The Wine Society is required to comply with the Modern Slavery Act 2015 by publishing an updated annual statement in June 2022. This statement highlights the steps we are taking to prevent modern slavery and human trafficking within our business and our supply chains.
Process undertaken to update statement
Our statement has been updated this year with support from an external sustainability consultancy, Herring Consultancy Limited, who have:
•Benchmarked our previous statement against the Ethical Trading Initiative’s Modern Slavery evaluation framework
•Brought the statement in line with the findings of the independant review of the modern Slavery Act (published 2021, as yet to be enacted in Parliament)
•Restructured the statement in line the above framework & findings
•Consulted internally with legal, HR, sourcing and sustainability teams to ensure all relevant policies and procedures are covered in the statement
•Updated the statement to ensure details of our organisation are correct
•Included plans for 2022 and 2023 to revise our responsible sourcing and human rights approach and bolster our activities to tackled forced and child labour.
Key differences between the 2021 and 2022 statements
As a result of the above work, the key differences between the 2021 and 2022 statements are:
•Revised structure of the statement
•Updated organisational and governance details
•Updated and expanded policies, procedures and contractual controls
•Strengthened sections on supply chain, due diligence, grievance and remediation
•Addition of a section on key performance indicators in line with government guidance
The Wine Society is committed to complying with the Modern Slavery Act 2015. This statement highlights the steps we are taking to prevent modern slavery and human trafficking within our business and our supply chains. This statement and the related processes are reviewed annually.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
The Wine Society takes a zero-tolerance approach to any activity that violates human rights. We are committed to acting ethically and with integrity in all our business dealings and relationships. We recognise that this is a global issue and we understand that it is our responsibility to prevent and mitigate the risk of such violations. We are committed to treating our staff and supply chains fairly. We regularly review and improve our practices to ensure that they are the most effectiye in protecting human rights.
The Wine Society is one of the world’s oldest member-owned community of wine lovers. Since 1874 we’ve been doing business differently, putting our members before profit to ensure fairer bottle prices for both the people that enjoy them, and for those who make them. We are committed to trading ethically and responsibly.
The Wine Society (TWS) has a head office and combined warehousing facilities in Stevenage in the UK where own-label and branded wine is packaged and distributed. We have 65 permanent staff in our warehouses and use agency workers during peak times who are recruited through five labour agencies. We have over 30 permanent staff working in our Contact Centre and can recruit up to 40 agency workers during the peak Christmas period through third party suppliers. We also employ 18 permanent drivers and use eight third-party logistics providers who hire temporary drivers that work for TWS. Our permanent warehouse workers are represented by the USDAW union.
The Society, entirely owned by its members, is overseen by a board of up to 13 members known as 'the Committee’. The Wine Society's Executive Team, which reports to the Committee, is responsible for TWS's strategic approach to identifying and tackling forced and child labour and for ensuring that appropriate measures are in place within TWS’s operations, business and supply chains. Our Senior Leadership Team take operational decisions and lead the implementation of our agreed goals and strategy. Our over 250 staff members are supported by the Head of HR and the HR team.
As of 2022, we have a newly appointed Director of Sustainability & Social Impact who will lead our approach to human rights including tackling forced and child labour. Our Director is overseeing a review of existing policies and procedures and the implementation of a formal
Responsible Sourcing and human rights approach in 2022/ 23 with support from an external sustainability consultancy.
Our supply chain
We trade with a wide range of producers, suppliers and carriers nationally and internationally. We source our wine globally from more than 800 direct suppliers in more than 23 countries across Europe, South Africa, North and South America, Australia and New Zealand. Agriculture is a high-risk sector and evidence from NGOs and research bodies such as Oxfam indicates that there will be risks on European farms particularly where migrant and casual workers are used. A significant body of research also indicates labour exploitation and forced labour risks for migrant and casual workers in vineyards in South Africa. More work is planned in 2022 to understand the specific risks of forced and child labour in our supply chains (see below).
Policies and contractual controls
The Wine Society has the following policies in place to manage the risks of forced labour and child labour in our own operations and supply chains:
1. Employee Handbook — our employee handbook is provided to all new employees.
It contains our:
a. Discipline and Grievance policy
b. Whistleblowing Policy
c. Equal Opportunities Policy
d. Health and Safety Policy
e. Driving Policy
2. Wage commitments — we monitor compliance against payment of national minimum wage and national living wages to our own directly employed operational staff on an ongoing basis by our Payroll Manager. These figures are reported to our Senior Leadership Team and Executive Team twice yearly
3 Recruitment process - we conduct robust checks on all new members of staff, including their eligibility to work in the UK to detect human trafficking or individuals being forced to work against their will. Our recruitment process is being reviewed in Q3 of 2012
4.Labour provider vetting — we have formal terms of business with the temporary agencies we use. Our process for recruiting and vetting labour providers is being reviewed in 2022
5.Anti-Corruption and Bribery Policy — our policy was updated in 202 I and applies to all members of TWS’s staff and our members who make up our board known as the “Committee". The policy will be reviewed in 2022
6. Code of Practice for Supply of Own Brand Labels — our Code of Practice provides the basic requirements that suppliers are expected to meet when supplying wines and spirits under any label bearing the name of The Wine Society. Reyiewed annually, it requires suppliers, their employees, suppliers and sub-contractors to:
a. Comply with all applicable anti-slavery and human trafficking laws, statutes and regulations
b. Comply with TWS's Anti-Slavery policy
c. Ensure their responses to the TWS’s supplier audit checklist are complete and accurate
d. Notify TWS as soon as the supplier becomes aware of any actual or suspected slavery or human trafficking; and
e. Comply with applicable laws, statutes, regulations and codes relating to anti- bribery and anti-corruption
Code of Practice for Supply of Non-Own Brand Labels — expectations for suppliers of non-own brand wine with regards modern slaves are the same as suppliers of own-brand labels (see point 6. Above). This policy is also reviewed annually
8. Anti-Slavery Policy — included in our Codes of Practice for own brand and non- own brand suppliers is our Anti-Slavery policy which lays out expectations of suppliers for identifying and preventing modern slavery
9. Contracts — where possible, we include Anti Modern Slaven clauses within our supplier agreements to make commitments contractually binding
10. Supplier self-audits — our product suppliers are asked to complete a self-audit which includes questions on concerns on modern slavery/human trafficking in the supply chain and questions about personnel
11. Legal compliance review — we review changes to regulation and our business's legal compliance, including the Agency Workers Regulations and modern slavery legislation, on a quarterly basis.
Our supplier facing policies are sent out to all new own label and non-own label wine suppliers along with our purchase order with a requirement that suppliers sign and return the Code of Practice
We are in the process of re-defining the minimum social and environmental standards applicable to any Wine Society supplier, service provider or sub-contractor, including the management of risks of forced and child labour. In 2022, we will be:
•Updating all of our internal and supplier-facing policies with input from staff and suppliers to meet the ILO's Core Conventions, including the Forced Labour Convention. This will include a human rights policy and an updated Supplier Code of Conduct
•Communicating our updated policies to relevant stakeholders
•Updating our supplier questionnaires to cover human rights and responsible sourcing including reporting against relevant national human rights and modern slavery legislation, for example the UK Modern Slavery Act or the German Supply Chain Law
•Implementing a system for data capture/ processing
•Developing supplier visit guidance/ protocols
•Developing guidance on ethical procurement practices.
Assessing risks of forced labour and child labour
Our supplier self-audits enable us to understand the topline risks of our wine suppliers. We are in the process of formalising our risk assessment of human rights, including forced labour and child labour, for our own operations and our supply chains. This risk assessment will use publicly available, reputable information about country and product risks of forced and child labour.
We anticipate that our greatest risks will be in our global supply chains at farm level and linked to indirect supply chains in particular packaging, services and the outsourcing of labour provision.
From 2022 onwards, our ongoing modern slavery risks will be informed by our risk assessment, supplier self-audits, third-party audits, grievance or whistleblowing channels or external sources. We will prioritise the risks which are most salient to our business.
Due diligence and steps to manage modern slavery risks
We have built trusted relationships with our suppliers over many years and we work closely with them to ensure they are reputable and conduct business to the same high standard as TWS.
Before we start working with suppliers, we carry out due diligence checks to satisfy ourselves that we are trading with reputable, financially viable organisations. We also ask wine producers to complete a self-audit which includes a declaration relating to modern slavery.
We expect all partners in our supply chain to be opposed to slavery and human trafficking. Our wine producers are visited frequently by buyers and staff and our quality audit covers a check that suppliers have signed our Code of Practice. This Code expects wine suppliers to take reasonable steps to ensure employees, suppliers, and sub-contractors adhere to anti- slavery and human trafficking laws, statutes and regulations. We audit our suppliers regularly on quality and will look to broaden this out to cover human rights issues in coming years.
Between 2022 and 2023, we will be strengthening how we work with suppliers to ensure continuous improvements in their approaches to identifying and tackling forced and child labour. Potential steps will include regular communication, supportive purchasing practices, third-party certification, strengthening suppliers’ engagement in, and understanding of, modern slaver}’ and increasing the number of suppliers who have effective grievance mechanisms in place.
It is mandatory for all members of staff to familiarise themselves with this statement and our Modern Slavery policy.
All new starters attend an induction with the HR Department which specifically highlights our commitment to the prevention of modern slavery. Employees are expected to familiarise themselves with the Policy annually following the publication of our annual statement. This Policy is accessible both on our website and within our Employee Handbook which will be added to the new Intranet (The Hub) during 2022.
In 2022, we will deliver training and engagement activities with relevant TWS members of staff to ensure they are up to date with emerging modern slavery risks and with changes to TWS’s policies and procedures for preventing and mitigating modern slavery. From 2023 onwards, we will deliver ongoing formalised training on human rights, including forced and child labour, to relevant staff.
Grievances and remedial actions
All employees are actively encouraged to be vigilant when it comes to identifying the risk of modern slavery. Any concerns are referred to the Executive Team, even if they are unsure about whether a particular act, or any treatment of workers or their working conditions, might constitute slavery.
All concerns are investigated with the support of the HR and Legal teams. Following a full investigation, appropriate action is taken as required.
Our staff have access to a comprehensive grievance policy and whistle blowing policy should there be a need to refer to them.
To date, there have been no reports from staff, the public, suppliers or law enforcement agencies to indicate that modern slavery practices have been identified in the business or supply chain. However, we remain alert to the threat in a rapidly changing world and continue to scrutinise any suspicious activities in our business.
Our plans for 2022 include a review of access for external whistle-blowers and using questionnaires to map whether high-risk suppliers have grievance mechanisms. We acknowledge that workers need to be involved in the development of grievance procedures and recognise that workplace grievance procedures should follow the United Nations Guiding Principles “effectiveness criteria”.
We will also be reviewing and further defining our policies and procedures with regards the remediation of cases of forced and child labour.
Key Performance Indicators
In 2022, our plan is to implement indicators which will enable us to measure the performance of our modern slavery approach. These indicators will include:
•%ge of staff in leadership positions and/ or working directly with suppliers who have been trained to understand the signs of modern slavery, the root causes and the steps they can take to reduce the risks of forced labour and child labour
•%ge of suppliers who have signed our revised Code of Practice
•%ge of direct and indirect suppliers included in our topline risk assessment
•%ge of high-risk suppliers (direct and indirect) providing information through questionnaires on how they manage the risks of forced labour and child labour, including grievance mechanisms
•%ge of grievances raised relating to forced labour and child labour.
This statement was approved by the Committee on 29 June 2022
Alan Black - Committee Chair