Modern Slavery Statement
INTRODUCTION AND ORGANISATION STRUCTURE
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 (“the Act”) and sets out the steps that we, Speciality Drinks Limited (“the Company”) and our affiliates (The Whisky Experience Ltd, Whisky Auction Limited, and ABV Global Limited) (the “Group”) have taken and are taking to ensure that slavery and human trafficking is not taking place in our supply chain, or in any part of our business. The Group is a UK based, national and international drinks wholesaler and retailer, with over 20 years’ experience of selling to UK and international markets and is owned by The Whisky Exchange Holdings Limited.
OUR COMMITMENT
As part of the drinks industry, the Group recognises that it has a responsibility to take a robust, zero tolerance approach to slavery and human trafficking. We are committed to acting ethically, with integrity in all our business relationships, and to implementing, and enforcing, effective systems and controls to ensure slavery and human trafficking are not taking place anywhere within our Group and our supply chain.
DUE DILIGENCE AND MANAGEMENT
The Group:
• is committed to supplying high-quality products that are sourced and manufactured in a fair, ethical and environmentally responsible way;
• has a zero-tolerance approach towards modern slavery and human trafficking within its operations and supply chain;
• encourages its staff and those it works with to report any concerns they may have, in order to enable its management to act promptly on any concerns;
• has a Code of Business Conduct;
• is committed to paying staff the national minimum wage;
• maintains the appropriate registrations in the UK for its business activities;
• where possible reviews its supplier contract terms to identify compliance opportunities; and
• where possible ensures that bespoke contracts include compliance clauses.
RISK ASSESSMENT
As far as is reasonably possible, we will use external risk assessment tools such as Global Slavery Index and the International Labour Organisations Resources on Forced Labour and Trafficking to assess and monitor sector and geographical risks.
RELEVANT POLICIES
The following policies / processes outline the Group’s approach to the identification of modern slavery risks, and steps to be taken to prevent slavery and human trafficking in its operations:
• Whistleblowing Policy: The Group encourages its staff, customers and other business partners to report any concerns related to both the direct activities and supply chains of the Group. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
• Employee Handbook: The Group's induction programme and handbook makes clear to staff the actions and behaviour expected of them when representing the Group. The Group strives to maintain the highest standards of employee conduct and ethical behaviour when operating within the UK and internationally.
• Recruitment Agencies: The Group uses only specified, reputable employment agencies to source from the labour market, and always verifies the practices of any new agency prior to working with them. We conduct robust checks on any new employee, including eligibility to work in the UK, to safeguard against human trafficking or individuals being forced to work against their will.
KEY PERFORMANCE IDICATORS TO MEASURE EFFECTIVENESS
We will continue to monitor the effectiveness of our compliance regime and take necessary steps to address any identified instances of slavery and human trafficking and to ensure that breaches of the Group’s Anti-Slavery Policy are reported.
TRAINING
Training / guidance on the Group’s Anti-Slavery Policy and the risks of modern slavery and human trafficking in our business and in our supply chains is available to staff.
APPROVAL OF STATEMENT
This statement has been approved by the Company’s Directors on 8 July 2024 for the financial year ending 30th June 2024. This statement will be reviewed on an annual basis and will be updated if necessary.