This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes the SUEZ anti-slavery and human trafficking statement for the financial year ending 31 December 2018.
This statement sets out SUEZ’s actions to identify all potential modern slavery risks related to its business in the UK and to put in place reasonable steps to prevent slavery and human trafficking in our business and supply chain. We are committed to conducting business responsibly and to maintaining and improving systems and processes to reduce the risk of slavery or human trafficking in our business and supply chain.
All references to SUEZ in this statement include all UK SUEZ Group companies, all of which have endorsed this statement and the actions within.
Slavery, servitude, forced labour and human trafficking (Modern Slavery) is a world-wide and growing issue given the rapid rise in global migration. The sector in which we operate can be attractive to perpetrators of this type of crime so as a leading integrated water and waste management and recycling business in the UK, the company recognises the need to adopt a robust approach to slavery and human trafficking. SUEZ has a zero tolerance approach to Modern Slavery within our operations and supply chain and staff are expected to report concerns, using a variety of appropriate reporting channels, and we are committed to act upon any such reports.
SUEZ in the UK commits to developing and delivering a proactive approach to tackling hidden labour exploitation. We will continue to achieve this by carrying out the following:
- The existence of an appropriate policy on preventing hidden labour exploitation which will be reviewed on a regular basis.
- The existence of practical and pragmatic working procedures to support local management in this aim.
- The delivery of training for key managers using both external organisations and internal resources for SUEZ’s water business. A key support relationship has been developed and maintained with the organisation Hope for Justice.
- The continued and improved delivery of training to a broader range of employees, through the development of SUEZ’s own in-house training course.
- The original communications plan for SUEZ Recycling and Recovery UK Ltd which highlighted Modern Slavery and where to seek help is to be rolled-out across SUEZ’s water business. Posters at sites provide information on Modern Slavery and numbers to call, for example SUEZ’s independent Whistleblowing Line and Hope for Justice.
- Working closely and engaging with employees and employee representative bodies as part of preventative strategies.
Organisational structure and supply chains
SUEZ operates at over 300 sites across the UK providing recycling and recovery services, and water services. Our business headquarters are in Maidenhead, UK and we employ over 5,000 people across the UK Group. The following companies are covered by this statement:
SUEZ Recycling and Recovery UK Ltd
SUEZ Recycling and Recovery South East Ltd
SUEZ Recycling and Recovery Lancashire Ltd
SUEZ Recycling and Recovery Tees Valley Ltd
SUEZ Recycling and Recovery Surrey Ltd
Ondeo Industrial Solutions UK Limited
We have relationships with external businesses to source labour and materials/waste for our business. The majority of our suppliers are UK companies. Suppliers of goods and services to SUEZ must comply with all relevant legislation and international standards as relevant to their industry, including, child and forced labour, health and safety of workers, non-discrimination, employment law, human rights, fraud, bribery and corruption. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
Relevant policies and procedures
SUEZ has in place the following policies and procedures that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Anti-Slavery and Human Trafficking Policy and Procedure – reviewed annually.
- Whistleblowing Policy – SUEZ uses an independently provided whistleblowing hotline, which provides an easy and confidential means for concerns to be raised. We investigate every whistleblowing case and seek to achieve a resolution as soon as practicable.
- Employee Assistance Programme – provides an external and confidential support service by telephone through which advice and information are imparted to employees across a wide range of topics. This service also includes face-to-face counselling.
- ‘We Hear’ confidential employee support line, run by employees for employees.
- Supplier Code of Conduct – suppliers are required to confirm that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
- Sustainable Procurement Policy.
We continue to work with Hope for Justice (http://hopeforjustice.org/united-kingdom/), an international anti-human-trafficking charity, in providing a programme to promote awareness of modern slavery. This has been prioritised in the areas of our business operations where the risk of modern slavery practices have been assessed to be the greatest and includes:
- Training for key personnel.
- The distribution of an employee newsletter and posters.
The training includes:
- Introduction to Modern Slavery.
- Relevance to SUEZ.
- Definitions of Modern Slavery.
- What to do if they spot signs of Modern Slavery in UK.
- Where to go for more information.
SUEZ has trained circa 100 employees to date in SUEZ recycling and recovery UK. Going forward training will be implemented through the development of SUEZ’s in-house training course, delivered via a digital platform.
During 2019, SUEZ aims to work with Hope for Justice to roll-out training, by way of Webex and classroom sessions to senior managers, team leaders and supervisors, as well as to its HR team.
Practical steps taken in the financial year ending 31 December 2018
To underpin our compliance, we implemented the following measures:
- Introduced a Sustainable Procurement Policy, which strives to gain supply chain transparency and source products, materials and services using credible and recognised sourcing and certification schemes, where available. It also aims to help us identify and address human rights abuses and labour exploitation in our supply chain.
- A pre-screening process for new suppliers with an annual turnover greater than £36 million, which involves ensuring that they provide a statement detailing how they comply with the Modern Slavery Act 2015. We also ensure new suppliers sign our terms and conditions which includes an Anti-Slavery provision detailing their obligations in this regard under the terms of our contract with them.
- Conduct risk assessments in line with our Sustainable Development Goals for each major procurement spend area of the business.
- Engage with our suppliers both to convey to them our Anti-Slavery and Human Trafficking Policy and Supplier Code of Conduct and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses.
- Ongoing review of supplier contracts to ensure the appropriate modern slavery provisions are included.
- Working with the Jericho foundation, who support victims of modern day slavery. After a period of support and counselling, the Jericho foundation offer part-time work to help facilitate victims back into the workplace. Once victims are ready to return to work full-time we are working to offer positions in our facilities in Birmingham.
- Training of staff as set out above.
- Review of policies and procedures to ensure that they continue to be fit for purpose.
The Company will consider the impact on any person working for us or on our behalf who believes they are a victim of slavery, human trafficking or forced labour, and aims to support any such person, including assisting that person in reporting this concern to the appropriate authorities.
This statement has been approved by the board of SUEZ on 07 May 2019 who will review and update it annually.
David Palmer-Jones, Chief Executive Officer, SUEZ recycling and recovery UK
On behalf of SUEZ recycling and recovery UK Group Companies
Katherine Walsh, UKIN HR Manager, SUEZ water technologies and solutions UK
On behalf of SUEZ water technologies and solutions UK Group Companies