Modern Slavery Statement 2016/17

Introduction

Every solution that adm deploys to meet clients’ needs is built based on three key pillars: people, process and technology.  People are at the heart of everything that we do and, as such, we are committed to ensuring that every worker, whether in our business or our supply chain, benefits from a working environment in which fundamental rights and freedoms are respected. We operate a zero-tolerance policy in respect of all forms of modern slavery, forced/compulsory labour and human trafficking, whether in our own global operations or in our supply chains.

We are proud of the steps we have taken to guard against slavery and human trafficking in our global operations. As we continue to grow across the territories we are present in, we are committed to further improvements to our practices in order to ensure that risks are always managed effectively.

Our business and supply chain

Established in 1992, adm is one of the largest independent marketing services businesses in the world employing over 350 people worldwide.  adm has its headquarters in London, United Kingdom and operates in 19 countries globally. adm provides global supply chain solutions to a broad spectrum of clients spanning across several diverse sectors using product supply chains which are global and extensive. adm sources and distributes products in Europe, Latin America, North America and Asia using hundreds of suppliers and strategic partners.  adm’s mission is to combine great people, process, expertise and proprietary technology to deliver outstanding results and added value to clients.

 

Our Policies

We are continuously developing our Corporate Social Responsibility (CSR) strategy based on the UN Global Compact’s four pillars of human rights, labour standards, environmental and anti-corruption principles and with reference to the United Nations Guiding Principles on Business and Human Rights. We strive to ensure these principles underpin everything that we do, from sourcing responsibly to ensuring that the rights of every worker connected with our business are safeguarded and protected. adm’s Global Employee Handbook and its associated policies set out certain minimum standards regarding the human rights of its staff. Our Supplier Code of Conduct sets out minimum standards in respect of the human rights of our suppliers’ personnel. These policies, coupled with our accession to the UN Guiding Principles, reflects our commitment to acting ethically and with integrity in all of our business relationships, and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking are not taking place anywhere in our supply chains.

In respect of adm staff, adm has a range of global Human Resources policies designed to safeguard human rights, including guidance on ethical standards. We have policies on equal opportunities, harassment and bullying, grievance and disciplinary procedures, fair competition, and time-off benefits (including compassionate leave, religious holidays, ceremonies and festivals, working from home and time off for dependents). adm’s whistleblowing policy encourages all staff to report allegations of wrongdoing and all reports will be fully investigated and appropriate remedial actions taken.

In respect of our suppliers’ personnel, adm requires that all suppliers comply with adm’s Supplier Code of Conduct which sets out our minimum requirements with regards to anti-bribery and anti-corruption, child labour, forced labour and human trafficking, working conditions, transparency and environment.  A supplier must formally accept adm’s Supplier Code of Conduct in order to become a preferred supplier.  A supplier’s on-going compliance with the adm Supplier Code of Conduct is monitored through periodic audits.

In 2017 and beyond and as part of adm’s ongoing commitment to CSR, adm intends to develop further ethical trading policies and programmes of training with the objective of managing the managing the risks of modern slavery more specifically

Due diligence

Recognising the human rights risks inherent in global sourcing and, particularly in the specific regions in which adm operates, and given that global sourcing is core to adm’s service offering, adm considers its biggest risk of modern slavery and human trafficking is in its product supply chains.  This is where we predominantly focus our efforts to identify and minimise the potential risks of human rights abuses, including forced or compulsory labour.  adm employs a rigorous supplier selection process including performing detailed due diligence checks in the form of ethical/compliance audits (including factory audits), both prior to a new supplier being on-boarded and then on a periodic basis afterwards. Our Quality Assurance and CSR teams comprise around 30 dedicated staff.

Audits are conducted every two years as a minimum by our CSR auditors or qualified auditors from accredited testing houses. These audits assess compliance with, amongst other things, adm’s Supplier Code of Conduct and adm’s standards on Human & Labour Rights and Working Conditions.  adm is a member of the Supplier Ethical Data Exchange (SEDEX) and administers Sedex Members Ethical Trade Audits (in particular 4 Pillar SMETA audits).

The 4 Pillar SMETA audits inform adm about the living conditions, wages, overtime hours and working conditions of supplier staff, and allow adm to monitor and minimise the risks of human rights abuses in our supply chain.  adm has developed a CSR checklist which is used for grading suppliers based on the audit results and our CSR objectives. If a supplier fails an audit on ethical grounds, the supplier is blacklisted from providing products to adm. We consider these assessments and audits as an integral part of supplier management within adm and our commitment to eradicating the risk of human trafficking and modern slavery from our supply chain.

Governance

The adm Board is responsible for ensuring that adm meets its human rights responsibilities. adm’s human rights responsibilities are key elements of an annual corporate risk assessment process which is overseen by the Group General Counsel on behalf of the adm Board. This assessment is developed in conjunction with the participation of senior leaders within adm.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, adm intends to complete the first tranch of a programme of business ethics training by the end of 2017 and this is will be bolstered through refresher training on a periodic basis.

Further steps  

Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:

Commitments 2017-2020

  • Develop ethical trading policies and trade support programmes in respect of modern slavery specifically;
  • Update adm’s Whistleblowing policy to include a helpline to cover all adm sourcing regions in the relevant languages;
  • Review all employee and supplier policies to ensure they provide adequate protection against modern slavery;
  • Ensure ethical training programme is provided to all staff in local language worldwide; and
  • Develop supplier compliance and ethical standards training for all sourcing regions

As a rapidly expanding organisation, adm is committed to ensuring it implements a scalable compliance framework to ensure it is alerted to any emerging risks and it has appropriate systems and processes in place to eradicate such risks. We will therefore continue to develop and embed our CSR framework in our day to day business culture and as a core component of our wider business strategy.

This statement has been published in accordance with the Modern Slavery Act 2015.  It sets out steps taken by ADM (Group) Limited and the other relevant group companies during year ending 31 March 2017 to prevent modern slavery and human trafficking in its business and supply chains.  References to ‘us’, ‘our’, or ‘we’ are to ADM (Group) Limited and its affiliates and subsidiaries.