Introduction
Policies
Our policies relating to ethical conduct have always prohibited human rights abuses such as child or forced labour. Following the introduction of the UK Modern Slavery Act, we are now strengthening our existing policies and taking a risk-based approach to managing modern slavery and human trafficking in our supply chain.
Our policies include:
- Code of Conduct – the code includes how SDL behaves as an organisation and how it expects its employees to act and interact with customers and suppliers.
- Whistleblowing Policy – employees can raise concerns about SDL practices without fear of reprisal
Due Diligence
Employees are required to follow our Code of Conduct and asked to report any concerns to relevant management or via the Whistleblowing process. In addition staff must complete annual training on the Code of Conduct.
Our approved key suppliers undergo initial evaluation and thereafter an annual review.
Current activities
We are undergoing a review of our compliance programme and associated controls to identify, assess and monitor risk areas in our supply chains.
We have hired a dedicated Group Compliance Officer whose responsibilities will include overseeing the programme and addressing the risks of slavery by conducting more detailed, annual risk assessments and reviewing supply chain due diligence.
Over the next 18/24 months we will be upgrading our business management systems and enhancing our Vendor Management capability and reporting.
We will develop KPIs against which we will report annually.
Signed
David Clayton
Chairman
on behalf of the SDL PLC Board