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. We recognise that modern slavery continues to be a global issue and humanitarian crises. Rising social inequality and widespread labour shortages resulting from the Covid-19 pandemic only serve to increase the risks of human trafficking and forced labour. This statement outlines the steps we have taken to date, and continue to take, as a business to prevent slavery and human trafficking in our own operations and supply chains.
Our supply chain
We buy products and services from thousands of suppliers and are immensely proud of the role they play in enabling each of our operating locations to deliver outstanding levels of service and hospitality to meet our client and customer needs. Our supply chain is complex and varied and 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 but our Procurement & Supply Chain function is also responsible for the goods and services we need to run our business (GNFR – Goods and services not for resale) such as HR and professional services, technology, logistics and cleaning. Our supply chain remains incredibly diverse and provides the platform from which our businesses can grow, develop and continue to provide fantastic food and service.
STEPS TAKEN BY SEARCYS TO DATE
At Searcys, we recognise that strong governance is essential for identifying and driving out modern slavery in our business and across our supply chain, and that executive-level ownership and engagement on the issue of modern slavery is critical. The development and oversight of ethics and sustainability policies had been the responsibility of our Integrity and Ethics Committee which underwent a refresh in 2021 as we broadened its responsibilities to cover all areas classified within our Environmental, Social and Governance (“ESG”) targets and goals. Now known as the ESG Committee, we continue to have strong membership from our enabling functions such as HR, Health and Safety, Sustainability, Procurement and Supply Chain, Legal as well as Operations. As part of developing the new ESG Committee we also refreshed the terms of reference to clarify the purpose and role of the individual members and Chair. Reporting to the main Searcys board, modern slavery continues to be a permanent agenda item for the ESG Committee as it continues to take its responsibility on developing and overseeing our ethical approach in this area as a high priority.
2. Policies and contractual controls
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 our policies are underpinned by our adherence to a number of important internationally recognised standards including the UN Universal Declaration of Human Rights, core International Labour Organisation (ILO) standards, the Ethical Trading Initiative (ETI) Base Code and national and international laws. The following nine clauses guide us in how we protect and respect human rights across our operations:
- 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; and
- 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 and we have well established processes and policies in place to ensure that workers making and delivering the products and services we use or sell are treated responsibly.
Throughout 2021 we continued to adapt our ways of working to ensure that they remained fit for purpose in the face of the ongoing Covid-19 pandemic and the resultant issues created by pressures in the labour market, inflation and supply chain disruption. The nature of these additional pressures continues to impact how we identify, assess and manage risk in our supply chains as well as changing the nature and visibility of some of those risks. 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.
Any supplier wishing to work with our business will go through a detailed on-boarding process which requires them to agree and sign up to our general terms and conditions of trade, which include appropriate anti-slavery and human trafficking clauses. They are also required to agree and commit to full compliance with the following:
- our Responsible Sourcing and Ethical Trading Policy which sets out our standards in relation to ethical trading;
- our Anti-Slavery and Human Trafficking Supplier Sign-Off which relates more specifically to the Modern Slavery Act;
- the implementation of a due diligence process within their business to ensure there is no slavery and human trafficking in their supply chain (including in relation to personnel obtained via recruitment agencies); and
- that any contracts with subcontractors and suppliers also include human trafficking provisions that meet our requirements.
In addition to managing our requirements through the onboarding process, we also capture additional information through our supplier management portal where all eligible Tier 1 and Tier 2 suppliers are required to complete a Self Audit Questionnaire (SAQ) which formally records and captures the supplier’s key details, policies and 3rd party accreditation and certification. It is a requirement of our portal that these be refreshed and updated on an annual basis by the supplier for our Supply Chain Technical team to approve continued supply and adherence to our requirements and policies. We are committed to strengthening further our processes and controls around gathering key supplier information in order for us to increase visibility, identify risks and improve ethical practices across our supply chain.
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. It has been challenging to carry out site visits and see suppliers face-to-face in 2021 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 have however made good progress with our SEDEX (Supplier Ethical Data Exchange) engagement work and self-assessment questionnaires which had been temporarily put on hold in 2020 as a result of the pandemic.
Our approach to modern slavery continues to evolve as we strive to keep pace with the challenges of the changing external environment. In 2021 we focussed our activities around the following areas:
Fig 2: 2021 targets
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. Whilst we have a greater ability to influence our Tier 1 suppliers, we understand that some of our greatest ethical and human rights risks lie in our Tier 2 and 3 supply chain. Although these do not come under our direct management, we see it as a collective responsibility to work with our suppliers to understand existing and emerging risks and take appropriate action. One of the more obvious impacts of Covid-19 in our sector has been the widespread labour shortage in warehousing, processing and driving of heavy goods vehicles and we have focussed on strengthening our due diligence in the area of temporary labour both for suppliers serving our business as well as that of our suppliers.
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.
We remain 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. Throughout 2021 we continued to engage with our teams using our online platform and see this as a key area of continued development.
5. Looking ahead
With the continued development of Searcys ESG Strategy and continued oversight of this by the ESG Committee, we hope to make further progress in 2022 to further reduce the risk of Modern Slavery by working towards, or achieving, the following goals:
- collaborating with our top strategic suppliers across Tiers 1 and 2 to ensure that a minimum of 80% have a Human Rights Policy in place by end-2023;
- achieving 100% SEDEX or equivalent registration for all suppliers with fully completed SAQ’s by end-2025;
- redeveloping and launching our Supplier Code of Conduct and updating our Ethical Trading and Sustainability policy by end -2022;
- reviewing our supplier onboarding process and platforms, along with our standard terms and conditions, to ensure that supplier expectations and standards are clear, understood and reflect the changing needs of our clients and customers in the areas of ethical trading and human rights;
- growing awareness of human rights through additional e-learning tools and platforms across all our businesses with the aim of having every colleague undertake annual online training by end-2023;
- exploring the option to partner with a charity or supplier supporting the survivors of Modern Slavery;
- enlisting and instructing the services of an independent third party to complete comprehensive audits of all agencies providing temporary labour provision into our businesses by end-2022; and
- acknowledging that modern slavery is a systemic issue requiring greater collaboration and support from external partners and industry bodies, we will register and sign up to work with a verified, independent, body to help us develop our modern slavery prevention strategy.
2021 continued to highlight 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 continue to recognise that the responsible and ethical sourcing of products and services is of paramount importance as we recover both from the social and economic consequences of the Covid-19 pandemic and face increased volatility in the labour market and across our supply chain.
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 2022.
Searcy Tansley & Company Limited
28th June 2022
Searcy Tansley & Company Limited
28th June 2022
This statement has also been endorsed by:
Procurement and Supply Chain Director
28th June 2022