This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes the SUEZ anti-slavery and human trafficking statement for the financial year ending 31 December 2019.
We recognise that slavery, servitude, forced labour and human trafficking (Modern Slavery) are world-wide and growing issues. Our sector has been specifically targeted by perpetrators of this type of crime. As a leading water, waste management and recycling business in the UK, the company recognises the need to adopt a robust approach to slavery and human trafficking. We commit to identifying areas of risk within our business and developing strategies to prevent and to manage those risks proactively.
Our statement this year builds on the previous two years and outlines where we have been, where we are and what our plans are to ensure that we mitigate our risk of modern slavery.
Organisational structure and supply chains
SUEZ operates at over 300 sites across the UK providing recycling and recovery services, and water services. Our business headquarters are in Maidenhead, UK and we employ over 5,500 people across the UK Group. The following companies are covered by this statement:
SUEZ Recycling and Recovery UK Ltd
SUEZ Recycling and Recovery South East Ltd
SUEZ Recycling and Recovery Lancashire Ltd
SUEZ Recycling and Recovery Tees Valley Ltd
SUEZ Recycling and Recovery Surrey Ltd
SUEZ works with thousands of suppliers. We are aware of the risks of modern slavery within the supply chain and have developed our procurement team’s competence on the identification of these risks and the actions needed to mitigate or manage them.
Policies and contractual control
SUEZ has in place the following policies and procedures that set out its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Anti-Slavery and Human Trafficking Policy and Procedure – reviewed annually.
- Whistleblowing Policy – SUEZ uses an independently provided whistleblowing hotline, which provides an easy and confidential means for concerns to be raised. We investigate every whistleblowing case and seek to achieve a resolution as soon as practicable.
- Employee Assistance Programme – provides an external and confidential support service by telephone through which advice and information are imparted to employees across a wide range of topics. This service also includes face-to-face counselling.
- Wellness Charter – our culture promotes and actively supports the wellness of all of us, every day.
- ‘We hear’ confidential employee support line, run by employees for employees.
- Supplier Code of Conduct – suppliers are required to confirm that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
- Sustainable Procurement Policy – this strives to gain supply chain transparency and source products, materials and services using credible and recognised sourcing and certification schemes, where available. It also aims to help us identify and address human rights abuses and labour exploitation in our supply chain.
Identification of risk and steps taken to prevent and manage risk
SUEZ recognises that expert advice on identifying and managing modern slavery risks is beneficial. SUEZ joined Slave-Free Alliance in August 2019, who then carried out a gap analysis in October 2019.
Following their recommendations, a working party was established to identify risk areas within our business, producing a road map to set out how those risks will be mitigated, a timeline for action and measures to ensure that these are regularly reviewed, as it is recognised that modern slavery is a constantly changing challenge.
In addition, SUEZ recycling and recovery UK has signed up to the Sustainable Development Strategy framework to ensure we live in a better world by 2030. All United Nations member states have signed to take action such as:
Sustainable Development Goal #8
Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.
Take immediate and effective measures to eradicate forced labour, end modern slavery and human trafficking and secure the prohibition and elimination of the worst forms of child labour, including recruitment and use of child soldiers, and by 2025 end child labour in all its forms.
Due diligence processes with our supply chain
We have a Supplier Code of Conduct that all of our suppliers are required to agree to. This includes a commitment from suppliers to comply with labour standards based on the conventions of the International Labour Organisation within their own organisations and within their supply chains. Our Anti-Slavery Policy is also supplied within information provided to all new suppliers to ensure they are aware and that there is no ambiguity in the SUEZ position with regards to modern slavery.
The supply chain has been risk-assessed at a high level and this has identified that our agency worker suppliers and managed service providers are an area of potential risk. As a result, labour provider audits are included as a standing agenda item in Supplier Relationship Management meetings with these suppliers. Both our suppliers for agency workers and managed services are members of Slave-Free Alliance and are proactively undertaking additional checks to ensure that no workers supplied to SUEZ are being exploited.
Training and building capacity
We have worked with Hope for Justice to deliver awareness training to over 100 line managers in areas of our business that were considered at risk in recent years. This supported onsite awareness campaigns with posters explaining what modern slavery is and how to raise concerns in the workplace.
As part of our commitment to eradicating modern slavery, we intend to build on our knowledge and capacity in relation to slavery and human trafficking by ensuring that we target key areas within our business. This is supported by our Board of Directors who, in November 2019, received an executive training session and briefing from Slave-Free Alliance.
Our action plan for 2020-2021 is to carry out further training needs analysis within at-risk sites in order to provide targeted learning in the most appropriate and effective manner. The initial stage was scheduled for March 2020. However, the COVID-19 pandemic has led to this being postponed to later in the year. This will then be followed up with classroom (where social distancing allows this) and web-based learning interventions.
Next steps 2020/2021
- Embed current good practice with high-risk tier-one suppliers, extend this to tier-two suppliers and review current labour providers through audit.
- Extend risk assessment to tier-two suppliers ensuring that any remedial action is in place by end of quarter three and completed by May 2021.
- Review and extend our Supplier Code of Conduct to ensure that it includes high-risk tier-two labour suppliers by May 2021.
- Carry out a training needs analysis, design and deliver an appropriate solution, and initiate a review of its impact by end of 2020.
- Develop a formalised response plan, including remediation of victims and circulate to line management and human resources teams by the end of 2020.
The Company will consider the impact on any person working for us, or on our behalf, who believes they are a victim of slavery, human trafficking or forced labour, and aims to support any such person, including assisting that person in reporting this concern to the appropriate authorities.
This statement has been approved by the board of SUEZ on 01 June 2020 who will review and update it annually.
John Scanlon, Chief Executive Officer, SUEZ recycling and recovery UK