MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE YEAR ENDED APRIL 2020
This statement is made in accordance with section 54 of the Modern Slavery Act 2015.
Social responsibility is treated very seriously at the Hemingways Group of Companies and we always conduct our business in accordance with our core values of integrity, respect, commitment and innovation. We recognise that as a growing business with multiple supply chains, and activities in numerous different countries, we need to be aware of the issues related to modern slavery and proactively act to ensure that slavery and human trafficking are not present in our business or supply chain.
OUR GROUP’S ORGANISATIONAL STRUCTURE
Hemingways Marketing Services is an independent, privately-owned company that provides a range of services, most often in the field of e-commerce, to numerous retail brands and manufacturers. In addition we sell products such as branded confectionery and retail gift cards and digital codes direct to consumers and corporate clients.
This statement is made on behalf of the following group operations and companies:
Hemingways Marketing Services Ltd
Hemingways Group Holdings Ltd
Cadbury Gifts Direct
Hemingways procures a wide range of goods and services from a variety of suppliers. Our supply chains currently support the following activities:
Product for resale including gift cards, digital codes, gift vouchers, confectionery.
Printing and packaging including stationery supplies
Distribution and logistics services
Warehouse equipment, storage and processing equipment
Technology services including hosting, data security, technical environment, processing software.
Recruitment and training
Advertising and marketing
Business process outsourcing, eg payroll
Hemingways has adopted a risk-based approach to the assessment of our business and supply chain, which has involved taking geographical, industry and market factors into account in order to identify categories of supply that may present a higher risk of modern slavery being present.
ACTIONS TO ADDRESS RISK
In most cases, Hemingways works with companies accredited by our partner companies who regulate and enforce their own regimes of regular compliance audits and who have contractual commitments to comply with applicable laws and regulations. A good example of this would be our supply of printed packaging and distribution materials to support our confectionery activities. In this instance we source directly from print companies accredited and regulated by Cadbury owner, Mondelez International.
Elsewhere the company utilises the services of companies regarded as ‘blue-chip’ or best in class and who correspondingly are subject to continuous regulatory assessment. A good example would be the use of DPD logistics and Royal Mail Group as distributors of both confectionery and pre-paid products such as gift cards.
Supply lines that fall outside of these channels are monitored by Hemingways and as part of our initiative to identify and mitigate risk we have undertaken, or are in the process of undertaking, the following actions:
Including obligations in our supplier on-boarding forms and terms and conditions, that cover modern slavery legislation.
Conduct briefings and awareness training amongst staff, particularly those responsible for sourcing and on-boarding new suppliers, to cover an assessment of the slavery and trafficking risk in our supplier sourcing process.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
To this end responsibility for the systems and methods deployed by Hemingways to ensure that slavery and human trafficking is not involved in our supply chains is held at director level and included for review at Board meetings involving consultation with legal, HR, and procurement departments.
This statement has been approved by the Board of Directors of Hemingways Group Holdings Ltd and Hemingways Marketing Services Ltd.
Signed: Andrew Johnson, Group Managing Director : June 2020