SAPC’s Modern Slavery, Human Trafficking & Child Labour Policy

This statement sets out St Austell Printing Company’s actions to understand all potential modern slavery, human trafficking and child labour risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery, human trafficking or child labour in its own business and its supply chains.

As part of the paper and printing industry, the company recognises that it has a responsibility to take a robust approach to the slavery, human trafficking and child labour.

The company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

We will not tolerate the exploitation of children, their engagement in unacceptably hazardous work, and the physical punishment, abuse, or involuntary servitude of any worker. We expect our suppliers and contractors with whom we do business to uphold the same standards.

Organisational structure and supply chains;

• The Company produces a range of commercial print for the following sectors (not exclusively); publishing, leisure, tourism & hospitality, education, retail, legal and financial services, construction industry and the public sector.
• The supply chain includes consumables required for the production of print and is monitored by supplier approval, maintained within the company ISO 14001 quality manual.
• The Company is based on one site and operates in the UK.

Responsibility for the Company’s anti-slavery and anti child labour initiatives is as follows;

• Policies: As set out in the company handbook and company statements.
• Procedures: As set out in our recruitment policy and staff appointment procedures.
• Investigations/due diligence: Responsibility for investigation and due diligence is with all department managers with ultimate responsibility with the Directors of the Company.
• Awareness: All staff are made aware of the policy as described below.

Relevant Policies

The company operates the following policies that describe its approach to the identification of modern slavery and child labour risks and steps to be taken to prevent slavery and human trafficking in its operations;

• Whistleblowing policy The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Employee code of conduct The Company’s Handbook makes clear to employees the actions and behaviour expected of them when representing the company. The company strives to maintain the highest standards of employee conduct and ethical behaviour and managing its supply chain.
• Purchasing & Supplier Procedures The Company’s ISO 14001/9001 Environmental /Quality Procedures identifies the procedures required to ensure its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Serious violations of the company’s supplier code of conduct will lead to the termination of the business relationship.

Due diligence & Staff Awareness

The company undertakes due diligence when considering taking on new staff and new suppliers, reviewing its existing suppliers.

The company has raised awareness of modern slavery and child labour issues by sharing information via email, staff notice boards and the staff handbook to explain;

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery, human trafficking and child labour;
• what employees can do to flag up potential slavery, human trafficking and child labour issues to the relevant parties within the company

The Management team and Directors shall be responsible for this policy and for ensuring that it remains relevant through period review, however, it is the responsibility of every employee to ensure we adhere to the principles and aims set out.

Peter Moody
Managing Director
Aug 2022