Slavery and Human Trafficking Statement 2020 (External)
Slavery and Human Trafficking Statement of SGS United Kingdom Limited and its UK affiliates (“SGS United Kingdom”) for the financial year ending 31 December 2019.
This is our fourth Modern Slavery Statement since the first was published in June 2017. It sets out what SGS United Kingdom did in 2019 to ensure that slavery and human trafficking did not take place in our supply chains or in any part of our business. It also sets out the SGS Group’s actions and our current plans for 2020 and 2021.
Group Structure and Business
SGS is the world’s leading inspection, verification, testing and certification company. With more than 89,000 employees, SGS operates a network of over 2,600 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 2019 Sustainability Report, which reports on the environmental and societal impacts of our business activities using our 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 a fundamental part of this ambition.
Our Legal & Compliance Policies
Human Rights Policy
SGS SA’s Human Rights Committee 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 publicly available Human Rights Policy, which mandates SGS affiliates to protect and respect human rights, including whilst selecting and managing employees, suppliers and business partners.
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 will 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.
SGS has a Supplier Code of Conduct that 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. SGS United Kingdom continues to require 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 which in 2018 allowed us to mandate 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. We then moved to a more risk-based management system screening 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 continued to assess suppliers based on spend too. 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.
SGS, as mentioned above, runs an annual Integrity training, which addresses many areas of ethics, trust and human rights and restates the mechanisms by which one can report concerns. It includes topics such as child labour, forced labour, freedom of association and discrimination, working hours, and health and safety. The training is conducted by eLearning and is mandatory for all employees.
In addition, in 2019 we also introduced more personal face to face training on ethics and human rights issues via our bi-monthly Integrity Talks and continued to run a global communication campaign about our V2S model and human rights.
Further, the SGS Group is looking for ways to provide human rights training to our suppliers.
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 our integrity training. We remind our staff of the Helpline by which they can report issues involving modern slavery and we 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 2019. 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.
SGS is currently working on the definition and deployment of various improvements to our human rights mechanisms. In particular, we are working on updating our Integrity training, by integrating intelligence and cases compiled through our integrity helpline and compliance departments during previous years.
In addition, SGS plans to further enhance its due diligence and is evaluating means to better understand exposure to human rights risks at a local level and to ensure that adequate mitigation plans are in place.
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. The deadline for publication of this Statement was extended due to the COVID-19 pandemic.
On behalf of the Board (signature of James McGurk, Managing Director)