For the Financial Year ending 31 October 2022
Organisation Structure and Supply Chains
This statement sets out Wynnstay Group Plc and its subsidiary companies (“the Group”) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
A leading supplier of agricultural products, the Group is dedicated to providing a professional, reliable, and efficient service to a range of customers including farmers and rural dwellers across a wide trading area, currently limited to the UK. Committed to national growth, the Group conducts its activities ethically and with honesty and with integrity but recognises the potential for abuses to occur within extended supply chains and wishes to do all that it can to prevent modern slavery and human trafficking acts. The Board will not tolerate business relationships with organisations knowingly involved with such abuse.
This statement therefore sets out the Group’s approach to understanding the potential risks of such abuses, and the steps in place and to be implemented, to prevent modern slavery or human trafficking events occurring within its own business and associated supply chains. This statement relates to intentions and actions taken during the financial year, and to the future development of procedures for identifying risks and preventing abuses.
In accordance with Section 54 of the Modern Slavey Act 2015, the Board continues to seek adequate transparency within its own business units and direct supply chains to identify actual instances or risks of slavery or human trafficking. The Board has not currently extended efforts to identify such risks beyond the immediate direct supply chains due to resource and practical limitations, although dialogue on such matters continue with appropriate links in more complex supply arrangements.
Policies in Relation to Modern Slavery and Human Trafficking
The Group’s Modern Slavery Policy complies with the Act 2015 and incorporates a risk assessment protocol which identifies and assesses potential risk within the organisation. Appropriate investigative and auditing processes should a risk be identified, will be conducted immediately, as necessary and reported to the Board by the Operations & Procurement Director. Appropriate investigative and auditing processes commensurate to the scale of the enterprise and risk, are executed, as necessary.
The Group’s Whistleblowing Policy encourages all 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.
Due Dilligence Processes
The Wynnstay Board has committed to preventing modern slavery and human trafficking acts from its corporate activities, and to ensure that its national and international supply chains are free from such abuses. Where possible the organisation prefers to build long standing relationships with suppliers, where through a strengthening of trading commitments, we can make clear our expectations of business behaviour.
During the last year, the Group continued to review its primary trading partners with a view to identifying relationships where a risk may exist even if it had not been previously identified. During our reviews and engagements with suppliers, a categorisation process is used to risk assess the respective entity into low, medium or high risk for possible modern slavery or human trafficking concerns. Further investigation or research would be carried out into any entities classed as medium or high risk before commencing or continuing to trade with that entity. During the year, no relationships were identified as being in this these categories.
The Board also recognise that concerns about modern slavery are not just limited to the Group’s supply chains but may also be a risk within the Business’s own employment environment, and particularly with regard to temporary or agency staff use. The HR function continues to assess hiring practices and only approved agencies with appropriate employment due diligence processes have been used during the previous year.
Risk Assessment and Management
Standard trading conditions for all new relationships incorporate appropriate confirmations on these matters, with a view to normalising the consideration of modern slavery and human trafficking risks in the usual commercial contract terms for our business.
All suspected cases of modern slavery and human trafficking will be reported to the Operations and Procurement Director immediately following any concerns, and any such report will be investigated on a case-by-case basis, with appropriate remedial action taken immediately.
Key Performance Indicators to Measure Effectiveness of Steps Being Taken
A system is in place whereby the supply chain verification process is completed prior to the supplier entering the companies supply chain and, the organisation continues to evaluate all existing suppliers for evidence of continued ethical trading behaviour.
Training on Modern Slavery and Trafficking
The organisation has identified appropriate colleagues requiring training on modern slavery who are provided with sufficient training where appropriate, enabling them to identify risk and ensure the expectations of the procurement policy and its associated processes are understood at all levels across the Business.
Modern slavery is a pernicious crime that targets the most vulnerable and preys on the weak, and the Board wants to see it irradicated from our industry as a whole, both from an ethical perspective as well as ensuring a fair competitive playing field.
This statement has been approved by the Company's Board of Directors, who have assessed that current risks with regard to modern slavery and human trafficking abuse within the business and its direct supply chain is low due to the nature of its continued operations.
Group Finance Director
Wynnstay Group PLC
28 February 2023