Slavery and Human Trafficking Statement 2017

INTRODUCTION FROM THE MANAGING DIRECTOR
Delaware North is a provider of catering and hospitality services in a number of sectors within the UK market place. It is a part of Delaware North Companies Incorporated headquartered in Buffalo, New York. The UK Company has in the region of 400 salaried employees as well as a significant database of some 5,000 individuals who work shifts on a periodic, and occasional basis. The UK head office is located in Wembley, Middlesex.

The Company recognises that modern slavery is a crime that can take many forms such as slavery, servitude, forced and compulsory labour and human trafficking. The directors and senior management team of Delaware North in the UK are fully committed to the implementation of the requirements of the Modern Slavery Act 2015.

The company is grounded in a foundation of family ownership for over 100 years and we strive to maintain those same core family values of integrity, honesty and equality for all. We are committed to increasing transparency within our supply chain and working with suppliers who share this same commitment to our end goals.

The UK turnover is in excess of £75 million annually and is split across 4 UK subsidiaries operating within sectors including sport and leisure, travel and tourism.

The UK Risk and Compliance Committee has oversight of actions taken in relation to our commitment to ensuring our supply chain is free from modern slavery and human trafficking. The committee comprised members of the senior UK leadership/directors and representatives of HR, Procurement, Finance and Safety.

OUR SUPPLY CHAINS
We are committed to working with our suppliers to build greater transparency within our supply chain. We make a commitment to act ethically and expect the same of our suppliers. All of our supplier contracts require suppliers to comply with all relevant legislation, applicable laws and our company policies. All of our tier one primary suppliers are based within the UK but many of them will be supplying goods which have been sourced and/or manufactured in other locations throughout the world and as such we are aware of the additional exposure that this may create and of the need for them to improve the transparency within their own supply chains.

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 Ethical Buying Policy 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 slavery and human trafficking is not taking place any where in our supply chains.

SUPPLY CHAIN RISK
We have identified that the risk of slavery and human trafficking in our business comes from three main areas:

  1. Our directly engaged workforce.
  2. The supply of temporary agency labour
  3. The supply of goods and services

DUE DILIGENCE PROCESSES FOR OUR WORKFORCE
All of our full time workforce are required to read and sign our employee code of conduct which outlines all of our core policies and draws attention to our confidential hotline. Additionally our Human Relations department maintains a suite of policies and procedures to protect our employees and workforce.

The nature of our business requires that we have a large variable hours’ workforce:

a) Directly engaged workers are seen by a member of our team following worker assessment days before commencing work where their right to work documentation is verified and other checks such as the bank account where they are paid is in their own name.

b) Staffing agencies providing workers are all engaged under a Service Level Agreement which they have signed up to and are audited against during the term of their contract.

We have implemented a confidential hotline which we encourage employees or any member of our wider team to use to anonymously report any area of concern. The hotline is advertised in company collateral as well as on posters displayed throughout our workplaces.

SUPPLIER ADHERENCE TO OUR VALUES
We have zero tolerance to slavery and human trafficking and expect the same of our suppliers.

As part of our initiative to identify and mitigate risk we have taken a number of steps during 2016 in order to deliver on our commitments.

RISK ASSESSMENT
An internal assessment of supply chain risk has been carried out based on such areas as availability of appropriate ethical, corporate social responsibility and employment policies, demographics of the workforce, geographical concerns, supplier audits and responses to a supplier questionnaire submitted to our top 100 suppliers (based on annual spend) in 2016, accounting for over 90% of our supplier expenditure.

AUDIT
All agencies providing labour are audited against the Service Level Agreement that they are signed up to which includes checks on the compliance with payment of the National Minimum Wage or National Living Wage as appropriate.

TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have initially provided training to our procurement team in the ‘red flags’ which can be used to help identify areas where modern slavery or human trafficking may exist.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
During the coming months we will be carrying out a review of our effectiveness in combating slavery and human trafficking as a result of the introduction of the measures outlined above in 2016 but we are considering appointing an independent 3rd party to conduct an externally facilitated review to bring insights on the ways we can further tackle slavery and human trafficking.

FURTHER STEPS

  • For future RFP processes we will be including a specific requirement for any prospective supplier to demonstrate that they are taking appropriate steps with regard to modern slavery and human trafficking. 
  • As supplier contracts come up for renewal we will be incorporating a statement on Modern Slavery and Human Trafficking which will require the supplier to demonstrate their commitment to the eradication of modern slavery within their supply chain. 
  • Online training to be provided during 2017 for all full time employees and those additional contracted hours’ employees which include an element of managing people.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending December 2016.

Doug Tetley Signature

Doug Tetley 1st September 2016
Managing Director
Delaware North – United Kingdom