Statement on Modern Slavery
Statement of Forth Ports Limited on behalf of the Forth Ports Group in relation to Modern Slavery and Human Trafficking
This statement is made pursuant to section 54(6) of the Modern Slavery Act 2015 (the “Act”) and constitutes the Group’s slavery and human trafficking statement for the financial year ending on 31 December 2019. It was approved by the board of directors at its meeting on 19 June 2020.
Forth Ports fully supports the aims of the Act and is committed to tackling slavery and human trafficking where it can. The Group has zero tolerance of slavery and human trafficking in all its different forms in any part of its business and in its supply chain.
Forth Ports Limited is the parent company of the Forth Ports Group (the “Group”). The Group owns and operates eight commercial ports on the Firth of Forth, the Firth of Tay and the Thames: Tilbury (London), Grangemouth, Dundee, Leith (Edinburgh), Rosyth, Methil, Burntisland, Kirkcaldy. We offer businesses a wide range of port-related services and help connect the UK with Europe and the rest of the world. This group statement is made in respect of Forth Ports Limited (parent) and Port of Tilbury London Limited (subsidiary). Further details of the organisation’s structure can be found at www.forthports.co.uk.
The Group’s approach to oversight of this important area reflects a commitment to act ethically and responsibly in all business relationships and to ensure that slavery and human trafficking are not present in any part of its business or in its supply chain. The Group supports and is committed to upholding the UN Guiding Principles on Business and Human Rights and is committed to developing its approach and practices so that it can detect and eradicate any non-compliant activities that it identifies.
To tackle slavery and human trafficking, the Group has continued to:
- Identify, monitor and assess categories of third party spend most at risk from slavery and human trafficking;
- Incorporate anti-slavery and human trafficking obligations into procurement agreements and subcontracting arrangements on a risk assessed basis;
- Include appropriate measures in its due diligence processes for sourcing suppliers on a risk assessed basis;
- Provide training to relevant Group employees to ensure an understanding of the risks of slavery and human trafficking and how to detect and prevent any non-compliant activities or practices in the business or its supply chain;
- Have established systems to enable whistleblowing; and
- Report its commitments, policy, performance and actions in tackling slavery and human trafficking as part of annual reporting.
Our supply chain covers a broad range of goods and services associated with the operation of our business including: third party direct labour, fixed and mobile plant and equipment, haulage, a wide range of operational and engineering goods and services as well as construction projects. As such, the Group has set standards that it expects suppliers to adhere to in its responsible procurement policy, which is issued as part of our supplier welcome packs, and introduced standard contract forms for new contracts to ensure suppliers are able to demonstrate compliance with the Act.
In May 2018, the Group received a certificate of achievement in Corporate Ethical Procurement & Supply from the Chartered Institute of Procurement & Supply (‘CIPS’). This has been renewed annually and with all procurement staff required to be recertified on this basis. As a result of this, we are also listed on the CIPS Ethical Register.
COMMUNICATION AND TRAINING
We are committed to ensuring our staff understand and are compliant with our approach to preventing modern slavery and human trafficking. The Group has provided the following training and communication on our Modern Slavery Statement:
- The CEO has written to every employee stressing our commitment to preventing modern slavery and human trafficking – a copy of this letter is provided to every new start at induction;
- All new employees, agency workers and contractors are briefed on our Modern Slavery Statement, with this statement available on our website at all times;
- All leadership roles and those that are involved in procurement activities on behalf of the Group have completed an e-learning module to ensure a high level understanding of the risks of Modern Slavery and Human Trafficking in our supply chain and business, alongside the relevant policies;
- Briefing slides have been issued to relevant employees;
- In 2019, this was supplemented with a Group wide refresher training to relevant staff to remind them of the instances, the areas where risks are more likely to exist and to encourage debate and discussion across all levels of staff.
The Group will continue to report on its approach to combat slavery and human trafficking annually at the end of each financial year including information about its consideration of:
- The due diligence processes applied by the Group in sourcing suppliers and during the course of any mergers or acquisitions;
- The risk assessment methods and steps taken to manage the risks in both the business and the supply chain;
- The effectiveness of ensuring that slavery and human trafficking is not taking place in any part of its business or its supply chains; and
- The adequacy of training arrangements to ensure that relevant Group employees have the knowledge and skills necessary to fulfil their obligations.
This statement has been approved by the Forth Ports Limited Board of Directors on behalf of the Group and covers both Forth Ports Limited and Port of Tilbury London Limited.
Chief Financial Officer
Date: June 2020