Modern Slavery Policy
Modern Slavery Policy
Introduction
GM Packaging Ltd is committed to preventing modern slavery and human trafficking in all its forms within our operations and supply chains. This policy outlines our commitment to comply with the Modern Slavery Act 2015 and our approach to ensuring that slavery, servitude, forced or compulsory labour, and human trafficking do not occur within our organization or any of our supply chains.
Policy Statement
GM Packaging Ltd prohibits the use of slavery, servitude, forced or compulsory labour, and human trafficking in any of its operations or supply chains. We are committed to conducting business ethically and with integrity, and we expect the same standards to be upheld by all individuals and organizations we engage with.
Adherence to Local and National Laws
GM Packaging Ltd is committed to adhering to all local and national laws and regulations related to labour and employment practices, including but not limited to the Modern Slavery Act 2015 and relevant international conventions and standards.
Workers' Rights
GM Packaging Ltd upholds the following rights for all workers:
Freedom to terminate their employment at any time with reasonable notice.
Freedom of movement within the workplace and outside of working hours.
Freedom of association, including the right to join or form trade unions and engage in collective bargaining.
Prohibition of Violence, Harassment, and Intimidation
GM Packaging Ltd strictly prohibits any form of violence, harassment, or intimidation against workers in any aspect of their employment, including recruitment, training, and daily work activities.
Prohibition of Worker Paid Recruitment Fees
GM Packaging Ltd prohibits the charging of recruitment fees to workers by any party, including labour recruiters and employment agencies. Workers shall not be required to pay any fees or expenses related to their recruitment, employment, or deployment.
Prohibition of Compulsory Overtime and Child Labor
GM Packaging Ltd prohibits the use of compulsory overtime and child labour in any of its operations or supply chains. We do not employ workers under the age of 18 in hazardous work or under any conditions that may jeopardize their health, safety, or moral development.
Prohibition of Discrimination
GM Packaging Ltd prohibits discrimination in any aspect of employment, including recruitment, hiring, promotion, and termination, based on race, colour, gender, age, religion, disability, sexual orientation, or any other characteristic protected by law.
Protection of Workers' Rights
GM Packaging Ltd prohibits the confiscation of workers' original identification documents, including passports, identity cards, and work permits, by any party. Workers shall retain possession of their original identification documents at all times.
Access to Remedy and Compensation
GM Packaging Ltd is committed to providing access to remedy, compensation, and justice for any worker who has been subjected to modern slavery or human trafficking within our organization or supply chains. We have established mechanisms for reporting grievances and complaints, and we ensure that all reports are thoroughly investigated and addressed in a timely and transparent manner.
Fair Treatment of Suppliers
GM Packaging Ltd recognizes the importance of fair and ethical treatment of our suppliers in preventing modern slavery and human trafficking. We are committed to fostering positive relationships with our suppliers and ensuring that our business practices do not contribute to exploitation or unfair treatment.
We acknowledge that placing unreasonable expectations on suppliers, such as aggressive pricing demands, short lead times, late high volume orders, inaccurate forecasting, late or extended payment terms, withdrawing from contracts at the last minute, or imposing unfair penalties for not meeting orders due to last minute changes, can create undue pressure and increase the risk of labour abuses within their operations.
Therefore, GM Packaging Ltd endeavours to work collaboratively with our suppliers to establish fair and reasonable terms of engagement. We strive to provide accurate forecasting, reasonable lead times, and timely payments for goods and services rendered. We communicate openly and transparently with our suppliers, ensuring that technical specifications are clearly defined and any changes are communicated in a timely manner.
By treating our suppliers fairly and ethically, we aim to create a supply chain that is resilient, sustainable, and free from exploitation.
Integration of Modern Slavery Risks in Purchasing Process
GM Packaging Ltd recognizes the critical importance of considering modern slavery risks throughout the purchasing process to prevent exploitation and uphold ethical standards. Therefore, we have implemented measures to address modern slavery risks at various stages of the purchasing process, including tender evaluation, contract award, in-life contract management, and end of contract review.
Tender Evaluation: During the tender evaluation process, GM Packaging Ltd assesses potential suppliers not only on the basis of cost and quality but also on their commitment to ethical labour practices. We evaluate suppliers' policies, procedures, and track records related to modern slavery prevention to ensure alignment with our values and standards.
Contract Award: When awarding contracts, GM Packaging Ltd prioritizes suppliers who demonstrate a clear commitment to preventing modern slavery and human trafficking within their operations and supply chains. We include clauses in contracts that require suppliers to adhere to our Modern Slavery Policy and comply with all relevant laws and regulations.
In-Life Contract Management: Throughout the duration of contracts, GM Packaging Ltd actively monitors and manages suppliers' compliance with our Modern Slavery Policy. We engage with suppliers regularly to assess their performance, address any issues or concerns, and provide support and guidance as needed to ensure ongoing adherence to ethical labour practices.
End of Contract Review: At the conclusion of contracts, GM Packaging Ltd conducts a comprehensive review of suppliers' performance, including their compliance with our Modern Slavery Policy. We assess whether suppliers have effectively mitigated modern slavery risks and fulfilled their obligations under the contract. This review informs our decisions regarding future engagements with suppliers.
By integrating modern slavery risk considerations into every stage of the purchasing process, GM Packaging Ltd demonstrates its commitment to ethical sourcing and the prevention of modern slavery and human trafficking.
Identification of High-Risk Environments
GM Packaging Ltd acknowledges that the highest risk of modern slavery within our organization and supply chains is often found in manufacturing environments where vulnerable groups, including migrant workers, refugees, women, and children, are prevalent. These groups are particularly susceptible to exploitation due to factors such as language barriers, lack of legal documentation, socioeconomic vulnerability, and limited access to support networks.
We recognize the importance of identifying and addressing the specific risks faced by these vulnerable groups to effectively prevent modern slavery and human trafficking. GM Packaging Ltd is committed to implementing targeted measures to safeguard the rights and well-being of all individuals within our organization and supply chains, with a particular focus on those who may be most at risk.
By acknowledging and addressing the unique vulnerabilities of migrant workers, refugees, women, and children, GM Packaging Ltd demonstrates its commitment to promoting inclusivity, diversity, and respect for human rights throughout our operations and supply chains.
Supplier Risk Assessment
GM Packaging Ltd has conducted thorough investigations into all tier 1 suppliers within the last 12 months to assess their risk of involvement in modern slavery and human trafficking. We are pleased to report that our investigations have found none of our tier 1 suppliers to be at higher risk of modern slavery during this period.
These assessments are part of our ongoing commitment to ensuring ethical sourcing practices and preventing exploitation within our supply chains. GM Packaging Ltd remains vigilant in monitoring and addressing modern slavery risks and will continue to engage with suppliers to uphold the highest standards of ethical conduct.
Collaboration with Non-Governmental Organizations and Businesses
GM Packaging Ltd is committed to collaborating with non-governmental organizations (NGOs) and other businesses to support efforts aimed at preventing and mitigating modern slavery and human trafficking. We recognize that addressing these complex issues requires a multi-stakeholder approach and collective action from governments, businesses, civil society, and the international community.
We actively seek opportunities to partner with NGOs, industry associations, and other stakeholders to share best practices, leverage resources, and collectively advocate for policies and initiatives that promote ethical labour practices and protect the rights of workers.
By working collaboratively with external partners, GM Packaging Ltd aims to amplify our impact, enhance our understanding of modern slavery risks, and contribute to meaningful change within our industry and beyond.
Investigation of Debt Bondage
GM Packaging Ltd is committed to thoroughly investigating any allegations or situations of debt bondage that may arise as a result of how employees were recruited within our supply chain. We take such allegations seriously and are dedicated to ensuring the fair and ethical treatment of all workers involved in our operations and supply chains.
Should any instances of debt bondage be brought to our attention, GM Packaging Ltd will conduct prompt and thorough investigations, working collaboratively with relevant stakeholders, including affected individuals, suppliers, and external experts. We will take appropriate actions to address the root causes of the issue, mitigate harm, and prevent its recurrence in the future.
Our commitment to investigating and addressing debt bondage reflects our values of integrity, respect for human rights, and accountability. GM Packaging Ltd is committed to upholding the highest standards of ethical conduct and promoting fair and dignified working conditions for all individuals within our supply chain.
Access to Grievance Mechanism
GM Packaging Ltd provides access to a confidential grievance mechanism for reporting incidents or suspected incidents of modern slavery within our organization or supply chains. We are committed to creating a safe and supportive environment where individuals feel empowered to raise concerns without fear of retaliation.
Our grievance mechanism allows employees, suppliers, contractors, and other stakeholders to report any suspected violations of our Modern Slavery Policy or ethical labour practices. Reports can be made anonymously if desired, and all concerns will be treated with the utmost seriousness and confidentiality.
GM Packaging Ltd is dedicated to thoroughly investigating all reports received through our grievance mechanism and taking appropriate action to address any identified issues. We are committed to continuous improvement and will use feedback from the grievance mechanism to enhance our policies, procedures, and practices related to modern slavery prevention.
Supplier Compliance and Termination Clause
In the event that a supplier is found to be non-compliant or non-responsive in addressing a report of modern slavery within their operations or supply chains, GM Packaging Ltd reserves the right to assess their position with a view to terminating trade with them, as outlined in our service level agreement.
GM Packaging Ltd takes allegations of modern slavery and human trafficking very seriously, and we expect our suppliers to demonstrate a proactive and cooperative approach in addressing any identified issues. Failure to respond appropriately to reports of modern slavery may be considered a breach of our ethical standards and contractual obligations.
If, following a thorough investigation, a supplier is found to be non-compliant with our Modern Slavery Policy or fails to take adequate steps to address modern slavery risks, GM Packaging Ltd will initiate discussions with the supplier to address the concerns raised. Depending on the severity and nature of the non-compliance, termination of trade with the supplier may be necessary to uphold our commitment to ethical sourcing and prevent further harm.
This clause underscores GM Packaging Ltd's unwavering commitment to eradicating modern slavery and human trafficking from our supply chains and holding our suppliers accountable for their actions.
Staff Training on Modern Slavery
GM Packaging Ltd is committed to providing relevant and regular training to all staff members on the identification, prevention, and response to modern slavery and human trafficking. We recognize that education and awareness are key components of our efforts to combat these crimes effectively.
Our training programs cover various topics, including:
Understanding the nature and prevalence of modern slavery and human trafficking.
Recognizing the signs and indicators of modern slavery in different contexts.
Understanding the legal and ethical obligations under the Modern Slavery Act 2015 and other relevant legislation.
Reporting mechanisms and procedures for addressing suspicions or incidents of modern slavery.
Responsibilities and roles of staff members in preventing and mitigating modern slavery risks within our organization and supply chains.
GM Packaging Ltd regularly reviews and updates its training materials to ensure they remain current and relevant to the evolving nature of modern slavery risks. We encourage active participation and engagement from all staff members to foster a culture of awareness, vigilance, and accountability throughout our organization.
By providing comprehensive training, GM Packaging Ltd aims to empower staff members with the knowledge and skills needed to identify and address modern slavery effectively, thereby contributing to the protection of human rights and the prevention of exploitation.
Modern Slavery Training Content
GM Packaging Ltd ensures that our modern slavery training covers a comprehensive range of indicators as outlined by the International Labour Organization (ILO). These indicators are crucial for recognizing potential instances of modern slavery and human trafficking within our organization and supply chains. Our training includes, but is not limited to, the following key indicators:
Abuse of Vulnerability: Exploiting individuals who are in vulnerable situations, such as migrants, refugees, or those facing economic hardship.
Deception: Providing false information or promises to deceive individuals into exploitative situations.
Restriction of Movement: Imposing restrictions on the freedom of movement of workers, preventing them from leaving their place of work or residence.
Isolation: Keeping workers isolated from the outside world, including their families and communities, to maintain control over them.
Physical and Sexual Violence: Subjecting workers to physical or sexual abuse as a means of control or coercion.
Intimidation and Threats: Using threats or intimidation tactics to instill fear and prevent workers from asserting their rights.
Retention of Identity Documents: Confiscating or withholding workers' identity documents, such as passports or identification cards, to restrict their freedom of movement.
Withholding of Wages: Failing to pay workers their rightful wages or withholding payment as a form of control.
Debt Bondage: Trapping workers in a cycle of debt by requiring them to repay loans or advances through labour, often under exploitative conditions.
Abusive Working and Living Conditions: Subjecting workers to harsh or inhumane working conditions, including inadequate housing, sanitation, and safety standards.
Excessive Overtime: Forcing workers to work long hours beyond legal limits or without adequate rest periods.
By incorporating these indicators into our modern slavery training, GM Packaging Ltd aims to equip staff members with the knowledge and awareness necessary to identify and address potential instances of modern slavery effectively.
Key Performance Indicators (KPIs) for Modern Slavery Mitigation
At GM Packaging Ltd, we have established key performance indicators (KPIs) to measure our efforts in mitigating modern slavery within our organization and supply chain. These KPIs focus on enhancing awareness, capacity building, and response mechanisms to effectively address modern slavery risks. Our main KPIs include:
Frequency of Training and Capacity Building: We measure the frequency and effectiveness of training and capacity building initiatives on modern slavery issues for our staff. This includes tracking the number of training sessions conducted, participation rates, and feedback from staff members. By regularly training our staff, we aim to enhance their understanding of modern slavery risks and empower them to identify and respond to such situations effectively.
Changes in Awareness of Risk: We assess changes in awareness levels among our staff regarding modern slavery risks. This involves conducting pre- and post-training surveys to gauge the impact of our training programs on staff awareness and knowledge of modern slavery indicators, reporting mechanisms, and grievance procedures. By monitoring changes in awareness, we can identify areas for improvement and tailor our training efforts accordingly.
Grievance Procedures/Whistle-blowing Procedures: We track the utilization and effectiveness of our grievance procedures and whistle-blowing mechanisms for staff to report suspected cases of modern slavery. This includes monitoring the number of reports received, response times, investigation outcomes, and actions taken to address reported cases. By ensuring robust grievance procedures and whistle-blowing mechanisms, we provide staff with channels to raise concerns confidentially and receive appropriate support and follow-up.
By setting and monitoring these KPIs, GM Packaging Ltd demonstrates its commitment to continuous improvement and accountability in addressing modern slavery risks throughout our organization and supply chain.
Conclusion
GM Packaging Ltd is dedicated to continuously improving our practices to prevent modern slavery and human trafficking. We are committed to working collaboratively with our employees, suppliers, and other stakeholders to uphold the highest standards of ethical conduct and to create a work environment free from exploitation and abuse.
Approved By: Kelvin Carruth
Signature:
Date: 9th May 2024
GM Packaging Ltd.