Slavery and Human Trafficking Statement
Slavery and Human Trafficking Statement of SGS United Kingdom Limited and its UK affiliates (“SGS United Kingdom”) for the financial year ending 31 December 2017.
This statement updates our first Modern Slavery Statement published in June 2017. It sets out what SGS United Kingdom has done in 2017 to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. It also sets out our current plans for 2018.
Group Structure and Business
SGS is the world’s leading inspection, verification, testing and certification company. With more than 95,000 employees, SGS operates a network of over 2,400 offices and laboratories around the world helping to ensure quality and integrity of products and systems. The Group also provides some employment agency services.
SGS SA is the ultimate parent company of SGS United Kingdom and the SGS Group.
The SGS Group has recently published the SGS 2017 Sustainability Report, which reports on the environmental and societal impacts of our business activities using our innovative Value to Society (V2S) model. Our Sustainability Ambition 2020 is to deliver measurable sustainable value to society. Ensuring human rights are a working reality across our operations and our supply chain is an important part of this ambition and in 2018 we are organising a global SGS communication campaign about our V2S model.
Our Legal & Compliance Policies
Human Rights Policy
In 2017 SGS SA established a Human Rights Committee which is chaired by our Chief Executive Officer and oversees compliance with all Human Rights in all affiliates of the SGS Group. It has implemented a Human Rights Policy, publicly available on its website which mandates SGS affiliates to protect and respect human rights, including whilst selecting and managing employees, suppliers and business partners. A Human Rights and Sustainable Supply Chain Officer was appointed in 2017 and is responsible for its implementation.
Our Code of Integrity – our employees and representatives
For many years the entire SGS Group has operated under a publicly available Code of Integrity applicable to all employees, consultants, joint-venture partners, agents, subcontractors and anyone acting on behalf of, or representing, SGS. This Code contains a clear prohibition on child labour and forced labour, breach of which can result in disciplinary proceedings or termination of contracts.
All new employees are trained in the Code of Integrity upon joining SGS and all existing employees and contractors undertake annual refresher courses.
Our Supplier Code of Conduct
SGS United Kingdom procures various equipment, consumables, property and utilities for the provision of its services. It also purchases manpower through sub-contractors, temporary/agency staff, recruitment agencies and various professional advisors and other services such as facilities management services.
In 2017 a Supplier Code of Conduct was developed by procurement and sustainability experts within our Group. This is publicly available and sets out SGS’s requirement that all suppliers and their suppliers operate a zero-tolerance approach to modern slavery and that non-compliance can result in the termination of our relationship with any supplier. In 2017 SGS United Kingdom required vital suppliers to commit to our Supplier Code.
Our Supplier Due Diligence Process
In 2017 the SGS Group began to implement a new procurement system and rationalise our supplier base. This simplification will enable us to better monitor our suppliers.
We used a more detailed self-assessment questionnaire to obtain information from certain new and existing suppliers to enable us to give each an ethical risk rating. This rating now dictates how often we will review that supplier and the depth of the review required to properly monitor compliance with the MSA. We initially focussed upon our top 50 existing suppliers by spend and we targeted operationally critical new suppliers.
In 2018 we are moving to a more risk based management system. We will carefully screen suppliers from higher risk geographical areas and/or offering higher risk services such as security, cleaning, catering, waste, laundry, logistics and hospitality and also suppliers of higher risk goods such as branded merchandising. We will also assess suppliers based on spend. We will continue to use our pre-qualification process which includes the self-assessment questionnaire for both potentially new and existing suppliers. In the event that we judge a supplier to represent the highest potential risk (on the basis of the screening and pre-qualification stages) we will look to initiate an audit process against the standards set out by SEDEX.
In 2017 training on the Code of Integrity was given in class-based sessions by managers. Whilst already addressing many areas of ethics and trust, in 2017 the Code of Integrity training specifically alerted staff to the problem of modern slavery and how to report concerns.
In addition, we have helped staff to understand and identify modern slavery risks using internal communications such as “Modern Slavery - It is Closer Than You think”.
In 2018 the Code of Integrity training will be made available by e learning to facilitate its delivery and administration. Awareness of modern slavery will also be increased by SGS United Kingdom’s intranet alerts and Operational Integrity Training Talks.
A Human Rights Awareness Course has also been developed for distribution.
Reporting Modern Slavery
For many years SGS SA has had an established Integrity Helpline available to employees and suppliers to enable confidential and anonymous reporting of possible legal and policy violations without recrimination. Reports can also be made directly to the Compliance function in Switzerland or the UK. Details are contained in the Code of Integrity, the Human Rights Policy, the Supplier Code of Conduct, on our internal and external websites and in integrity training. We will remind our staff of the application of the Helpline to issues involving modern slavery and highlight the recommended means of escalating perceived issues.
Effectiveness of Our Modern Slavery Act Initiatives
SGS United Kingdom did not detect any violations of the MSA within our supply chain or business in 2017. We shall continue to review suppliers. We shall report on the progress of all MSA initiatives in our Modern Slavery Statement next year.
Further, the SGS Group is committed to the transparent reporting of all our human rights commitments and performance through our Annual Report and our Corporate Sustainability Report.
This Statement is made pursuant to the Modern Slavery Act 2015 and has been approved by the Board of Directors of SGS United Kingdom Limited.