Anti Slavery Policy
This statement is formulated inline with Modern Slavery Act 2015 and sets out the steps that Lister Wilder has taken, and is continuing to follow, to make sure that modern slavery or human trafficking is not taking place within our business or supply chain. This statement is a living document and will be reviewed annually by the Company Board. We will ensure we remain current with UK Government legislation though due-diligence and continue to develop staff and contractors in their respective knowledge and understanding.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Lister Wilder has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
ABOUT THE ORGANISATION
Lister Wilder specialise in supplying and maintaining machinery for 4 key markets:
Lister Wilder directly employs in excess of 230 staff with a much smaller number indirectly employed operating across 9 sites. Established in 1947, we remain a wholly owned family business and this has certainly been a factor in attracting and retaining the very best staff in the industry. It’s their knowledge and expertise that allow us to make the leap from being ‘just another machinery dealer’ into one of the most focussed, customer friendly, and exciting Dealerships in the South of England. We are proud of our achievements and our reputation and we are within the UK Top 4 AGCO Company’s. We also hold the Gold Service Dealership Award from Kubota and conform to Achilles B2 process.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
Lister Wilder is aware of our responsibilities towards customers, employees, the local community and ensure all suppliers to Lister Wilder adhere to the same ethical principles. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our internal policies replicate our commitment to acting ethically and with integrity in all our business relationships. Currently all awarded suppliers sign up to our terms and conditions of contract which contain a provision around Good Industry Practice to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains; and that they conduct their businesses in a manner that is consistent with Lister Wilder’s anti-slavery policy. We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- RECRUITMENT POLICY We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all directly employed staff and agencies.
- EQUAL OPPORTUNITIES We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment and access to training and development opportunities.
- ANTI-BRIBERY POLICIES We adhere to all parts of the Bribery Act 2010 and operate a zero-tolerance policy. Clear guidance is given so that our employees are informed on how to raise concerns about how colleagues or people who maybe / are being approached or about possible Bribery practices within our business or supply chain.
- WHISTLEBLOWING POLICY We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated or about practices within our business or supply chain, without fear of reprisals.
- STANDARDS OF BUSINESS CONDUCT This code explains the way we behave as an organisation and how we expect our employees and suppliers to act.
OUR SUPPLY CHAIN
We have significant suppliers within the business, predominantly Agco providing 40%, Kubota 30% and other suppliers combined at 30%. Both Agco and Kubota have rigorous policies that we, as authorised dealers, conform to. Our approach to procurement and our supply chain includes:
- Ensuring that our suppliers are carefully selected through our robust supplier selection criteria/processes.
- We have a risk-based approach towards auditing/gaining assurance from suppliers and any contractors.
- Ensuring invitation to tender documents contain a clause on human rights issues.
- Ensuring invitation to tender documents also contains clauses giving Lister Wilder the right to terminate a contract for failure to comply with labour laws.
- Using the standard Supplier Selection Questionnaire (SQ) that has been introduced (which includes a section on Modern Day Slavery). https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/558520/PPN_8_16_StandardSQ_Template_v3.pdf
- Lister Wilder staff must contact and work with the Procurement Department when looking to work with new suppliers, so appropriate checks can be undertaken.
- Supplier adherence to our values. We are zero tolerant to slavery and human trafficking and thereby expect all our direct and indirect suppliers/contractors to follow suit.
- Where it is verified that a subcontractor has breached human trafficking, then this subcontractor will be excluded in accordance with this Policy.
Advice and training will be supplied on modern slavery and human trafficking to staff through our compulsory staff induction training plan. For existing staff, we continue to raise awareness through proactive means, such as:
- Information boards in rest areas
- Via our internal email system as company notices
We are committed to looking at ways to continuously increase awareness within our organisation and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business. Tool box talks, team briefings and company newsletters will be used at suitable times.
OUR PERFORMANCE INDICATORS
We will know the effectiveness of the steps that we are taking to ensure that slavery and / or human trafficking is not taking place within our business or supply chain if:
- No reports are received from our staff, the public or law enforcement agencies to indicate that modern slavery practices have been identified.
- Engage with potential new business suppliers/contractors, ensuring due-diligence is completed prior to securing new business/supply contracts.
- Reviewing the completion of in-house online training for staff.
Through structured and regular Directors meetings, the Chair will ensure Group Directors understand the requirements and ensure Directors drive compliance within their area of responsibility. Directors are to engage with Line Managers at Group level to ensure proactive leadership is current and informative to all staff.
COLLABORATION ACROSS INDUSTRY
We are proud members of The British Agricultural and Garden Machinery Association (BAGMA). Being members of BAGMA, we are obliged to uphold the Codes of Conduct set by the association and remain vigilant to any changes.
APPROVAL FOR THIS STATEMENT
This statement will be presented for approval at the Management Board on Monday 8th April 2019 and will follow the UK Tax Year thereafter.