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Modern Slavery Act 2015

The Modern Slavery Act 2015 came into effect on 29th October 2015. The Act seeks to address the role of businesses in preventing modern slavery from occurring in organisations and their supply chain. The Act requires businesses in any sector which meet defined criteria to produce a slavery and human trafficking statement for each financial year of the operation.
What we have done
All Sugarmedown’s partners must be committed to eradicating modern slavery and human trafficking. Our efforts include the following:

Sugarmedown UK
Sugarmedown UK has written policies which serve to address the requirements of the Modern Slavery Act 2015. These include:

Code of Conduct
Our Code of Conduct is embedded within our organisation and serves to ensure that all members of staff are aware of their responsibilities and commitment to operating ethically, and assist them in making the right choices. Our Code of Conduct includes information on our company values, human rights and safeguarding which align closely to the requirements of Modern Slavery.

Equality and diversity
Our Equality and Diversity policy is in place to ensure that we treat people fairly and with respect from recruitment through to employment. This policy applies to our customers and our staff by fostering a culture which safeguards our customers and staff affording dignity and respect to all.

Our Safeguarding policy sets out the legislative requirements to provide a duty of care, promote positive well-being and provide a clear process for escalating concerns to protect the welfare of individuals. This includes Modern Slavery concerns. We have also introduced a Modern Slavery Reporting Procedure across our UK business. Both the Safeguarding Policy and reporting procedure have been communicated to all UK employees.

Recruitment and selection
Our recruitment process is in place to ensure that the right staff are employed by the business that demonstrate our values, have high ethical standards, are the right people for the right role and fundamentally meet the requirements of being able to work in the UK.

UK and USA supplier network and delivery partners

Suppliers of goods and services
The Sugarmedown supplier network includes suppliers of services and goods both in the UK and USA and any other areas we serve. Each of our supplier network organisations is responsible for meeting legislative and regulatory laws that govern them. However, Sugarmedown is communicating with all of its current supplier network organisations in the UK to emphasise the legal requirements of the Modern Slavery Act, and our commitment to work only with organisations that share our commitment.

Prior to working with organisations, we complete due diligence activities which include review of key policies. In addition, we have issued mandatory evaluation questionnaires to gauge current controls and processes in place aimed at eradicating modern slavery and human trafficking.

Sugarmedown Group
To assess each global organisation’s processes in relation to identifying, reporting and eradicating modern slavery we have:

Communicated the requirements of the Act and our commitment to senior leaders across our global network
Issued mandatory evaluation questionnaires to gauge current controls and process in place to eradicate modern slavery and human trafficking

What we will do
Our commitment to the eradication of modern slavery and human trafficking is certain, and to strengthen this further we will:

Have regular monitoring of how the Modern Slavery Act is being applied through audits and assurance activities across our network.

Training on the Modern Slavery Act will be made compulsory and all Sugarmedown UK staff will have a requirement to complete training on the act, including how to identify and escalate any concerns.

Continue to review and develop the policies, processes and controls in place to support our commitment to eradicate modern slavery across out global network or organisations.

Sugarmedown will develop and update this statement when required.
Colette Browne

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