Modern Slavery Act
St Pierre Groupe Modern Slavery Statement for Financial Year 2018/19
St Pierre Groupe is a Manchester-based bakery business, which supplies European-style bakery products to the UK and USA markets. Its suppliers are based within Europe, North America and Canada.
As a commitment to eradicate Modern Slavery this statement outlines the steps that St Pierre Groupe has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within its business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. St Pierre Groupe has a zero-tolerance approach to any form of modern slavery and is committed to acting ethically and with integrity and transparency in all its business dealings. It is also committed to ensuring effective systems and controls are put in place to safeguard against any form of modern slavery taking place within its business or supply chain.
We operate a number of internal policies and procedures to ensure that we are conducting business in an ethical and transparent manner. These include:
- Recruitment Policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK, checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- Public Interest Disclosure Policy. We operate this policy to ensure that employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
- Professional Code of Conduct. This code explains the manner in which we behave as an organisation and how we expect our employees to act.
- Equal Opportunities Policy. This policy is to ensure fair treatment of all employees within our business environment.
- National Minimum Wage & Living Wage. This ensures that all employees of St Pierre Groupe receive pay in line or above the national minimum levels.
- Health & Safety. Due to the nature of our work and the duty of care we have for our employees and all who we conduct business with, we ensure that appropriate health and safety policies and training are provided to all to ensure a safe and clean working environment.
- Gifts, Entertaining, Conflicts of Interests and Bribes Policy. Ethical difficulties can arise when an employee is offered hospitality, gifts or personal services by a supplier or a customer. We operate a robust policy to ensure criminal activities, such as bribery, do not take place.
- St Pierre Groupe is a member of the SEDEX to enable the assessment and mapping of our multiple supply chains and ensure responsible sourcing is carried out at every level.
- Supplier Code of Conduct. This policy sets out what current and future suppliers will need to comply with in order for us to conduct business with them. This includes ensuring they have their own robust policies and are not involved with any modern slavery or trafficking.
St Pierre Groupe operates a supplier Code of Conduct and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search, including using our SEDEX membership, to ensure that particular organisation has never been convicted of offenses relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
Other due diligence steps include:
- Ensuring new suppliers uphold all standards and requirements in our supplier’s code of conduct before adding them into the supply chain
- Annual audit and mapping of supply chains using SEDEX
- Annual risk assessment of full supply chain including a further assessment on how high-risk areas have improved. One way of doing this can be asking them to complete a modern Slavery Act Due Diligence Questionnaire, which covers their governance, policies, training and supply chain
- Annual staff training on modern slavery requirements
Approval for this statement
This statement was approved by the Board of Directors on 18/12/18
Name: Jeremy Gilboy
Date: 18th December 2018