Modern Slavery Statement
SEARCYS ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR FINANCIAL YEAR ENDING 30th DECEMBER 2021
Searcy Tansley & Company Limited (‘Searcys’) operates an iconic collection of restaurants, bars and venues. We work with a large number of partners, stakeholders and suppliers and recognise that every entity in our supply chain has a duty to respect human rights.
At Searcys, we are clear about our responsibility to prevent slavery and human trafficking. We have a zero tolerance approach to all forms of slavery both within our own operations and across our supply chain. This statement outlines the steps we have taken to date, and are continuing to take, to ensure that slavery and human trafficking cannot take place in any part of our supply chain and/or business.
Our supply chain
We are immensely proud of our supply chain and family of suppliers and their role in enabling each of our operating locations to source products and services to meet individual client and customer needs. We deliberately operate a decentralised supply chain model, providing our teams with the choice and ability to select from approved suppliers as opposed to creating and forcing centrally determined supply chain solutions. Our supply chain is predicated on fresh and regional supplier networks. It is incredibly diverse and provides the platform from which our business can grow, develop and continue to provide fantastic food and service.
STEPS TAKEN BY SEARCYS TO DATE
2020 was a year that saw our business, along with the lives of our colleagues and suppliers within the catering and hospitality sector, turned upside down by the impact of the COVID-19 Pandemic. This continues to present a unique set of business challenges that we are striving to overcome and whilst this has inevitably delayed the achievement of some of the targets set to improve our processes and controls further in areas of modern slavery or human trafficking, we remain determined to protect and respect the rights of the people who work within our supply chain.
Whilst we were unable to meet in person, our Integrity and Ethics Committee (which has recently become our Environmental Social Governance Committee), which is responsible for overseeing the processes we are putting in place to prevent modern slavery or human trafficking from taking place in our business and/or supply chain, continues to be fully embedded in our business and continued to meet virtually throughout 2020. Reporting to the main Board, Modern Slavery remains a permanent agenda item for the Committee as it continues to take responsibility for developing and overseeing our ethical approach as a high priority.
2. Ethical Trading Initiative Base Code
Searcys remains committed to ensuring that its dealings with its own employees, and with its suppliers, are conducted ethically and responsibly. Searcys adheres to internationally recognised human rights principles and the Ethical Trading Initiative Base Code. This Code contains the following nine clauses which are founded on the conventions of the International Labour Organisation (ILO) and are an internationally recognised code of labour practice:
- • Employment is freely chosen
- • Freedom of association and the right to collective bargaining are respected
- • Working conditions are safe and hygienic
- • Child labour shall not be used
- • Living wages are paid
- • Working hours are not excessive
- • No discrimination is practiced
- • Regular employment is provided
- • No harsh or inhumane treatment is allowed
We expect suppliers to comply with all applicable national laws in the countries in which they operate and all relevant ILO Conventions.
3. Our suppliers
Our procurement function is responsible for sourcing the goods and services that we need to run our business. Our supply chain is extensive and, even though our focus naturally lies in the food and beverage categories given the nature of our business, our standards and policies extend to all suppliers used across our operations.
2020 was a year when we had to adapt and change our ways of working to address new risks and challenges resulting from the Covid-19 Pandemic. Not only has Covid-19 impacted how we identify, assess and manage risk in our supply chains, it has also changed the nature and visibility of some of those risks. This has been compounded by geopolitical factors with the changing status for many workers as a result of the UK leaving the EU, as well as new, unanticipated, demand for products directly associated with the Pandemic. Whilst we continue to adapt, we endeavour to make sure that our standards are continuously met through a rigorous supplier on-boarding and audit process, along with regular supplier dialogue.
All new suppliers go through a detailed on-boarding process. Suppliers are then expected to update the information they provided during the on-boarding process on an annual basis for further review and approval by our supply chain team. As part of that on-boarding process, suppliers must acknowledge and commit to comply with:
- a) our Responsible Sourcing and Ethical Trading Policy which sets out our standards in relation to ethical trading; and
- b) our Anti-Slavery and Human Trafficking Supplier Sign-Off which relates more specifically to the Modern Slavery Act.
These commitments have to be made as part of the Self Audit Questionnaire (SAQ) which formally records and captures the supplier’s key details and capabilities.
A breakdown of the 1,087 suppliers registered on our Portal who submit Self Audit questionnaires annually (2020) is provided below;
Fig1: SAQ’s registered 2021.
Whilst all existing and new suppliers agree and sign up to our general terms and conditions of trade, which include appropriate anti-slavery and human trafficking clauses, the extra level of due diligence managed through our portal enables us to regularly monitor and manage adherence to our policies.
Whilst the number of suppliers registered on our Portal increased vs. 2019, not all were able to commit to agreeing to our Responsible Sourcing and Ethical Trading Policy as well as our Anti-Slavery and Human Trafficking Supplier Sign-Off. We saw this very much as being a direct result of key resources being absent as well as lockdown restrictions being forced on many suppliers as a result of the Covid-19 Pandemic. We look forward to working with our supplier base throughout the remainder of 2021 to update SAQ’s for those Categories where we have agreements outstanding
Our on-boarding process also enables us to determine which suppliers are most at risk of responsible sourcing challenges and, for those high-risk suppliers, we prioritise a site audit. The site audit allows us to understand more about what the supplier is really doing to protect their people and following this, we notify the supplier of any remedial action we believe is required. Unfortunately, throughout 2020 on-site audits were severely restricted due to the Covid-19 Pandemic but we continued to have an open dialogue with all key suppliers and managed and monitored the update of SAQ’s closely to ensure no deterioration in a Supplier’s status in complying with our Responsible and Ethical standards and requirements. We also embarked on our SEDEX (Supplier Ethical Data Exchange) audits and whilst we made progress in the first quarter of 2020 (Top 100 Suppliers approached outside of those already registered) we temporarily put the programme on hold due to the Covid-19 Pandemic. We plan to resurrect this in Q4 2021 once restrictions are lifted and resources are more freely available.
The below table summarises those actions that we committed to in our last statement along with an update on progress and 2021 plans:
Fig 2: 2021 targets, status and 2022 plans.
Our supplier expectations:
We maintain a regular dialogue with our suppliers and, with many of them, have a history of strong, long-standing relationships. We believe that this enables them to invest in the longer term and improve working standards for their employees. We see it as our responsibility to work closely with our supplier partners to ensure that they understand and implement our high standards and continue to comply with local legislation and regulations.
We will only continue to trade with those suppliers who fully comply with our Responsible Sourcing and Ethical Trading Policy and our Anti-Slavery and Human Trafficking Supplier Sign-Off or those who are taking verifiable steps towards compliance.
We see it as our responsibility to work with our suppliers to achieve 100% compliance, and if non-compliance or refusal to adhere is presented, we will work to find suitable, compliant alternatives.
4. Training and awareness
We recognise that to achieve the successful implementation of any anti-slavery and anti-human trafficking culture it is vital to train and raise awareness with those employees who have the potential to come in to contact with suppliers on a regular basis. Our intention is to continue to focus on identifying any potential risks or failures, thereby driving ever greater compliance with our high standards.
In 2020 we committed to rolling out our Ethical Trade and Modern Slavery training module to our colleagues beyond those who are directly linked to managing and assessing modern slavery and human trafficking risks in our business. Whilst early progress was made in 2020 prior to the onset of the Covid-19 Pandemic, the subsequent disruption to many of our teams and colleagues has meant that meaningful progress in this area has been temporarily arrested. Our focus in 2021 will be to re-engage with many of our colleagues returning to the business as well as increasing awareness across our locations using a variety of mixed media.
2020 was a year that highlighted the many inequalities and imbalances that exist in our society and around the world and whilst responding effectively to the direct needs within our business for wellbeing and colleague welfare, we recognise that the responsible and ethical sourcing of products and services is of increasing importance as we recover from the social and economic consequences of the Covid-19 Pandemic.
We remain dedicated to the implementation, measurement and raising of awareness and standards on modern slavery across our business and supplier base and will continue to build on the activities and progress we have made to date.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Searcys slavery and human trafficking statement for the financial year ending 30th December 2021. It was approved by Searcys Board of Directors on 28th June 2021.
Searcy Tansley & Company Limited
28th June 2021
Searcy Tansley & Company Limited
28th June 2021
This statement has also been endorsed by:
Procurement and Supply Chain Director
28th June 2021