Slavery & 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 2017 to end 28 February 2018. The Statement also refers to activity we will be taking during our 2018/19 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 ParcelShop locations.
Within the UK, Hermes has 3,000 employees and operates a network of over 10,500 couriers, 27 depots, 550 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 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 which we expect our Suppliers and Service Providers to comply with while 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, as set out in our statement for 2017/18, are risk based and correspond with the level of risk identified.
As part of this risk assessment third party auditor, SGS, has completed two of three phases of external audit to assess compliance with all aspects of our Code of Conduct across our Depot network and network of Service Providers. We will assess the findings of these audits over the coming review year period and report on next steps in our next statement.
4. Due Diligence Processes
In order to seek to prevent slavery and trafficking in our business and supply chains we send a copy of our Code of Conduct to any company applying to work with Hermes through a formal tender process. Part 2 of the Code sets out the principles which we expect our Suppliers and Service Providers to comply with while 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.
The Code of Conduct forms a part of the contract we have with Suppliers and, in signing a contract to work with Hermes, companies agree to comply with the Code.
We would eliminate from a tender process any company who does not share our values and who chooses not to sign up to the Code as part of a contract.
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 is 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 have rolled out an online training package to all our employees. This is a compulsory training and completion is required by the end of September 2018.
In addition, in the coming year we will assess the need for additional targeted training in areas of the business that have the ability to minimise the risks of modern slavery, such as our procurement department, Field Team and Depot operations.
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 will:
- Review the effectiveness of our Anti-Slavery and Trafficking Policy and Code of Conduct;
- Ensure that staff complete the compulsory Modern Slavery Act online training In addition, we will assesses the further training needs for Field Team and Depot staff in the coming year;
- Ensure that the final phase of Depot and sub depot audits carried out by our third party auditor to assess compliance with our Code of Conduct is completed;
- Analyse and disseminate internally the findings of the third party auditor’s report on compliance with the Code of Conduct and take appropriate action as needed to addresses any areas of non-compliance;
- Carry out an audit of our payroll to ensure that multiple payments into the same bank account are investigated, understood and approved (e.g. because the bank account belongs to family members employed by Hermes); and
- Continue to 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.
Martijn De Lange
24th September 2018