2015 Modern Slavery Act

Introduction

This Act noted that slavery and human trafficking remains a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. This Act requires businesses of a certain size to produce an annual statement setting out the steps they have taken to ensure there is no modern slavery in their own business and their supply chains. The measure is designed to create a level playing field between those businesses, which act responsibly and those that need to change their policies and practices.

Our business

Simpsons Malt is a manufacturer of malt, primarily for the food and drink sector and an agricultural merchant operating under the trading names of McCreath, Simpson & Prentice and John Guthrie. Simpsons Malt has its head office in Berwick-upon-Tweed and all trading outlets are in the UK.

Our supply chains

Our supply chain includes the sourcing of raw materials principally related to the provision of malt for the food and drink industries and is typically a UK based supply chain.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery, or human trafficking, in our supply chains, or in any part of our business. Our compliance with this Act reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure this in our own business and spreading the message to our supply chain.

Delivering on this commitment became the specific responsibility of Human Resources Director Martin Tilstone and McCreath, Simpson & Prentice Commercial Director Andy Hindhaugh.

In the first quarter of 2016, a decision was taken on behalf of Simpsons Malt to undertake the following:

• A letter was sent to our supplier base of approximately 2,500 stating:

“We ensure all our own employees have a legal right to work, that they are registered for and pay their appropriate National Insurance contributions and that relevant legislation with respect to health & safety, minimum wage, working time and pension enrolment are followed.

• We went on to explain that our expectation from our suppliers was that they do the same and trade ethically.
• Recognizing that the law can be complex in these areas, Simpsons Malt offered to review supplier policies, provide feedback and assist in achieving compliance.

In early 2017, there was the need to consider if this mailing should be repeated and built on, but it was felt that too frequent repetition would dilute its power and it was noted that replies to our previous letter were still being received from suppliers as late as Quarter 3, 2016. It was decided to target further steps in early 2018.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with our values.

Governance & review

This statement detailing our approach to the Modern Slavery Act in its second year has gone to the Board of Directors in June 2017 and a review of activity will continue to occur annually.

On behalf of the Board

Richard Simpson

Vice-Chairman
1 June 2017