Slavery and Human Trafficking Statement & Policy

Glen Grant Limited trading as Campari UK, is a manufacturer and supplier of spirits. We are part of Gruppo Campari worldwide and have offices in London (Level 27, The Shard,32 Londonbridge Street, London, SE1 9SG) and Scotland (Glen Grant Distillery, Elgin Road, Rothes, Banffshire, AB38 7BS) within the UK.

In compliance with the Modern Slavery Act 2015, Glent Grant Ltd offers the following statement regarding its efforts to prevent slavery and human trafficking in its supply chain:

OUR POLCIES ON SLAVERY AND HUMAN TRAFFICKING

Glen Grant Ltd is committed to social and environmental resonsibility and to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We recognise the responsibility to take a robust approach and is committed to maintaining and improving systems and processes to avoid complicty in human rights violations related to our own operations, our supply chain and our products.

We realise that slavery and human trafficking can occur in many forms, such as forced labour, child labour, domestic servitude, sex traffickig and workplace abuse.

Our Anti-slavery Policy reflects our commitment to acting ethicaly and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place in any of our supply chains.

We have a zero tolerance to slavery and human trafficking and we expect all those in our supply chain and contractors to comply with our values. We are committed to ensuring there is transparency in our own business and in our approach to tackle modern slavery throughout our supply chains, consistent with our disclosure obligations. We expect the same high standards from all our contractors, suppliers and other busienss partners. We expect that our suppliers in turn hold their own suppliers to the same high standards.

Many of our products have a basis in agricultural productions and may also engage high-volume production and logistics processes. We seek to sourche high value and high quality products and services and supply them to our customer base.

Training

It is mandatory for all members of staff to familiarise themselves with this statement and policy, escpecially for Directors, account managers and sales teams. It forms part of the induction process for new employees, trading partners and contractors. It is available in the languages relevant to our business.

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.

The company’s modern slavery training covers:

  • our business purchasing practices which influence supply chain conditions;
  • what initial steps should be taken if slavery or human trafficking is suspected and how to escalate to the relevant parties within the company;
  • what steps the company should take if trading partners do not implement anti-slavery policies, including their removal from the company’s supply chain.

Due diligence

We have a programme of regular contact with our trading partners and it is part of that programme to check, as far as possible, that our partners are similarly committed to good practices in relation to their workforce and contractors.

We have adopted and documented processes that will:

  1. Check the identity of our trading partners;
  2. Check the financial health of trading partners;
  3. Check the contract terms;
  4. Educate and train our own employees and contractors as well as encouraging our trading partners to do the same;
  5. Periodically review the practices adopted by trading partners.

It is integral to those processes that in each case we will assess how much information we need in order to justify the relationship or specific transaction:

  • When we receive information, we will, as far as possible, corss-check it with independent sources and analyse the effect of that information on the rist posed by the proposed arrangement.
  • We will identify trigger points that will lead to a review of trading arrangements, such as changes in key personnel or radical changes to the pattern of business within the trading partner.
  • We will take into account any available external evidence when considering whether a relationship or transaction is appropriate.

We aim to encourage openness and will support anyone who raises geniune concerns in good faith under this policy, even if they turn out to be mistaken. We are 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 the business or product supply chain.

Detrimental treatment include dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an employee believe they have suffered any such treatment, they should inform the HR Manager immediately. If the matter is not remedied, the employee should raise a formal grievance in line with the company Formal Grievance Procedure.

An employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

RELEVANT POLICIES

Glen Grant Ltd operates the following policies:

  • Whistleblowing policy
    We encourage all employees to report any concerns related to direct activities or supply chain of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The company’s whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
  • General Code of Conduct
    The company’s general code of conduct outlines in the employee handbook, clearly to all employees the actions and behaviour expected of them when representing the company. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our business and supply chain.

Glen Grant Ltd as part of the wider Gruppo Campari business also follows the following group policies:

  • Gruppo Campari Corporate Social Responsibility
  • Gruppo Campari Code of Ethics
  • Gruppo Campari Business Conduct Guidelines

This statement and policy is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Glen Grant Ltd’s slavery and human trafficking statement for the current financial year.

This statement and policy will be reviewed and updated annually.


Pietro Mattioni
Managing Director
Glen Grant Ltd

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Last updated Feb 01 2017