Modern Slavery & Support of Human Rights
Thomas Sherriff & Co is known for its commitment to social responsibility, both as an
employer and in how we conduct our business.
As a responsible SME, Thomas Sherriff & Co strives to ensure that human rights are
upheld for our employees and all workers in our supply chain. We strive to ensure that
slavery and human trafficking are absent from our supply chain.
Increasingly, governments are adopting laws aimed at eliminating slavery and human
trafficking from product supply chains. These laws require companies to analyze the risk
of the presence of modern slavery in their supply chains and to make disclosures
regarding their efforts to ensure that their supply chains are free from slavery and human
trafficking. Examples of these laws include: the California Transparency in Supply
Chains Act, the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act
2018.
Thomas Sherriff & Co is committed to compliance with applicable laws in these areas,
and Thomas Sherriff & Co engages in the following to address issues related to forced
labor, slavery, and human trafficking:
Supplier Code of Conduct:
– Our Thomas Sherriff & Co Supplier Code of Conduct establishes clear guidelines for
the standard of ethical behavior expected from our suppliers. It prohibits suppliers from
using child, forced, involuntary, or slave labor. As new suppliers enter our supply base,
our standard practice is to require suppliers to review and acknowledge their
agreement with the Supplier Code of Conduct. In addition, the Supplier Code of
Conduct is periodically reviewed and updated as appropriate.
– Our employees regularly discuss the Supplier Code of Conduct with suppliers
during supplier conferences, meetings, and performance reviews.
– Many of our standard contract templates contain language incorporating the
Supplier Code of Conduct.
Risk-based Assessments and Audits:
– Suppliers who want to enter our supply base must certify that they do not use child,
forced, involuntary, or slave labor, or engage in human trafficking.Thomas Sheriff & Co Est 1816
– We conduct periodic audits of our suppliers to identify certain risks and any
unethical behavior, including illegal employment practices or those that do not
comply with the Supplier Code of Conduct.
Supply Chain Sustainability Assessments:
– Thomas Sherriff & Co uses a third-party company to further assess the sustainability
performance of key suppliers in our supply chain. Labor and Human Rights is a core
theme in these assessments. Thomas Sherriff & Co uses the results of these
assessments in our procurement processes and sourcing decisions.
Training for Thomas Sherriff & Co Employees and Leaders:
– Annually, all Thomas Sherriff & Co salaried employees are required to review our
Code of Business Conduct and certify that they comply with it.
– The Code of Business Conduct sets forth the company’s commitment to human rights
with all of its business partners, including that the company does not use or condone
the use of any form of forced or indentured labor or human trafficking in the supply
chain, manufacturing, or distribution of our products. The Code of Business Conduct
makes clear that the company complies with child labor laws, expects others to do
the same, and will consider the compliance with such laws in its selection of suppliers.
– Salaried employees regularly receive training on the Code of Business Conduct.
Additional training courses focus on individual sections of the Code as needed. New
Thomas Sherriff & Co employees are assigned the Code of Business Conduct
training immediately upon joining the company.
– Supplier Code of Conduct training is also available to all employees. This training is
mandatory for all Supply Management & Logistics employees and covers various
topics, including human trafficking.
Internal Accountability and Controls:
Any Thomas Sherriff & Co employee, supplier, or concerned individual can
anonymously report a potential ethical violation, including human trafficking by a
Thomas Sherriff & Co supplier, through any of the following methods:
o Compliance Number: 01620 823132
o Compliance Email: haddington@thomassherriff.co.uk
o By post:
Thomas Sherriff & Co
Backburn
Letham Road
Haddington
EH41 4NN
Allegations are thoroughly reviewed or investigated by an internal team that includes
Supply Management representatives and Directors. Allegations found to be credible are
dealt with as appropriate. Suppliers that are found in violation of the Supplier Code of
Conduct may be eliminated from our supply base.
This statement was approved by the board of directors on 1st of February 2023