Slavery and Human Trafficking Statement 2019

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 500 salaried and guaranteed-hours employees as well as a significant database of some 6,000 individuals who work shifts on a periodic, and occasional basis. The UK head office is located in Uxbridge, 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 £90 million annually and is split across 5 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, IT 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 though 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 is required to read and sign our employee code of conduct which outlines all of our core policies and draws attention to our independently monitored 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:

  1. 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.

  2. 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 2017 in order to deliver on our commitments.

As part of our initiative to identify and mitigate risk we took a number of steps during 2017 in order to deliver on our commitments and during 2018 we continued that commitment.

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 supplier questionnaires.

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 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. In 2017 this was extended to all salaried employees and since mid-2017 all new full time hires across our UK business have been required to complete mandatory Modern Slavery training.


OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
No calls have been received through the confidential hotline which related to Modern Slavery. Agency audits completed to date have not identified any cause for concern. All new hires complete mandatory Modern Slavery Awareness Training.

FURTHER STEPS

  • We will be publishing our Transparency Statement on the Modern Slavery Registry website
  • The Leaning and Development Department are reviewing a refresher training module to be introduced in 2019 to ensure this subject retains appropriate focus within our business.
  • The three year roll out of a centrally controlled procurement system will be completed in Q1 of 2019 removing the ability for any supplier to provide goods or services if they have not been approved through the central procurement team.

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 2018.


Doug Tetley signature

Doug Tetley
Managing Director
Delaware North -United Kingdom
18th June 2019