This Statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps which we have taken to ensure that slavery and human trafficking are not taking place in our supply chains or in any part of our business.
This statement covers all of the companies within the PZ Cussons Plc Group, both within the UK and overseas (the "Group").
Our approach to business is encapsulated in our Good4Business (G4B) principles which seek to Create Sustainable Value for all of our stakeholders, including our shareholders, customers and consumers, business partners, local communities and our employees. We believe that sustainable, long term value is only possible in an environment which is open, honest and fair and which treats all stakeholders with respect and integrity. Good4Business is rooted in strong values dating back to the foundation of the business in Africa in the 1880s and is based on four key areas of focus:
• Business Governance & Ethics
• Community & Charity
The integrity of our supply chains, including ensuring that there is no slavery or human trafficking, is a priority for the Board of Directors and the Group as a whole.
Our organisational structure, business and supply chains
PZ Cussons Plc is a FTSE-listed international consumer products business which operates (itself and through members of its Group) in selected markets in Africa, Asia and Europe and has its headquarters in the UK. We produce, market and sell some of the world’s best known and loved brands in the following categories: personal care, home care, food and nutrition and electricals.
The Group manufactures products in each of its categories in its own factories across multiple countries. In addition, a proportion of total sales is derived from finished goods which are manufactured by third parties. The Group is reliant on a wide range of raw materials for the production of its products, both within its own manufacturing processes and the wider supply chain. Respecting human rights and other ethical and environmental issues in the wider supply chain is a responsibility which must also be borne by our suppliers but we play an active role in supplier development and have adopted various means to clearly communicate our expectations.
Our policies and standards
The Group maintains written policies which strictly prohibit the use of slavery or human trafficking in its supply chain. Our G4B framework strongly condemns - and provides that we shall have no involvement whatsoever in - forced labour, child slavery or any practice which is exploitative of children or exposes them to risk of harm. We will not work with third parties who are involved in any such practices.
These principles are also set out within the Group Procurement Code of Business Conduct which contains guidance for the Group’s procurement team on the Group’s values and appropriate business practices. We expect businesses throughout our supply chain to adopt and enforce equivalent policies in their own operations and to encourage their own suppliers to do the same. In addition, direct suppliers are required to confirm their compliance with the relevant laws and regulatory standards in all countries in which we operate.
The Group has in place a long-established whistle-blower system (our “Speak Up Policy”) which encourages and enables employees to raise confidentially (and anonymously, if desired) any concerns or issues related to business conduct or activities, including in respect of slavery or human trafficking. This is in operation in all of the countries where the Group operates and is regularly refreshed and promoted.
We comply fully with legislation relating to the limitation of working hours and minimum pay in all countries where we operate. In all of the countries in which we operate we seek to better local communities through programmes targeted at the preservation of the environment and the development of the health, wellbeing or enlightenment of the communities we support.
Due diligence and assessment of risk
We seek to identify and do business with companies which have values and standards which are consistent with our own, including working to cascade these expectations throughout their own supply chain.
A full global audit programme is in operation across all third party manufacturing suppliers. Audits are conducted every two to three years, with more regular audits (annual or twice yearly) conducted in respect of any supplier which has given rise to any concerns or in respect of which an action plan has been established. Our preliminary assessment is based upon geography (including an assessment of countries considered to be at higher risk of slavery or human trafficking), the commodity purchased, supplier performance and the nature of the business transaction.
Over the course of the last two years ending 31 May 2016, third party manufacturing suppliers representing 50% of spend have been audited and plans are in place to cover suppliers representing 86% of total spend by the end of the 2016 calendar year. Site tours are now a formal part of the audit process, providing additional opportunities to identify any social or ethical concerns, including in respect of slavery and human trafficking.
We terminate relationships with suppliers if issues of non-compliance with our policies are identified and/or non-compliance is not addressed in a timely manner.
Effectiveness reviews and performance indicators
We are currently reviewing the appropriate performance indicators by which we may most effectively assess the effectiveness of our reviews. We plan to implement industry best practices in respect of monitoring the compliance status of suppliers during the year ending 31 May 2017.
Training and building capability
The Group Procurement Code of Business Conduct provides practical guidance and advice in respect of a range of potential situations and real-life examples. In recognition of the key role played by the Group’s Procurement team in ensuring compliance with our values throughout the supply chain, all members are required to review the Code annually with their manager and to renew their commitment to the Code in writing.
Where our audits identify any concerns or areas for improvement, we work actively with our suppliers to apprise them of our expectations and the reasons for our approach and to help them develop their own standards and policies to match our own.
This Statement is formulated by the PZ Cussons Plc Good 4 Business Committee and approved by the Board of Directors.
Chair, Good4Business Committee