awareness
To ensure a high level of
understanding of the risks of modern slavery and human trafficking in our
supply chains and our business, we deliver awareness training to all employees,
publish our Modern Slavery Policy on the staff intranet, and send regular
communications to our staff on business ethics.
Training In addition to the awareness program
Zeus has given advice to staff on:
·
Various forms of modern slavery
in which people can be held and exploited
·
The size of the problem and the
risk to our organisation
·
How employees can identify the
signs of slavery and human trafficking, including unrealistically low prices
·
How employees should respond if
they suspect slavery or human trafficking
·
How suppliers can escalate
potential slavery or human trafficking issues to the relevant people within
their own organisation
·
What external help is available
for the victims of slavery
·
What terms and guidance should
be provided to suppliers in relation to slavery policies and controls
·
What steps Zeus will take if a
supplier fails to implement anti-slavery policies or controls
This
statement has been authorised by the board and covers the financial year
01.01.2022 to 31.12.2022