Modern Slavery Statement
Scolmore continues to support the aims of the Modern Slavery Act 2015 and is committed to working towards prevention of forced labour, slavery and human trafficking.
The Code of Ethics, launched in June 2023, reflects the core values and the high ethical standards which inspire all our employees, business partners and other stakeholders and reinforces our adherence to the UN Guiding Principles and ethical international standards.
Our Anti-slavery and Human Trafficking policy, launched in May 2022, covers the activities of all Companies within the Scolmore Group and applies to the whole workforce.
It sets out our expectations to all our employees, contractors, suppliers and any other business partners.
In July 2022, we also issued and rolled out the Scolmore Supplier Code of Conduct (SCoC) to our Supply chain, which reflects the core values and the high ethical standards inspiring our employees, business partners and all other stakeholders.
The “Supplier Code of Conduct”, together with the “Sustainable Procurement” policy, which is at the final drafting stage and expected to be issued in May 2024, seek to provide a framework within which all procurement activity across the group will result in enhanced sustainability outcomes.
The above documents - both based on the UN Global Compact, the UN Guiding Principles for Business and Human Rights and the OECD Guidelines for Multinational Enterprises as well as other international standards, norms, and guidelines – cover, but are not limited to Child and Slave Labour, Health & Safety, Conflict Minerals, Environmental Protection, Fair Labour Practices and Business Ethics.
In addition, the “Sustainable Procurement” policy will set out requirements and guidance to ensure appropriate Due Diligence is carried out in respect of Scolmore’s Business Partners.
The above policy follows the introduction of the “Conflict Minerals” policy in July 2023, which aims at avoiding contributing towards conflict through our sourcing decisions related to the so-called 3TG (i.e. Tin, Tantalum, Tungsten and Gold) or “conflict minerals”, and addresses the risks related to conflict minerals and other unethically produced materials.
The trade of these minerals, as well as other materials not specifically defined as conflict minerals, which can be integrated in everyday products such as mobile phones and cars or in jewellery, can be used to finance armed groups, fuel forced labour and other human rights abuses, and support corruption and money laundering.
In 2023, the third-party quality audits on our manufacturing plants, which were already in place, have been coupled with social audits. Any non-conformities raised have been categorised according to the Ethical Base Initiative (ETI) Base Codes, a root cause analysis has been performed and corrective actions planned and implemented under the guidance of our Compliance Team. Between November 2023 and 30th April 2024, all 19 non-conformities raised were addressed and closed.
In line with our Anti-slavery and Human Trafficking policy, we continue raising awareness within our workforce and providing training and tools to those employees who could most likely come into contact with incidents of modern slavery during the performance of their duties (namely all Managers and Directors as well as all staff working in human resources, product development, quality, purchasing, supply chain, projects and legal & compliance departments.
All new starters in those departments must complete their training within the probationary period (usually 6 months) whereas at any given time and considered the presence of new starters, we expect at least 85% of the above staff to have completed their training.
June 2024