MODERN DAY SLAVERY STATEMENT – FINANCIAL YEAR ENDING MARCH 2021
This statement has been published in accordance with section 54 of the Modern Slavery Act 2015. It sets out Integrated Service Solutions’ commitment to eradicating Modern Day Slavery within our own supply chain and those in which we operate.
CONTENTS
1. Introduction
2. Organisation structure and supply chains
3. Policies in relation to slavery and human trafficking
4. Due diligence processes
5. Risk assessment and management
6. Key performance indicators to measure effectiveness of steps being taken
7. Training on modern slavery and trafficking
INTRODUCTION
This is ISS’s first modern slavery statement issued under the Modern Slavery Act. The statement refers to the financial year ending 27th March 2021 and outlines the steps taken by ISS to prevent modern slavery and human trafficking within our organisation and the supply chains within which we operate.
ORGANISATION STRUCTURE AND SUPPLY CHAINS
Integrated Service Solutions Ltd (ISS) is an innovative service provider operating primarily within the Fresh Produce sector in the UK. We focus on handling, quality control, ripening and packing of fruit and salad products delivering own brand fresh produce to our customers who predominantly operate in the retail sector within the UK and Republic of Ireland. As a joint venture, we operate independently, but also draw on the expertise and network of our 50/50 shareholders – direct produce supplies limited and Fowler Welch.
Since inception in 2014, ISS has experienced phenomenal growth. With annual revenues exceeding £38 million, and having established a strong market position, we now employ over 540 people across two sites at Teynham and Linton in Kent totalling 180,000 sq.ft.
We take responsibility for our activities and at our core are people, quality and service. These attributes, recognised by all our stakeholders, have enabled us to grow and develop strong relationships with our in-house teams, customers and suppliers.
Our supply chain is broadly split into two areas, the use of temporary labour and the procurement of ancillary products and services. To date the former has represented a significantly higher risk of labour exploitation than the latter and has received greater focus as such.
POLICIES IN RELATION TO SLAVERY & HUMAN TRAFFICKING
ISS have policies in place that support our aim to prevent modern slavery within our organisation and supply chains, including our Speak Up policy and clauses within our labour supplier contracts.
Our Speak Up policy outlines our commitment to conducting business with transparency, integrity and respect for the law. It details how our teams, our suppliers and customers can raise concerns about suspected misconduct or wrongdoing whilst maintaining confidentiality and without retribution.
ISS uphold the ETI principles and are independently audited to Sedex standards.
We have grievance and confidential reporting mechanisms in place to facilitate confidential reporting of concerns.
GOVERNANCE
ISS’s Senior Leadership team, chaired by the Managing Director, Mathew Newns is accountable for modern slavery activities within the business and the Board have final sign off.
DUE DILIGENCE PROCESS
The ISS HR team audit existing agency labour partners every six months to ETI and modern slavery principles in line with Stronger Together guidelines. Worker interviews are conducted across a random sample of individuals to try and identify any concerns, welfare or pay issues that the workers have that may flag suspicion of modern slavery so ISS can take appropriate action.
Any actions arising from these audits are recorded and non-conformances have to be signed off as satisfactorily closed by the ISS HR team. Non-conformances that are not closed in good time are escalated to the managing director and our legal support.
Due diligence audits are carried out by the ISS HR team to Stronger Together guidelines before new agency labour providers are considered for supply.
ISS acknowledge that we need to improve the due diligence process around our non-labour supply base and will be working towards this in the future.
RISK ASSESSMENT & MANAGEMENT
The most significant risk to ISS is the reliance on temporary labour.
The twelve-month reporting period has been particularly turbulent, the fresh produce packing sector has traditionally relied on significant numbers of low wage migrant workers to make up its teams. The onset of Covid-19 and latterly Brexit have not only reduced the overall size of the labour pool but also restricted the ability of people to move freely within and between countries. Statistics show that 1.4million workers left the UK between December 2019 and January 2021, that have not been replaced. This combined with the increased demand and cost of labour and in the case of Covid-19 the reduced face-to-face interaction with teams for large periods has created an environment that exacerbates the potential for exploitation, modern slavery and people trafficking to satisfy demand.
ISS manage this risk by using known, GLAA registered, audited and trusted labour suppliers and actively engage with workers to try and uncover concerns about modern slavery within their network. Most of our temporary workers are already living in the UK and are not sourced directly from overseas.
KEY PERFORMANCE INDICATORS TO MEASURE THE STEPS BEING TAKEN
ISS do not currently have KPI’s that specifically relate to modern slavery as they are embedded within our business KPI’s and are measured through conformance to independent external and internal audits.
ISS will look to create modern slavery specific measures to report on performance in the future.
Plans for 2021/22
Engagement with customer initiatives to monitor and improve our awareness of potential issues.
Increase awareness of modern slavery prevention measures within the ISS management and supervisory teams.
Achieve Stronger Together business partner status.
Review current policies and create new policies that specifically target the prevention of modern slavery and make this information more accessible to our teams and temporary workers.
TRAINING ON MODERN SLAVERY & TRAFFICKING
Our aim is to raise awareness of modern slavery within our organisation and within our supply chains, providing managers and teams with to knowledge to identify activities and behaviours that may be linked to exploitation. We proactively communicate to our teams as well as providing access to support, resources and tools for both managers and individuals in multiple languages and formats so that they may be confident in reporting concerns or seeking help in their native language and in a method that suits them.
We continue to provide compulsory training to every member of our team and our temporary labour teams as part of our induction process; every team member watches the Stronger Together film in their native language and takes part in a discussion about modern slavery afterwards.