Modern slavery statement
Organisational structure and supply chains
SUEZ operates at over 300 sites across the UK with more than 5,600 people delivering our recycling and recovery services. Our business headquarters are in Maidenhead, UK. The following companies are covered by this statement:
- SUEZ Recycling and Recovery UK Ltd
- SUEZ Recycling and Recovery South East Ltd
- SUEZ Recycling and Recovery Lancashire Ltd
- SUEZ Recycling and Recovery Surrey Ltd
We currently spend over £498 million per year across 3,268 suppliers. Of this, over 95% is spent with UK based companies.
Policies in relation to slavery and human trafficking
SUEZ has in place the following policies and procedures that set out its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Anti-Slavery and Human Trafficking Policy and Procedure – reviewed annually.
- Whistleblowing Policy – SUEZ uses an independently provided whistleblowing hotline, which provides an easy and confidential means for concerns to be raised. This is provided so that employees who feel they are not able to raise concerns internally have a method to do so in confidence. We investigate every whistleblowing case thoroughly and seek to achieve a resolution as soon as practicable.
- WeCare – Our Employee Assistance Programme (EAP) provides an external and confidential support and advisory service on a range of issues. Advice can be provided by telephone, video call or face-toface counselling.
- Wellness Charter – Our culture promotes and actively supports the wellness of all of us, every day. It includes our commitment to diversity and inclusion in line with our value of respect.
- Supplier Code of Conduct – Suppliers are required to confirm that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
- Sustainable Procurement Policy – This policy strives to gain supply chain transparency and source products, materials and services using credible and recognised sourcing and certification schemes, where available. It also aims to help us identify and address human rights abuses and labour exploitation in our supply chain.
Due diligence processes with our supply chain
SUEZ works with 3,268 suppliers. Our procurement team have been trained to identify potential risks in our supply chain and have introduced the necessary controls to mitigate the risk.
Our Supplier Code of Conduct, which all suppliers sign up to when being onboarded, includes a commitment for suppliers to adhere to all laws and regulations prohibiting human trafficking and forced or indentured labour, such as the Modern Slavery Act 2015. This includes the preparation and publishing of an annual statement where their turnover exceeds UK legislative thresholds. We expect suppliers to implement policies, practices and due diligence checks to ensure that modern slavery, child labour and human trafficking are not taking place in their supply chain, or in any part of their business. As such, suppliers must:
- Comply with all applicable laws, codes and regulations wherever they operate;
- Promptly notify SUEZ of any significant criminal or civil legal actions brought against them; and
- Promptly notify SUEZ of any fines or administrative sanctions brought against them which relate in any way to the requirements set out in the Supplier Code of Conduct.
We also include our anti-slavery policy in our onboarding information for all new suppliers to make them aware that there is no ambiguity in the SUEZ position with regards to modern slavery.
We have risk assessed our supply chain at a high level and identified that our Agency suppliers and Managed Service providers are an area where there is a potential risk. As such, we include labour provider audits as a standard agenda item in Supplier Relationship Management (SRM) meetings with these suppliers. Both our suppliers for Agency Labour and Managed Services are members of the Slave-Free Alliance with Smart Solutions also being registered with the Gangmasters and Labour Abuse Authority (GLAA), Stronger Together and the Association of Labour Providers (ALP) and are pro-actively undertaking additional checks to ensure that no SUEZ recruits are being exploited by outside influences. For example, during our audit checks with our main labour suppliers, Magnit Global and Smart Solutions both perform numerous checks to ensure the resource being provided has been vetted and checked for risk of modern slavery. These checks include but are not limited to, checking there is no duplication of essential information, that charges are not being levied to the staff for PPE, recruitment fees or transport costs and that the registration process is undertaken correctly including right to work documents checked.
We have a vendor neutral agency staff supplier which is engaged by SUEZ to provide a managed service which delivers temporary labour services to our sites. They undertake regular modern slavery audits with the panel of agencies who supply SUEZ. This is to effectively manage the risk to the organisation and ensure that no person employed by SUEZ under these services are being exploited. These audits investigate if each agency has in place all the various checks that may bring to light instances of modern slavery. For example, duplicate address checks, duplicate next of kin checks, duplicate bank accounts. They also ensure that each agency has a modern slavery policy, a whistleblowing policy, and a fair recruitment policy amongst others. These audits are shared with SUEZ on a quarterly basis, with any issues raised and discussed, including any actions, outcomes, or concerns as well as positive areas of best practice. Where the agency audit highlights actions required from a panel member and the agency don’t remedy the situation within the given timescale, that agency is removed from the panel and no longer used by Magnit Global or SUEZ.
We have improved our modern slavery questionnaires and assessment processes that are used when onboarding suppliers and in tenders as well as in Supplier Relationship Management meetings.
Identification of risk and steps taken to prevent and manage risk
We have identified five classification areas that we believe are high risk within the UK. This classification has been done in conjunction with the Slave Free Alliance and focuses on sectors where vulnerable groups to modern slavery have been identified:
- Agency Labour
- Facilities Management
- Industrial Services
We renewed our membership with Slave Free Alliance at the end of 2022, for another three years, demonstrating our continued commitment to managing the risk and taking steps to prevent modern slavery. Being a member of the Slave Free Alliance provides us with access to expertise and advice on best practice.
Our Optimisation Committee now receive updates twice a year on the work and progress of the working party. These updates include seeking approval of actions and answering questions on the activities of the working party for 2023/24. In addition to this, we have recognised the need of the working party to reflect the business it represents, so an additional member has joined the group representing the operational activities of our business.
Effectiveness in ensuring slavery is not taking place – performance indicators
Through our monthly reporting checks on duplicate addresses, bank details, next of kin and phone numbers, we identified several possible ‘red’ flags in 2022. Each of these were investigated, the individual employees were spoken to and we are pleased to confirm that there was no modern slavery activity.
We have also introduced checks by our internal auditors to make sure our employees have completed the mandatory training referred to below. In addition, for the sites that have been identified as high-risk, internal audit are also checking other measures are in place such as posters being prominently on display.
Training and building capacity
On 01 March 2022, we launched digital and toolbox talk mandatory training for everyone in SUEZ recycling and recovery UK.
The training consists of three courses which focus on the different needs of the business. Business support functions were provided with a 15-minute digital overview of modern slavery, the signs to watch out for and the process that they should follow if they have concerns. The training concludes with a test which the employee must pass to complete their training. Operational management teams also complete the same training, with the addition of a video guide on how to deliver the toolbox talk training to their frontline employees.
Due to the importance of modern slavery, we have made all three courses mandatory to ensure all our employees have sufficient knowledge to identify and respond appropriately if they have concerns.
In addition to the training noted above, we have introduced a modern slavery unit to our onboarding process for new starters. It outlines the same key messages as the mandatory training, such as signs of modern slavery and what to do should they have any concerns.
Collaboration and partnerships
We recognise that no organisation can tackle the issue of modern slavery alone. We have sought to collaborate with others, share our own experiences and welcome learning best practice from others.
SUEZ has been part of Slave-Free Alliance since 2019. Slave-Free Alliance is a social enterprise owned by the global anti-slavery charity Hope for Justice. We have worked in partnership looking at our modern slavery strategy and identifying ways to mitigate the risks even further. Being a member gives us access to expertise around modern slavery including supply chain due diligence and risk assessment, crisis response, training and investigations.
Supply Chain Sustainability School
We have partnered with the Supply Chain Sustainability School, which is an invaluable resource of training and resources on a range of sustainable issues including modern slavery. This will enable us to improve the training of our own employees and by joining the labour working group for the school engage with other companies to share best practice on modern slavery and have input to the future modern slavery resources on the school. We will also be able to direct our own suppliers in high-risk areas to access free training on modern slavery available from the school which will especially help small and medium sized suppliers that do not have access to the internal resources that we have.
Waste & Recycling Modern Slavery Working Group
SUEZ was a founding member of this collaborative group across the sector. The Waste & Recycling Modern Slavery Working Group has 18 member businesses which span contracting, management, logistics, exporting of waste, textiles, paper, plastic, e-waste, metals and more. It raises awareness of modern slavery and develops solutions for mitigating the risks that the whole sector faces.
Next steps 2023/2024
Our supply chain targets for 2023-24 are:
- To improve the rigour of the modern slavery assessments in the onboarding process and develop reporting on this.
- We have classified the high-risk categories of spend which are:
- Facilities Management
- Industrial Services
We have worked with Slave-Free Alliance to identify appropriate mitigations for the suppliers within these categories in order to reduce the risk. We are now able to implement these mitigations and will be issuing questionnaires to all high-risk suppliers in 2023/24 and will assess the results to identify any suppliers that are not meeting our standards and work with these suppliers to improve their performance or remove them from our supply chain.
- We have become a partner of the Supply Chain Sustainability School and will be asking the procurement team to complete the modern slavery learning pathways and attend a workshop on combatting modern slavery in supply chains to improve their knowledge and skills.
Other areas of development
- Development of more in-depth learning for specific audiences – Operational HR, H&S teams and Wellbeing and Inclusion Officers.
- High risk areas – such as materials recycling facilities (MRF) specially targeted training for all employees.
- Develop a training session for Driver Certificate of Professional Competence (CPC).
- Present the working parties plans to the SUEZ Works Council.
- Invite our suppliers to the Lunch and Learn – delivered by Slave-Free Alliance during 2023.
- Establish if the digital training for our suppliers is viable.
- Update, create and publish a flow chart of our escalation process including a Single Point of Contact.
This statement has been approved by the board of SUEZ recycling and recovery UK on 02 May 2023 who will review and update it annually.
John Scanlon, Chief Executive Officer, SUEZ recycling and recovery UK