Modern Slavery Act Statement



Modern Slavery Statement 2016       

Highland Spring Limited is a privately owned bottled water business established in 1979, with 5 rural bottling plants, each with their own natural water sources, and provides employment to around 500 employees.

We are committed to preventing slavery and human trafficking in our supply chain and our corporate activities.

We pride ourselves in acting ethically and with integrity in all our business dealings and relationships and expect the same high standards from our contractors, suppliers, customers and other business partners.

Responsibilities

The Chief Executive and Group Management Team are responsible for ensuring the statement is up to date and accurately reflects the Company’s actions and initiatives to tackle slavery and human trafficking.

HR and all Functional Heads are responsible for introducing polices and reviewing the process by which they are adopted.

Our Current Due Diligence

We are committed to implementing and enforcing effective systems and controls to prevent the risk of slavery and human trafficking in our supply chains. The steps we have taken to date include: 

  • Membership of the Supplier Ethical Data Exchange (SEDEX), a not for profit membership organisation dedicated to driving improvements in responsible and ethical business practices in global supply chains.
  • Adherence to the Ethical Trading Initiative (ETI) Base Code of Conduct and undertaking regular auditing across our Beacons and Fells locations.
  • Conducting half-yearly audits of our agency staff suppliers.
  • Including anti-slavery and human trafficking obligations as part of our standard raw material and packaging supplier contractual documents.
  • Implementing a formal supplier approval process across our packaging, raw materials and warehousing supplier base which incorporates:
  • monitoring SEDEX membership status of new suppliers; and
  • understanding the ethical policy status of our suppliers and their adherence to the (ETI) Base Code.

Our Continued Commitment

We will continue to develop our approach to combating slavery and human trafficking. In our 2017 financial year, we intend to:

  • Implement a corporate anti-slavery and human trafficking policy.
  • Implement ETI Base Code of Conduct audits at our Braes, Ochils and Glen locations.
  • Provide training regarding slavery and human trafficking for all our management and procurement teams to ensure they understand the risk and to provide guidance on how to report and manage any concerns.
  • Continue to review our supplier approval process. In particular, assess whether:
    • to extend the supplier approval process to cover all new haulage suppliers;
    • additional scrutiny is required for certain groups of suppliers deemed to be higher risk;
    • to impose a mandatory requirement of SEDEX membership for new packaging, raw materials, warehousing and haulage suppliers;
    • a supplier code of conduct would be an effective addition to our supplier compliance requirements.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes slavery and human trafficking statement for the financial year ending 31 December 2016 of: (i) Highland Spring Limited; and (ii) Speyside Glenlivet (HSL) Company Limited (a wholly owned subsidiary of Highland Spring Limited).

The statement was approved by the Group Management Team on 28 June 2017 and will be reviewed annually.


Les Montgomery, Chief Executive HIGHLAND SPRING LIMITED

Date: 28 June 2017

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