This Modern Slavery and Human Trafficking Statement relates to actions and activities since the financial year 1.7.17.
The statement sets down Halstan & Co Ltd’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
Organisational structure and supply chains
This statement covers the business activities of Halstan & Co Ltd which are as follows:
Halstan & Co Ltd is a privately owned printing company supplying to publishing and commercial customers. Halstan & Co Ltd has a supply chain which is comprised of organizations based in the United Kingdom or in Europe. Halstan & Co Ltd does not normally operate with supply chains outside of Europe. Halstan does not knowingly deal with any countries where slavery or human trafficking is considered high risk.
Halstan & Co Ltd assesses whether particular activities may be high risk in relation to modern slavery or human trafficking. We carry out due diligence by requesting slavery and trafficking statements from our supply lines.
The following activities are considered to be at high risk of modern slavery or human trafficking: Raw material harvest for paper manufacture. The suppliers at risk are requested to send statements. This is reviewed annually.
Responsibility for the Company’s anti-slavery initiatives is as follows:
1.1 The Finance Director is responsible for creating and reviewing policies. The process by which policies are developed is to ensure due diligence with suppliers and contractors to ensure there is no perceivable risk of slavery or human trafficking taking place.
1.2 Risk assessments are carried out on specific supply chains and all that are deemed to be high risk. The importation of paper or pulp for paper manufacture from outside of Europe is an example.
1.3 The Systems and Compliance Officer and Operations Director are responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.
Training
To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to be made aware of the policies and statements involving employment and risks of slavery and human trafficking. All staff are required to produce proof of identity and any permits if required by law to work in the UK.
Policies
The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.
The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations.
2.1 Whistleblowing policy – the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
2.2 Code of Conduct. The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.
Due Diligence Processes for Slavery and Human Trafficking
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of our business partners. We evaluate the modern slavery and human trafficking risks of each new supplier and request a statement and/or policy.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Board of Directors endorses this policy statement and is fully committed to its implementation.
Halstan & Co Ltd does not permit, condone or accept any form of human trafficking or slavery as defined in the Modern Slavery Act 2015.
This Modern Slavery and Human Trafficking Statement has been approved and authorised by:
Name: Paul Horseman
Position: Finance Director
Date: 1st July 2022