Modern Slavery Act

Policy Statement 

Introduction

Slavery and human trafficking (“Modern Slavery”) is a worldwide and far reaching issue. St Ives plc (“St Ives” or “the Group”)) and its subsidiaries are completely opposed to any form of slavery and human trafficking. Our staff are expected to highlight concerns that they may have, using the appropriate reporting channels, and management are expected to act accordingly.

Our business

St Ives is an international marketing services group comprised of 16 dynamic marketing and print services businesses. St Ives’ head office is based in London, United Kingdom. The group has three segments; Strategic Marketing, Marketing Activation and Books, and employs over 3,000 employees.

Our supply chains

As a marketing services group, most of our businesses have relatively straight-forward supply chains, with the majority of products and services sourced from suppliers based in the European Union or the United States. In assessing the supply chain of each segment, it was concluded that Marketing Activation and Books had the highest inherent risk of potential exposure to modern slavery due to the tangible nature of the products being procured. Therefore, steps have been taken to assess and manage the risk particularly in relation to this segment. Steps have also been taken to underpin our group wide procurement practices.

Our supply chain due diligence processes

As part of our initiative to identify and mitigate risk, we have reinforced the systems in place to:

  • Identify and monitor risk areas in our supply chain
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains
  • Protect whistle blowers

These systems have been strengthened by:

  • The introduction of a new supplier pre-qualification document to be completed by suppliers across Marketing Activation and Books. This makes agreement with the St Ives policy statement and confirmation of compliance with the Modern Slavery Act 2015, where applicable, a condition of becoming a supplier. The document will be used for the set-up of all new suppliers and subcontractors for both segments.
  • Steps being taken to contact existing suppliers of Marketing Activation and Books to confirm compliance with the Modern Slavery Act 2015 and St Ives’ policy statement.
  • Supplier audits being carried out on key suppliers within the group.
  • Updating the General Terms of Purchase to state that suppliers are required to adhere to the Group’s Ethical Trading Policy and Anti-Corruption and Bribery Policy.

Our policies

The Group will not knowingly do business with any organisation or body involved in slavery or human trafficking. Our commitment to the Modern Slavery Act 2015 is reinforced by the Group’s following policies:

  • Ethical Trading Policy
  • Anti-Corruption and Bribery Policy
  • Whistleblowing Policy
  • Grievance Procedure
  • Sustainability Policy

Our People

Each business within the group has a local HR function to address employee issues and a formal recruitment process which includes pre-employment checks. For our UK based businesses this includes processes to ensure that employees have the right to work in the United Kingdom and St Ives complies with the National Living Wage which became law on 1 April 2016.

Staff awareness initiatives are conducted within the group facilitated by training for specific roles. The Group’s whistleblowing policy is reviewed periodically and rolled out to each of our businesses.

This policy statement concerning slavery and human trafficking is made pursuant to section 54(1) of the Modern Slavery Act 2015 and was approved by the Boards of St Ives plc, SP Group Ltd, Service Graphics Ltd, St Ives Management Services Ltd and Clays Ltd. 

January 2017

 

matt-signature.jpg (1)

Matt Armitage

CEO, St Ives plc

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