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 2020. It was approved by the board of directors at its meeting on 27 May 2021.
Forth Ports Limited fully supports the aims of the Act and 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 in the United Kingdom (Tilbury, Grangemouth, Dundee, Leith, Rosyth, Methil, Burntisland and Kirkcaldy) and is a key employer in these local communities. We offer customers 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 takes it social responsibility seriously and is committed to conduct business in compliance with the highest ethical standards. 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 committed to the following:
- Applying high employment standards complying with relevant employment, health and safety and human rights laws to ensure our employees are safe and secure when at work;
- Identifying, monitoring and assessing categories of third party spend most at risk from slavery and human trafficking;
- Incorporating anti-slavery and human trafficking obligations into procurement agreements and subcontracting arrangements on a risk assessed basis;
- Including appropriate measures in its due diligence processes for sourcing suppliers on a risk assessed basis;
- Providing training to 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;
- Having established systems to enable whistleblowing; and
- Reporting 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, leasing of plant and equipment, haulage, a wide range of operational and engineering goods and services as well as capital investment in construction projects such as the newly operational Tilbury2. 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 pack as well as standard contract forms for new contracts to ensure suppliers are able to demonstrate compliance with the Act. We stipulate that all suppliers must have a Modern Slavery Statement or agree to adhere to ours. In addition we perform contractor audits which include a review of evidence that employees are eligible to work in the UK.
In 2018 the Group received a certificate of achievement in Corporate Ethical Procurement & Supply from the Chartered Institute of Procurement & Supply (‘CIPS’). This is renewed annually, 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 employees 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 emphasising 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 and this statement is available on our website;
- 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;
- In 2020, cognisant of the challenges being faced as a result of COVID-19 and with many relevant staff working from home, existing practices were supplemented with a Group wide update including a poster campaign.
The Group will report on its approach to combat slavery and human trafficking annually 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 2021