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SLAVERY AND HUMAN TRAFFICKING POLICY
Introduction
Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable
workers and can take various forms such as slavery, servitude, forced or compulsory labour and
human trafficking.
Lanchester Group is committed to the steps we have taken to combat slavery and human
trafficking and we are committed to constantly reviewing and improving our practices.
The company expects the same high standards from all its suppliers, contractors and other
business partners and, as part of its contracting processes, it includes specific prohibitions against
the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to
the same standards.
About Us
Formed in the 1980’s, The Lanchester Group now comprises of five companies, each with very
different specialities, but constantly working together providing a truly unique service for our
customers.
Lanchester Wines is a major supplier of wines and spirits. We source wines from
producers and suppliers from all over the world, supplying both the on and off trade as
well as creating our own brand ranges. We also have a Warrington based division dealing
exclusively with bulk wine orders, supplying some of the UK’s major high street retailers
and supermarkets.
Lanchester Gifts is a major drop ship supplier of wine and food gifts and hampers to
internet based businesses and high street retailers. We can create gifts to meet most price
points, pack and deliver to home addresses in the UK as well as drop ship and supply in
bulk.
Greencroft Bottling specialises in packaging wines and spirits. We pack a wide range of
products in a variety of packaging including bottles, bag in box, pouches, kegs and during
the coming year, cans. We pride ourselves in our constant re-investment in the latest
technology, keeping us at the forefront of the wine bottling industry.
Lanchester Energy is aimed at developing renewable energy sources, beginning with the
Lanchester Group’s own wind turbines. We’re now investigating possible new forms of
renewable energy generation, including solar and waste conversion.
Lanchester Properties owns and maintains our Co. Durham site. Set up in 2000, we have
heavily invested in renewable energy and were constantly improving facilities on site.
Slavery and Human Trafficking Policy (v4), July 2019
Our Policies on Slavery and Human Trafficking
Our policy reflects our commitment to acting ethically and with integrity in our business
relationships and to implementing and enforcing effective systems and controls to ensure slavery
and human trafficking is not taking place anywhere in our labour supply chains. We are
committed to ensuring:
employment is freely chosen
freedom of association and the right to collective bargaining for all
conditions of work are safe and hygienic
there is no child labour in our businesses or supply chain
that living wages are paid
working hours are not excessive
no discrimination takes place in our organisation
regular employment is provided
no harsh or inhumane treatment is allowed
Responsibility for the Policy
The Board of Directors has overall responsibility for ensuring that this policy complies with the
Company’s legal and ethical obligations. The HR Manager has day-to-day responsibility for
implementing this policy, monitoring its use and effectiveness and auditing internal control
systems, policies and procedures to ensure they are effective in preventing or remediating the risk
of modern slavery.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we monitor ethical standards across the
business on a regular basis both internally and via external third party audits. As a B member of
SEDEX we are subject to unannounced periodic SEDEX members Ethical Trade Audits as well as
individual customer audits. Sedex reports are published and shared with our Customers.
Remediation
Should slavery, and more concerning child slavery, be found in our businesses or supply chain, we
are committed to adopting industry best practice to make sure we do the right thing for any young
or vulnerable person we find.
This means that if an underage worker is found working in a factory we source from, we will report
them to the appropriate authorities and ensure their immediate safety. We will then continue to
work with authorities to them find a school, secure housing and where possible, financial support
until they reach the legal age of work.
Slavery and Human Trafficking Policy (v4), July 2019
We expect our supplier to adopt these principles should an underage worker be found in their
employment.
Our Supply Chains
As a responsible employer we strive to ensure that any labour providers we use are recruiting
responsibly and not using third party suppliers whereby the risk of trafficking and slavery is
greater.
As a company we use Labour Providers to supply a percentage of our workforce. Each Labour
Provider is audited against our own Labour Provider audit standard by trained auditors every 6
months. Within these audits, the ETI Base Code and controls around Modern Slavery are
reviewed.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our
supply chains and our business, we provide training to our staff as part of their induction. Our HR
team has attended the ‘Stronger Together – Tackling Modern Slavery in Supply Chains’ workshop
and the Stronger Together data is shared across our sites during induction in order that both our
permanent and temporary labour is fully aware of our commitment to preventing slavery and
human trafficking in our business, and along our supply chain. We also have various “campaign
posters” displayed across the site.
Raising Concerns
The Company aims to encourage openness and to support anyone who raises genuine concerns in
good faith under this policy, even if they turn out to be mistaken. The Company is committed to
ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good
faith, their suspicion that modern slavery is or may be taking place in any of its businesses or
supply chains.
Concerns should be raised directly to the HR Manager. In their absence, to a Senior Manager.
Concerns will be investigated and if necessary, reported to the authorities for immediate action.
Safety and confidentiality of any individuals is paramount and measures will be taken to protect
vulnerable persons.
Breach of the Policy
Any employee who breaches this policy will face disciplinary action, up to and including summary
dismissal for gross misconduct.
Slavery and Human Trafficking Policy (v4), July 2019
The Company may terminate its commercial relationship with suppliers, contractors and other
business partners if they breach this policy and / or are found to have been involved in modern
slavery.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes
our Group's slavery and human trafficking statement for the financial year ending 30 th June 2020.
_______________________________________________
Veronica Cleary
Director
