This statement is made to adhere to section 54 of the Modern Slavery Act.
It sets out our actions to understand all potential modern slavery risks related to our business and to put in place steps to ensure there is no slavery or human trafficking in our own business and our supply chains.
This statement relates to actions and activities during the financial year 1 May 2020 to 31 April 2021.
We are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.
This statement covers the activities of Shiner Limited, Shiner LLC and Shiner BV, employing over 130 employees across our three sites in Bristol UK, Los Angeles USA and Barendrecht, The Netherlands.
The Shiner board of directors is responsible for ensuring there is a satisfactory framework for managing cultural, ethical, risk and reputational matters affecting our services and products, people, customers, and vendors or suppliers.
This statement has been reviewed and authorised by our board of directors.
The core part of Shiner’s business is the distribution of products from our vendors to retailers across the UK, Europe and USA. In addition, we design products (as a licensee or for our own brands) and these products are subsequently manufactured by our suppliers across the world. Our supply chain starts with manufacture and ends with the retailer.
We are committed to the elimination of slavery and human trafficking. We expect our people to treat each other, and those we deal with, respectfully. We do not tolerate physical violence, disrespectful behaviour, bullying or harassment.
We have processes in place to help prevent modern slavery from occurring in our business. We have less control over our supply chain, but we have introduced processes and independent audits to enable us to monitor and manage this, and we
are committed to improving these processes.
Engaging with our Key Suppliers
Our relationships with our key suppliers and vendors are very important to our business success, and is a critical component of our support for human rights. Many of our suppliers are mature and established businesses who supply product to other organisations in the UK, Europe and USA.
Any supplier who is contracted by us is required to comply with all slavery and human trafficking legislation. Compliance is monitored either by the completion of a BCSI Audit, or through a signed declaration of our Code of Conduct. Any prospective supplier who fails to confirm during the procurement process that they are compliant will, without a satisfactory explanation, be disqualified from future participation.
If we become aware or suspect that an existing supplier is in breach of slavery or human trafficking legislation, we will investigate (if appropriate) and report the matter to the relevant authorities. Further we will review our relationship with that supplier which may result in termination of the contract with the supplier.
Our policies reflect our commitment to tackling modern slavery and human trafficking in both our business and supply chain. During the last financial year, we did not receive any reports of breaches internally or in relation to our suppliers. We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
- Whistleblowing policy
- Supplier code of conduct
- CSR policy statement
- Dignity at work policy
Those employees who work within our design and product development teams, engaging with our supplies, have attended external or internal training. The external training was provided by ASOS ‘Nail the Basics Workshop’. Further training will be provided during our 2021/22 financial year.
We understand that the area of the business which poses the greatest risk of slavery or human trafficking is within our upward supply chain. As a result, we undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence and reviews include:
- Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
- Evaluating the modern slavery and human trafficking risk of each new supplier
- Conducting supplier audits or assessments either through a third-party auditor or associated company auditor
- Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers via a third-party auditor
- Invoking sanctions against suppliers that fail to improve in line with an action plan or seriously violate our supplier code of conduct.
Improvements for 2021/22
Our purchasing process requires that our suppliers complete and sign our Ethical Code of Conduct statement. For suppliers who provide hardware goods, a BCSI audit is also required. It is our intention to extend this requirement for an independent audit across all our suppliers and we will have this in place before the end of April 2022.
We intend to review our internal training to ensure that all staff working with our suppliers have appropriate skills and knowledge to identify risks.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. The board approved this statement on 25 May 2021.