Modern Slavery Act Statement
Slavery and Human Trafficking Statement
Our Business and Structure
Print logic Reprographics is a limited company that operates in the UK only. It operates as part of the Print Logic Group.
We have a zero-tolerance approach to modern slavery and human trafficking and we are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or within our supply chain. Services and goods procured on behalf of our business are the results of transparent, objective, risk-based decision-making processes which are compliant with all applicable laws and regulations.
We expect the same high standards from those we work with and are committed to ensuring that there is no modern slavery or human trafficking within our supply chains.
Our Suppliers and Due Diligence
Our supply chain encompasses four core categories covering:
Information and Communications Technology;
- Professional and Consultancy Services;
- Site and Maintenance Services;
- Travel and Conferencing.
Each of these categories supports our business operations and that of our clients. Due to the nature of our business, around 60% of our supply chain relates to Professional and Consultancy Services.
As part of our procurement process, new suppliers are provided with our Minimum Commercial Terms which state that any contract we enter into with them will require certain terms to be agreed upon, including a warranty that no slavery is used in their business or by suppliers within their supply chain. They are also required to complete a detailed due diligence questionnaire.
Our due diligence questionnaire seeks to assess whether the supplier:
- has policies, processes and procedures in place relating to anti-slavery and unfair practices;
- operates using fair employment practices such as offering overtime on a voluntary basis;
- has taken steps to ensure that slavery and trafficking does not exist anywhere in their supply chain; and
- has systems in place to ensure compliance with the Modern Slavery Act 2015.
All suppliers (including their sub-contractors) are expected to adhere to our Supplier Operating Principles, some of which are set out below:
Suppliers are expected to have management systems in place for delivering and monitoring contractual compliance in line with the due diligence responses for their own operations and those of their sub-contractors.
Suppliers should comply with all relevant legislation in the countries in which they operate and all relevant International Labour Organisation conventions.
Suppliers are expected to communicate their expectations for compliance on all the issues raised within the due diligence responses to all of their relevant employees and sub-contractors / supply chain.
Due diligence responses allow us to assess the risk of modern slavery and human trafficking in the supplier’s business and their supply chain, regardless of expenditure. We use heat/risk maps to define the level of risk by considering probability and business impact. Should suppliers fail to meet our standards or be unwilling to make any changes, we will cease to engage with them.
We continue to take steps to help mitigate the risk of slavery and human trafficking in our supply chain, including:
Obtaining contractual warranties that no slavery is used anywhere in the supplier’s business or its supply chain and that all necessary processes and policies have been put into place to ensure that this remains the case;
Adding indemnity provisions and rights to terminate for breach of our Anti-Slavery policy into our contracts;
Ensuring risk areas are documented, monitored and taken into consideration in any future contract renewals;
Reviewing and developing our internal supplier audit programme to introduce new categorisations for our suppliers (Critical, Key or Operational). All Critical suppliers will be required to undergo annual re-verification of their due diligence questionnaire and audit; and
Extending risk mapping to include location, the length of the relationship and any other existing information to enable us to rate suppliers.
Our Risk Assessment
The risk of modern slavery and human trafficking occurring within our business and supply chain remains low and we have adequate controls in place to manage, monitor and mitigate such risks. Our business-wide risk assessment is reviewed periodically and updated to ensure that our controls remain appropriate and robust.
Training and Awareness
We are committed to ensuring that our staff understand what modern slavery and human trafficking is, are able to identify associated red flags and are aware of the actions they must take should they have any concerns. In addition to the policies set out above, we have a modern slavery and human trafficking e-learning module which can be accessed by all staff at any time.
Guidance issued by the National Crime Agency in 2020 highlighted that those working on immigration and conveyancing matters are likely to have higher visibility of modern slavery victims/offenders. As a result, we introduced compulsory training to our Employment and Real Estate legal teams in addition to our HR, Finance, Procurement and Practice Governance and Risk functions.
Each year, a business-wide communication is published informing all colleagues of our modern slavery and human trafficking policy and procedures.
In order to assess the appropriateness of actions taken to date and the effectiveness of our modern slavery controls, we will measure our performance as follows:
100% of our Procurement function to have undertaken the modern slavery and human trafficking e-learning module (by January 2023);
100% of our new suppliers to follow our procurement process and complete the necessary due diligence questionnaire before a contractual commitment for goods or services is entered into (by January 2023); and
We will continually review our systems to ensure we have robust policies and processes in place to mitigate the risk of modern slavery and human trafficking within our business and our supply chain.
Written by Jonathan Lee
Finance and Operations Manager
V1.0 January 2022
Signed by Paul Edwards 26/01/2022