Modern Slavery Statement

Policy statement
Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This document sets out the policy of SBID (Group of Companies) with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.

Modern slavery is a crime and a violation of fundamental human rights. SBID is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing systems and controls to ensure modern slavery is not taking place in our own business or our supply chains.
SBID is also committed to ensuring that there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from our contractors, suppliers and other business partners, and as part of our contracting processes, we aim to 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 standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

Our supply chains
SBID, as a standard-bearer company, is cognisant that there is a degree of modern slavery risk associated with our supply chain due to the global reach of our membership, product manufacture and installation across the world where we assemble, distribute and supply services. The dependence on suppliers including, but not limited to hosting providers, product applications, equipment (including fit-out), business support services (telecoms, couriers, insurance and legal services) and contractors for services.

SBID acknowledges that some of these suppliers operate within industries with a known record of modern slavery. SBID takes an active approach in vetting our members and our own suppliers including an understanding of their position on modern slavery and the steps they have taken to monitor against it.

Our risks
SBID undertakes supplier risk analysis as part of our vendor review program. These reviews have identified work undertaken by suppliers in the completion of risk assessments and the mitigation of modern slavery risks within their supply chains. SBID acknowledges that the production of second fix products, a business requirement, will continue to present a small modern slavery risk within our company supply chain.

Minimising risk
SBID expects all suppliers, contractors and other business partners to follow a zero-tolerance approach to modern slavery. This approach should be embedded in their procurement processes, which provides for risk-assessment, due diligence and supplier auditing. SBID seeks to ensure that all relevant contractual arrangements place legally-binding obligations on suppliers to meet these standards and to allow for compliance auditing.
SBID partners and collaborates with organisations that share our vision and can demonstrate compliance. A supplier code of conduct is being updated and implemented to support compliance auditing and monitoring of supplier practices. Work is being undertaken to promote understanding and awareness throughout the organisation with internal communications on the subject. Additionally, SBID will continue to build appropriate requirements into policies and quality management procedures as part of the ongoing compliance monitoring process.