HERMES PARCELNET LIMITED
Slavery and Human Trafficking Statement
1. Introduction / Background
This statement is made by Hermes Parcelnet Limited. It is a statement made in accordance with Section 54 of the Modern Slavery Act 2015 and covers the financial year from 1 March 2016 to 28 February 2017. The Statement also refers to activity we will be taking during our 2017/18 financial year.
We are the UK’s leading consumer delivery specialist handling more than 260 million parcels each year. We provide a range of delivery options to home, work, neighbour, safe place or our myHermes ParcelShop locations.
Within the UK, Hermes has 2,500 employees and operates a network of over 10,500 couriers, 450 sub-depots and over 4,500 ParcelShops.
Hermes works with a wide range of leading high street, catalogue and online retailers in the UK.
We engage a range of third party suppliers to provide goods and services to us (our “Suppliers”). These Suppliers include suppliers of fleet vehicles, sortation equipment, mobile scanning hardware and software and cloud based technology.
We also engage self-employed individuals to provide services on our behalf such as our final mile couriers, those who operate myHermes ParcelShops and/or provide sub-depot operational services (collectively, our “Services Providers”).
We are committed to the sustainable development of our business in a way that reconciles economic success with the social wellbeing of individuals that are employed by us or are involved in the provision of services to us.
We know that slavery, human trafficking, servitude and forced labour (“Modern Slavery”) is a global and increasing challenge for governments and business.
2. Our Policies and Contractual Terms on Slavery and Human Trafficking
As a business we recognise our responsibility to be aware of the risks of Modern Slavery within our own organisation and supply chain. We have taken the following steps:
- In September 2016 we introduced our new Code of Conduct (“the Code”). A copy of the Code can be found by clicking on the relevant link found below this statement.
This was a new and important step for us and acts as the cornerstone of our Social Compliance Model. The Code is based on ethical, moral and legal principles which provide a framework for all that we do. Our Suppliers and Services Providers can expect us to comply with the law, observe ethical standards and act as a fair business partner. In turn, we expect our Suppliers and Service Providers to apply the same standards. We make an unambiguous commitment in the Code to treat our service provider and suppliers with dignity and respect.
Part 1 of the Code sets out the principles that we expect our employees to comply with in the course of their relationship and interactions with our Suppliers and Service Providers. Part 2 of the Code sets out the principles that we expect our Suppliers and Service Providers to comply with whilst they are engaged by us. We expect the standards set out in the Code to be passed on to the employees, workers and the suppliers of our Suppliers and Services Providers.
Both parts of the Code include specific provisions in relation to Modern Slavery. Specifically, we define what Modern Slavery means and make clear that it is prohibited in our operations and supply chain. Hermes and our employees will not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of our Code in this respect. Likewise, our Suppliers and Service Providers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of those principles.
The Code includes a complaints procedure under which alleged breaches of the Code can be raised and will then be investigated. When it comes to modern slavery and other human rights-related complaints, the matter will be referred to the independent external Business and Human Rights Ombudsman appointed by Hermes (see further below).
- In tandem with our Code of Conduct, we have appointed an independent external Business and Human Rights Ombudsman. The role of the Ombudsman is to consider and investigate alleged serious breaches or potential breaches of human rights by following the process set out in our Ombudsman Investigation and Recommendations Procedure. The role of the Ombudsman includes investigating such matters, making findings and providing recommendations to ensure that we achieve and sustain the standards set out in our Code of Conduct. Although this would include matters related to modern slavery, we are aware that modern slavery is not commonly reported by the workers themselves as they can fear retaliation.
- In August 2017, we introduced a new Anti-Slavery and Human Trafficking Policy to cover all employees of Hermes Parcelnet Limited. A copy of our policy can be found by clicking on the relevant link found below this statement. Our policy outlines our zero tolerance approach to Modern Slavery of any kind within our operations and supply chain and it makes it clear that employees have a responsibility to prevent, detect and report any part of the business that they are responsible for or otherwise come across.
- We have also reviewed and amended our standard contractual terms for engaging new third party Suppliers to include specific detailed provisions on Modern Slavery.
3. Risk Assessment Processes
Our due diligence activities to combat Modern Slavery, described below, are risk based and will in future correspond with the level of risk identified.
As such, we have undertaken or begun the following processes during the period to inform our due diligence approach:
- We have carried out a risk assessment of our top 100 Suppliers (being those with annual spend greater than £200,000) and the next 100 Suppliers (being those with an annual spend of £100,000 - £200,000). Following this risk assessment we and have written to 72 of our ‘top 100 suppliers and 64 of our second tier of Suppliers, to make them aware of the standards set out in our Code of Conduct, asking them to acknowledge and agree to the terms that are relevant to them (as set out in Part 2 of the Code). We have monitored the responses received to ensure they are satisfactory.
- We have appointed an external third party auditor, SGS, to audit compliance with our Code of Conduct within our Depot network and network of Service Providers.
- We have participated in the Fast Forward ethical compliance training that was facilitated by the clients of Hermes that are part of the Fast Forward retailer initiative. Furthermore we have agreed to allow any audit of our business that is required by our clients as part of the Fast Forward retailer initiative.
4. Due Diligence Processes
In order to seek to prevent slavery and trafficking in our business and supply chains we have begun a due diligence process during this period.
New third party relationships will now be subject to specific questioning regarding compliance with the Modern Slavery Act and our Code of Conduct and we have modified our procurement procedures to address the risk of slavery and trafficking.
In order to ensure that our staff are aware of the challenge posed by Modern Slavery, how to spot the signs of Modern Slavery, and what steps they should be taking to mitigate the risk of Modern Slavery within our organisation and supply chain, we are rolling out an online training package to our employees that has been developed by Eversheds Sutherland. We are assessing the need for targeted specific training in areas of the business that have the ability to minimise the risks of modern slavery, such as our procurement department.
6. Measuring Effectiveness – Performance Indicators
In order to monitor the effectiveness of the steps we have taken to seek to prevent Modern Slavery taking place in our business and supply chains we intend to:
- Review the effectiveness of our Anti-Slavery and Trafficking Policy and Code of Conduct;
- Ensure that all relevant staff are trained in relation to the Modern Slavery Act and Modern Slavery risks on an ongoing basis;
- Monitor and consider responses of those suppliers with whom we correspond to raise awareness of our Code of Conduct;
- We will work to ensure that during 2017/18 no less than 8 Hermes depots, 40 sub-depots and 480 couriers are subject to an audit process by our external third party auditor SGS in relation to compliance with our Code of Conduct;
- Monitor and consider the appropriate response to audits carried out by our external third party auditor, SGS, in relation to compliance with our Code of Conduct; and
- Monitor and review the findings and recommendations of our external Business and Human Rights Ombudsman in relation to any alleged serious breaches or potential breaches of human rights.
This Slavery and Human Trafficking Statement is hereby approved by the Board of Directors of Hermes Parcelnet Limited.
20 September 2017