Modern Slavery Act 2015
Slavery and Human Trafficking Statement
Smurfit Kappa UK Ltd is committed to eliminating the risk of forced labour and human trafficking occurring in our direct operations and supply chain and we welcome the requirements set out in the UK Modern Slavery Act. We will continue to comply with the legislation and ensure our culture and actions reflect a no tolerance approach to modern slavery.
OUR GLOBAL BUSINESS
We are a FTSE 100 company and one of the leading providers of paper-based packaging solutions in the world, with around 45,000 employees in approximately 370 production sites across 34 countries and with a revenue of €8.2 billion in 2016. We are located in 21 countries in Europe, and 13 in the Americas and the only large-scale pan-regional player in Latin America. We have an unrivalled portfolio of paper-packaging solutions, which is constantly updated with our market-leading innovations. This is enhanced through the benefits of our integration, with optimal paper design, logistics, timeliness of service, and our packaging plants sourcing most of their raw materials from our own paper mills.
BUSINESS IN NUMBERS
OUR UK BUSINESS
Our UK business operations include 2 paper mills in our Paper division, 6 recycling plants in our Recycling division, 32 manufacturing operations and various office locations in our Corrugated division. Our external supplier network is predominantly based in the UK and Europe. Our Global Sourcing Category Management team coordinate the sourcing of each main category within SK, ensuring consistent oversight of our suppliers and their compliance with our expectations. They are assisted by a team of Project Managers for Group tenders and sourcing Cost-Take-Out and Best Practice projects. They work in partnership with all operations and in close cooperation with Country/ Business Sourcing Coordinators.
OUR COMMITMENTS AND CAPACITY BUILDING
Smurfit Kappa UK Ltd is committed to the application of the principles expressed in the United Nations Guiding Principles on Business and Human Rights, the Declaration of Fundamental Principles and Rights at Work developed by the International Labour Organisation, the UN Declaration of Fundamental Human Rights and the UN Global Compact.
We require all individuals, entities, agents or anyone acting on the Group’s behalf to comply with our various group policies which are supported and approved by our Board of Directors.
Our Social Citizenship Policy Statement and Code of Business Conduct - which are translated into 17 languages to ensure full accessibility - include specific reference to our commitment not to “countenance or condone forced labour or physical abuse”. Training on the Code of Business Conduct is included in the induction process for all employees.
Our Sustainable Sourcing Policy also explicitly states that we will not work with suppliers who do not share our declared values in good citizenship such as respecting human rights, including forced labour specifically.
Our policies include direct contact details if questions or concerns are raised and we also provide a Good Faith Reporting Policy Statement ‘Whistleblower Code’ to enable employees to report wrongdoing without fear of retaliation. Employees are made aware of the policy through our Company Handbook which is available on our intranet site.
During 2016, there were no significant incidents reported in the UK that were considered to be non-compliant with our Code of Business Conduct.
DUE DILIGENCE AND RISK ASSESSMENT
OUR DIRECT OPERATIONS
Our employees are governed by the Code of Business Conduct which provides a guide to legal and ethical responsibilities and points them to the information and the resources needed to exercise sound decision-making on the job. Employees are required to be familiar with the Code and all Group policies, to apply them every day and ask questions if they are ever unsure of the correct action to take.
Our Good Faith Reporting Policy Statement – ‘Whistleblower Code’ is designed to ensure employees have the opportunity to report actual or potential wrongdoing and our Code of Business Conduct includes reference to direct contacts to support employees in resolving questions or concerns.
A significant number of corrugated division manufacturing sites are externally audited every 2 years against internationally recognised standards e.g. SMETA. These audits include an assessment of how our sites are managing the risk of forced labour conditions occurring, alongside corrective action plans if areas for improvement are identified.
We are currently assessing all of our sites across business divisions and we are also investigating appropriate standards to implement.
OUR SUPPLY CHAIN
Sustainable sourcing is managed at group level, with local sourcing coordinators at each large business unit. All relationships and transactions with our strategic suppliers and subcontractors are governed by our Sustainable Sourcing Policy and Social Citizenship Policy Statement.
Our strategic Tier-One suppliers are global brands themselves, predominantly European based, and governed by stringent regulation. Nevertheless, we audit all of our strategic suppliers, requiring certification or compliance to internationally recognised standards including ISO 9001, ISO14001, OHSAS 18001 and social responsibility elements guided by the ISO 26000 voluntary standard every three years. After initial audit, we work with each supplier to address any cases of non-compliance or areas of improvement. We aim to increase the number of suppliers of key raw materials, goods and services who commit to the 10 principles of the UNGC Global Compact and who report on social data to SEDEX or ECOVADIS.
We are explicitly communicating our expectations to our strategic suppliers to uphold our commitment to combatting slavery and human trafficking, and are working with suppliers to develop similar compliance programmes within their own supply chains.
In order to obtain greater oversight of our non-strategic suppliers, we will conduct an exercise to assess their risk profile based on their country of operation, and the product/service that they provide. We will use this assessment to prioritise engagement with higher risk suppliers and identify practical actions to mitigate potential risk.
In 2017, Smurfit Kappa UK Ltd established a cross-functional and cross-divisional committee to drive and focus our commitment to eliminating the risk of modern slavery and establish practical and timely actions.
In order to monitor our performance we will establish key performance indicators to be assessed and disclosed on an annual basis.
This statement is made pursuant to Section 54 (1) of the UK Modern Slavery Act 2015 and has been approved by the Smurfit Kappa UK Ltd Board of Directors and signed on their behalf by Clive Bowers, CEO UK Corrugated Division at Smurfit Kappa UK Ltd and Director of statutory entity.
UK Corrugated CEO