Modern slavery statement - March 2020 version
Modern Slavery and Human Trafficking Act statement
This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 (the “Act”) and sets out the steps that we, South Staffordshire Water Plc, trading as South Staffordshire Water and Cambridge Water, take to ensure that human trafficking and modern slavery is not taking place in our business or in our supply chain.
Our organisation
We are part of the South Staffordshire Plc group of companies. South Staffordshire Plc is the ultimate parent company of South Staffordshire Water Plc and has read and fully supports South Staffordshire Water Plc’s modern slavery and human trafficking statement. More information about South Staffordshire Plc and a copy of its statement can be found at http://www.south-staffordshire.com/.
South Staffordshire Water supplies clean water to 1.3 million people and covers an area of 1490 square kilometres, which includes Walsall, Sandwell, Dudley, Tamworth, Uttoxeter, Burton, Lichfield, Sutton Coldfield and Cannock.
The water we supply is taken from Blithfield Reservoir, the River Severn and some 26 groundwater sites located across our area of supply. On average, we supply 330 million litres of water every day, which is distributed through nearly 6000km of water mains.
Following our merger with Cambridge Water Plc. in April 2013, we also provide water to 319,000 people living in an area of 730 square kilometres around the city of Cambridge. This extends to Ramsey in the north, Gamlingay in the west, Balsham in the east and Melbourn in the south. Cambridge Water supplies high quality underground water that is pumped from boreholes in chalk aquifers.
Both businesses operate under a single water licence.
Our supply chain
Our supply chain includes contractors of varying sizes and expertise, ranging from large framework suppliers delivering significant capital works, IT suppliers delivering system solutions and business change projects and smaller services contracts and suppliers of parts and materials.
Our policy on modern slavery and human trafficking
We have a zero tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships.
We are committed to ensuring that there is transparency in our business and that there is no slavery or human trafficking in our supply chain or in any of our business operations. We expect the same high standards from all of our contractors, suppliers and other business partners.
Our Anti-Slavery, Human Trafficking and Child Labour policy reflects our commitment and zero tolerance approach.
Actions taken and our due diligence processes
Our employees
South Staffordshire Water Plc employs around 430 employees within the UK. Our recruitment process, using an independent provider, includes base line background checks for confirmation of identity, entitlement to work in the UK, criminal records and financial checks for all new staff. All hired staff, and certain supply chain providers, have these checks prior to confirmation of engagement. More thorough checks are made for staff in roles with access to clean water production and to operational telemetry.
Training
All direct staff receive information regarding our Anti-slavery, Human Trafficking and Child Labour policy through corporate and local inductions.
We also deliver training and annual refresher training to managers and certain departments, like procurement, which need additional knowledge and relevant working procedures.
Procurement
We have mapped procurement processes, which require all suppliers to demonstrate they have the right policies and procedures in place and have an embedded risk assessment process for new suppliers and reviews for existing suppliers.
As part of our contracting processes, we include specific provisions in our contracts which require all contractors, suppliers (and their suppliers) and business partners to have in place and comply with their modern slavery policy (or, if preferred, comply with our Anti-slavery, Human Trafficking and Child Labour policy), which sets out the internal monitoring, control, due diligence and record keeping procedures undertaken by them in relation to modern slavery. The standard contractual provisions also require all contractors, suppliers and business partners to comply with the Act.
We have also mapped our supply chain, identifying risk associated with the origin of source and market conditions, mitigating where possible with secondary suppliers and encouraging new entrants to the sector supply market with early engagement on new requirements.
Risk assessment
All levels of risk and any potential risk are and will be reported through our business risk matrix process. Any risks identified and ongoing compliance are reported to and investigated by our internal audit team through our South Staffs Water Audit Committee.
Raising concerns
Anyone that may have a concern about modern slavery or human trafficking is encouraged to report this to a manager in the first instance. Where the matter is not suitably resolved or it is felt more serious, this can be reported through the company Whistleblowing Policy. Matters can also be discussed informally with the Head of Legal Services.
Continuous improvement
Whilst we are proud of our current approach, we will not be complacent and will continue our efforts to develop our approach to modern slavery.
We adopt the principles and standards established by the Chartered Institute of Purchasing and Supply (CIPS). In the forthcoming year we will focus on our:
- supplier due diligence processes; and
- managing effectiveness.
This statement constitutes South Staffordshire Water Plc’s modern slavery and human trafficking statement for the financial year ending 31 March 2020 and was approved by the Board on 26 March 2020.
Phil Newland
Managing Director
South Staffordshire Water Plc
31 March 2020