We base our approach to business on our five cornerstones keeping people safe, upholding family values, working for our customers, being the best and making decent returns. We communicate these both to our colleagues and suppliers as we believe it is what makes us different from our competitors. The cornerstones come down to doing the “right thing” which is how we have approached the issue of modern slavery internally with colleagues and with our suppliers.
We deliver products direct to customers via our own distribution channels and direct from our suppliers, and to customers via our network of approximately 2,000 stores and trade branches. Our product categories range from construction products for building, repair, maintenance or improvement to industrial civil engineering products, plumbing and heating systems, kitchens, bathrooms and DIY products.
The Supplier Commitments have been communicated to our suppliers and incorporated into our supplier manual and responsible sourcing procedures. The supplier due diligence process, described on the following page, includes an assessment against the requirements of the Supplier Commitments.
Regarding our own employees, we uphold high standards and comply fully with the relevant employment laws for the countries within which we operate. We have clear standards of conduct which are included in our employee handbook. Our employees have access to a whistleblowing line and are encouraged to report any concerns. No reports were registered in 2018 relating to modern slavery.
Our centrally-controlled suppliers go through a due diligence process, which includes two stages. Firstly, a contractual commitment to our ethical requirements through reference to our Supplier Commitments in the standard trading agreement. Secondly, an assessment of compliance with the commitments through our Online Risk Assessment (ORA) questionnaire. The ORA includes but is not limited to Business Ethics, Labour and Human Rights, Environment, Health & Safety and Product Quality. On completion of the ORA, the supplier receives a bespoke risk assessment for their company in the 3 key areas of Environmental Responsibility, Social Responsibility, and Quality & Product. Based on the results, our QA team may contact them to request further documentary evidence or undertake additional tasks to demonstrate compliance or mitigate risk. There are cases where a supplier account has been closed based on their ORA results although this has not been for reasons relating to modern slavery.
A third stage of assessment is in place for manufacturers of our own-brand (or no-brand, i.e. commodity) products; an audit programme. For a factory to be approved to manufacture on our behalf they need to pass an audit (which contains both technical and ethical components), conducted either by our QA team or our nominated 3rd party, Intertek. We work with our manufacturers to ensure that any major non-compliances are addressed before any further activity is undertaken with them.
These three stages of assessment form our minimum expectation around supplier due diligence and work is ongoing to bring all Group businesses and all suppliers under this framework.
Additionally, over 97% of timber and timber fibre products purchased by the Group in 2018 were certified as responsibly sourced (76% FSC and 21% PEFC). Both the FSC and PEFC certification schemes require compliance with the ILO Declaration on Fundamental Principles and Rights at Work, 1998, prohibiting the use of forced or child labour.
Due to the complexity of our global operations, including the UK, we acknowledge that there may be a risk of modern slavery in our supply chain. Our risk assessment is informed by the Global Slavery Index, the Corruption Perceptions Index and the Worldwide Governance Indicators (WGI) - World Bank.
We have provided training to key employees on modern slavery, including the QA team and our direct sourcing team. We have developed a modern slavery training module on our in-house training system which is accessible to all.
Besides the continued management of our existing due diligence programmes (see the “Due diligence” section above), in our 2017 statement we set out our aim to improve in four key areas. The progress made does not align directly with the specific actions listed in 2017 due to reorganisation during the year. However our core due diligence processes continued and progress made within the four key areas is summarised below:
We will continue to develop our approach, review our progress and publish an updated statement annually.
This statement is approved by the Board of Travis Perkins Plc and its subsidiaries in relation to the financial period ending 31 December 2018.
Travis Perkins Plc