Introduction

Sentry SL Ltd (the company) strives to have full commitment to our core philosophies and values. We are committed to the 10 principles of the United Nations Global Compact which relate to human rights, labour, environment and anti-corruption and we support the international agenda to abolish human trafficking, slavery, forced and child labour.

Part of this pledge entails compliance with relevant regulation and policy. We are therefore committed to addressing the requirements of the UK Modern Slavery Act 2015 (the “Act”) and ensuring that our supply chain is compliant with the regulations prescribed therein. We acknowledge the undertakings in the Act and endeavour to create a culture of transparency with regards to the supply of goods and services to us.

This statement is made pursuant to section 54 of the Act and constitutes the company’s modern slavery and human trafficking statement, as required by the Act.

Organisational Structure

The company has undertaken an investigation of its corporate structure and business partners and determined that our international suppliers do not carry out business, or part of a business which does not conform to UK & international Law as far as practically possible. Accordingly, any non-UK partners/suppliers that are not subject to the Act are not therefore excluded from this statement. The Company takes all its trading links seriously & as far as possible monitor all its supply chain

Supply chains and due diligence procedures

We are committed to ensuring that our supply chain is free of any slavery and/or human trafficking. We intend to govern all current and future third party relationships with these slavery issues in mind. We will not knowingly support and/or do business with any suppliers who are involved in slavery.

In order to fulfil our obligations under the Act, the Company will:

  1. Undertake due diligence procedures to assess the nature and extent of our exposure to the risk of slavery;
  2. Request information regarding third party supplier’s working practices and require the relevant key supplier to confirm that it is aware of, and complies with, its obligations under the Act;
  3. Communicate to potential key suppliers that we have a zero tolerance policy with regards to slavery;
  4. Ensure that key suppliers sign up to the Company’s Supplier Code of Conduct, which requires confirmation from suppliers that they have:
    a. Undertaken a review of their supply chain;
    b. Established that it is free from modern slavery; and
    c. Ensure that all their representatives (including employees, agents, suppliers and subcontractors) conduct business with and/or on behalf of  in accordance with the Supplier Code of Conduct.
  5. Communicate to suppliers, by way of the Company Supplier Code of Conduct, that they are required to undertake continued self-monitoring and promptly inform the Company of any violations of the Supplier Code of Conduct; and
  6. Include reference to, and compliance with, these slavery supply chain issues in our supplier engagement process, supplier audit procedures and contractual arrangements with third party suppliers.


The abovementioned processes aim to identify any slavery risks and are able to investigate and eradicate such risks.

Training and policies

Training is fundamental to raising awareness of these slavery issues. We have therefore identified relevant online training which is intended to provide an understanding of slavery and our obligations under the Act. Such training will be rolled out to key stakeholders, who will be identified by our Legal team.

Furthermore, as part of our commitments under the Act, we have developed an internal policy which is available to all of our employees in the UK and which provides further guidance on how to identify, manage and report such risks.

 

Monitoring and adherence

Responsibility for ensuring and monitoring adherence to this policy rests with all employees who interact with the third party suppliers. Employees who are aware of, or suspect, any violation of the Act are required to report such conduct to their lead manager who will intern elevate to Director Level. Furthermore, the Companies Whistleblowing Policy encourages all employees to raise concerns and/or disclose information without fear of retribution.

Measuring success

The Company uses the following key performance indicators to measure the effectiveness of its approach to modern slavery:

  • Effective deployment of training to key stakeholders;
  • Completion of due diligence procedures undertaken on key suppliers;
  • Ongoing monitoring of key suppliers; and
  • Effective avenues for employees and/or suppliers to escalate modern slavery issues and concerns.

Approval procedure

  • This statement, which will be reviewed regularly and updated as required, has been reviewed by key stakeholders, senior management and has been approved by the Company’s Board of Directors.

Conclusion

We reiterate our ongoing commitment to the Act and its underlying principals.