Pursuant to applicable regulations, including Section 54 of the UK Modern Slavery Act of 2015, and the California Transparency in Supply Chain Act of 2010 Malvern provides the following statement:
Malvern is part of the Spectris Group Plc. Spectris develops and markets productivity-enhancing instrumentation and controls. Spectris had sales of £1,190 million in 2015 and employs around 8,000 people worldwide.
Malvern and Spectris are absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are also free from these practices. We are committed to promoting responsible business practices with our suppliers.
1 Supply Chain Verification
1.1 Due diligence
Malvern undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:
- Mapping the supply chain against the top twenty Countries by Absolute Estimate of Modern Slavery identified in the Global Slavery Index 2014 to assess geographical risks of modern slavery and human trafficking;
- Evaluating the modern slavery and human trafficking risks of each new supplier;
- Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
- Conducting supplier audits, and certifying those suppliers, through Spectris’ own independently trained and certificated SA800 audit team to the international SA8000 Social Accountability standard with specific audits added to cover the greater degree of focus on slavery and human trafficking required by Section 54 of the UK Modern Slavery Act of 2015, and the California Transparency in Supply Chain Act of 2010;
- Through the audit process, creating an annual risk profile for each supplier;
- Through the audit process, taking steps to improve substandard suppliers' practices by undertaking annual surveillance audits by Spectris’ own independently trained and certificated SA800 audit team , providing advice to suppliers and agreeing with them during the audit the implementation of corrective action plans
- Using the Ethical Suppliers List identified through the audit process outlined above throughout the Spectris Group, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
- Terminating suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct.
1.2 Performance indicators
Malvern has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery legislation in various parts of the world. As a result;
- Spectris has fully trained all auditors and other relevant staff working in the Spectris Asia Pacific Procurement Office responsible for 100% by value of the purchase orders placed by Malvern on the top 20 countries at risk identified above on modern slavery;
- Spectris has developed a system within the Asia Pacific Supply Chain for supply chain verification of potential new suppliers in the top 20 countries at risk identified above that has been in place since March 2011 to evaluate potential suppliers before they enter the supply chain;
- Spectris is developing a system to extend that supply chain verification in all countries outside of the twenty countries at risk, and those at risk countries not included in the Asia Pacific procurement process, expected to be in place by December 2016 whereby the organisation evaluates potential suppliers before they enter the supply chain;
- Malvern has reviewed its existing supply chains in the top 20 countries identified above as at risk, completed in December 2015.
- Spectris requires all staff based worldwide and responsible for management of the supply chains in countries outside of the twenty countries at risk to have completed training on modern slavery by December 2016;
2 Supply Chain Auditing
Out of the total inventory spend for 2015, 15% was placed with companies in the top 20 countries at risk identified above. Of that 15%, 14.89% was audited.
Supply chain audits are carried out on suppliers, and certificates awarded to those suppliers who meet the requirements of the standard. They are carried out by Spectris’ own auditors, who have been independently trained to meet the auditing standards of the international SA8000 Social Accountability standard. Specific additional audits have been added to cover the greater degree of focus on slavery and human trafficking required by Section 54 of the UK Modern Slavery Act of 2015, and the California Transparency in Supply Chain Act of 2010;
The audit process is as follows:
2.1 Suppliers are sent a questionnaire containing all the elements of the SA8000 Standard plus the additional Anti-Slavery sections and requesting feedback on the suppliers’ view of conformance.
2.2 An initial audit is carried over 2 or 3 days. Non-conformances are recorded and corrective actions agreed with an end date for completion.
2.3 When all corrective actions are complete a certificate is awarded to the supplier and an audit schedule agreed.
2.4 This is a three year audit schedule. At yearly intervals, a surveillance audit takes place on approximately 30% of our “at risk” suppliers focussing on specific elements of the standard followed by a complete recertification audit after three years from original certificate award.
The supplier certification process is fully described above. Certificates are awarded for compliance to SA8000 and certification can be put at risk if non-conformances appear during surveillance or recertification audits. A previously certificated supplier will be an agreed period to rectify non-conformances, that period determined by the severity of the non-conformance. If it is decided that a supplier can no longer meet the requirements of the standard, then an exit period from the business would be agreed with the supplier.
The audit schedule includes a requirement for all suppliers in the countries at risk to carry out their own audits of their supply chains. Auditors check the compliance status of the supply chain during surveillance and recertification audits.
Our supplier code of conduct requires that all goods supplied must comply with the product specifications established by Spectris and its Operating Companies as well as comply with national and international standards and regulations.
4 Internal Accountability
Spectris has internal standards of business conduct in place applicable to the whole organisation that govern the actions of our company and employees and holds them to the highest level of ethical and social responsibilities. Our goal is to work with suppliers who embrace and comply with the same principles as our own.
Spectris operates the following policies 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:
- Whistleblowing policy: We encourage all our workers, suppliers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use the Spectris confidential helpline.
- Code of Business Ethics: Our code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
- Supplier Code of conduct: We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate 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. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship. The audit and certification process detailed above describes the process and steps taken to implement the code of conduct in relation to slavery and human trafficking.
- Recruitment/Agency workers Policy We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency we are planning to use before accepting workers from that agency. We expect our suppliers particularly in the high risk Slavery and Human Trafficking countries identified to do the same and we audit this requirement through the audit and certification process detailed in various places in this statement.
Spectris recognises that all supply chain management staff within the organisation working in all countries need to complete training on modern slavery and human trafficking.
It is the intention to design and implement training material and training sessions for all supply chain management staff within the organisation working in all countries. Once the material is in place, we will require all relevant staff to confirm understanding and acceptance of the requirements by December 2016.
Spectris’ modern slavery training will cover:
- Our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
- How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- How to identify the signs of slavery and human trafficking;
- What initial steps should be taken if slavery or human trafficking is suspected;
- How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
- What external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and "Stronger together" initiative;
- What messages, business incentives or guidance can be given to suppliers to implement anti-slavery policies; and
- What steps the organisation should take if suppliers do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.
5.1 Awareness-raising programme
As well as training supply chain management staff, Spectris intends to raise awareness of modern slavery issues to all other employees in the organisation by adding as a module within the organisation's wider human rights/ethics/ethical trade training programme.
The module will explain to staff the following:
- The basic principles of the Modern Slavery Act 2015;
- How employers can identify slavery and human trafficking;
- What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
- What external help is available, for example through the Modern Slavery Helpline.