Modern Slavery Statement

Modern Slavery Statement

POLICY STATEMENT

Granby Marketing Services commits to developing and adopting a proactive approach to tackling hidden labour exploitation.

Granby carry out promotional marketing, contract packing and 3PL services across all sectors. Although not legally obliged to publish a modern slavery statement Granby are choosing to do so in the interests of transparency and best practice activity.

The risk of encountering modern slavery is not considered material. Nevertheless, Granby is committed to ensuring it is not connected to modern slavery in any way. Granby seeks to ensure that the business operates in an open and transparent way and the overall approach to tackling modern slavery and human trafficking throughout Granby’s supply chain is consistent with the legal obligations under the Modern Slavery Act 2015

Organisation Structure and Supply Chains

Granby Marketing Services are an employee owned trust working from a multi site single location premise in Blackburn, Lancashire with no parent or subsidiary companies.

Granby purchase goods and services that relate to the following:

• Delivery Services
• Packaging
• IT Network Management
• Physical infrastructure maintenance services

A thorough process of onboarding, review and diligence takes place before organisations and companies are approved to provide good and / or services to Granby, including review of their own commitments to tacking modern slavery.

Granby considers the provision of these goods and services to present a low risk of modern slavery and forced labour, nevertheless, it is acknowledged that certain industries (e.g. cleaning and couriers) pose a higher risk of individuals being coerced, forced into labour or trafficked. Granby addresses these risks by implementing the policies below.

Granby prohibits, and expects all service providers to prohibit, the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. This prohibition extends to any subcontractor as Granby expects our service providers to hold their own suppliers to the same high standards

Granby has policies in place that reduce the risk of slavery or forced labour and ensure staff are treated with the dignity and respect they deserve, and expects its key service providers to have similar requirements in place.

Coverage

All Areas where Granby Marketing Services employ staff – Warehouse 1, 2, 3, 4, 5 and 6 areas.

Responsibility

All members of staff have a responsibility to be aware of workplace slavery issues and report any instances that come to their attention to their line managers.

Policy Commitments

Granby Marketing Services shall:

1. Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.
2. Accept that job finding fees are a business cost, and will not allow these to be paid by job applicants. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
3. Ensure that all staff responsible for directly recruiting workers are aware of issues around third party labour exploitation and signs to look for and have signed appropriate Compliance Principles.
4. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
5. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and police.
6. Provide information on tackling “Hidden Labour Exploitation” to our workforce (GMS currently do this through posters and awareness e-mails).
7. Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
8. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities by empowering staff to raise issues. with their team leaders and line managers through awareness campaigns.
9. Use recruitment measures to ensure that we only pay wages only into bank accounts owned by the worker.

Risk Assessment and performance indicators

Granby undertakes a risk assessment to identify the nature and extent of its exposure to modern slavery and human trafficking, which is updated at least annually. It has due regard to the countries in which Granby and its supply chain operates, the sector it works in, transaction risks and goods /service provider risks.

Granby monitors various performance indicators that could indicate a heightened risk of supporting modern slavery, for example staff training, whistleblowing events, or supplier responsiveness to questions regarding enforced labour. Resulting from this risk assessment, Granby has identified that the suppliers that may be targeted by human traffickers or labour providers are the smaller, less regulated firms alongside entities with overseas operations facing off to the same small suppliers, such as the cleaning provider, catering suppliers and couriers.

This is because these types of firms are typically smaller in nature therefore do not need to be transparent in their dealing of the Modern Slavery Act; and can have complex supply chains themselves.

Granby employ their own cleaners, do not employ any catering staff and use only couriers that have satisfactorily completed supplier onboarding process and respond satisfactorily to diligence measures incorporated into the ongoing review process.

Training
Granby ensure all key staff, including compliance, HR and leadership staff, are trained upon joining and thereafter about our expectations with regards to modern slavery.

Granby has endorsed this policy and has confirmed Granby’s commitment to improving practices to combat slavery and human trafficking following a review of the effectiveness of the steps Granby has taken to ensure that there is no slavery or human trafficking in Granby’s supply chains.