Modern Slavery Act Statement

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Modern Slavery Statement 2017

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.

Our Business
Highland Spring Limited is a privately owned bottled water business established in 1979, with 4 operational bottling plants, each with their own natural water sources, and provides employment to around 500 employees.

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 workers are encouraged to report any concerns they may have, and management are required to act upon them.

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. Steps 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 all operating sites. Three of our four operational sites have a programme of regular auditing in place and we have plans to extend this to the remaining site by the end of 2018.
  • • When recruiting we adopt good practice approaches to identification and reference checking, as standard we require our agency providers to do likewise. Regular audits are then carried out to assess and monitor compliance.
  • • Anti-slavery and human trafficking obligations are included as part of our standard raw material and packaging supplier contractual documents.
  • • Operate a formal supplier approval process across our packaging, raw materials and warehousing supplier base which incorporates:
  1. monitoring SEDEX membership status of new suppliers,
  2. understanding the ethical policy status of our suppliers; and
  3. as part of the continual review of our supplier approval process, SEDEX membership will now become an essential requirement for all existing and new packaging and raw materials suppliers

Policies

The requirements of the modern slavery Act 2015 are reflected within our policies and procedures. We have developed a Modern Slavery and Human Trafficking Policy, and operate the following compliance policies: Anti-Bribery, Bullying and Harassment, Whistleblowing and Ethical.

We are also preparing to introduce a supplier code of conduct which we believe will be an effective addition to our supplier compliance requirements.

Training and Awareness

We provide training regarding slavery and human trafficking for senior management and all members of our Supply Chain, Procurement and HR Teams, to ensure they understand the risk and provide guidance on how to report and manage any concerns. We support the Stronger Together UK initiative and ensure appropriate representation at relevant workshops. We intend to provide awareness training for all our employees.

Performance Measures

Whilst we do not have any designated key performance indicators against slavery and human trafficking our systems and controls regarding supplier screening and auditing allow us to periodically assess relevant policies are being adhered to. We will continue to monitor the effectiveness of our processes and take the necessary steps to improve as appropriate.

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 2017 of: (i) Highland Spring Limited; and (ii) Speyside Glenlivet (HSL) Company Limited (a wholly owned subsidiary of Highland Spring Limited).

The statement has been approved by the Group Management Team and will be reviewed annually.

CEO Signature

Les Montgomery, Chief Executive
HIGHLAND SPRING LIMITED

Date: 18th September 2018