Modern slavery statement
Organisational structure and supply chains
SUEZ operates at over 300 sites across the UK with over 5600 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 Holdings UK Ltd
SUEZ Recycling and Recovery UK Ltd
SUEZ Recycling and Recovery South East Ltd
SUEZ Recycling and Recovery Lancashire Ltd
SUEZ Recycling and Recovery Tees Valley Ltd
SUEZ Recycling and Recovery Surrey Ltd
As part of our action plan, we have carried out an initial risk assessment within our supply chain using high, medium and low risk categories. We currently spend over £510 million per year across 5,380 suppliers. Of this, over 85% is spent with UK based companies. We have identified the areas that we believe are higher risk within the UK and will initially focus on them.
We are aware of the risks of Modern Day Slavery within the supply chain and have developed the procurement team’s competence on the identification of these risks and the actions needed to mitigate or manage them. We are currently working with the Slave Free Alliance to further improve our risk management approach, particularly in our higher risk areas.
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. We investigate every whistleblowing case and seek to achieve a resolution as soon as practicable.
- WeCare – our Employee Assistance Programme provides an external and confidential support and advisory service on a range of area. Advice can be provided by telephone, video call or through, e. g. face-to-face 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.
- ‘We Hear’ confidential employee support line, run by employees for employees.
- 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 - 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 work with 5,000 suppliers, of those we work with 3,500 regularly. Our procurement team have been trained to identify potential risks in our supply chain and introduce the necessary controls to mitigate the risk.
We have a Supplier Code of Conduct which all suppliers sign up to when being on-boarded. This includes a commitment for suppliers to comply with Labour standards based on the conventions of the International Labour Organisation within their own organisations and within their supply chains. We also include our Anti-slavery policy in our on-boarding information for all new suppliers to make them aware that there is no ambiguity in the SUEZ position with regards to Modern Day 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 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, check that they have in place, duplicate address, duplicate next of kin and duplicate bank accounts.
We have a vendor neutral agency staff supplier which is employed by SUEZ to provide a managed service which delivers temporary labour services to our sites. They undertake regular Modern-Day 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 Day Slavery. For example, duplicate address checks, duplicate next of kin checks, duplicate bank accounts. They also ensure that each agency has a MDS 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.
We have improved our MDS questionnaires when on-boarding suppliers and in tenders and Supplier Relationship Management meetings. We are also members of an industry group that shares best practice on Modern Day Slavery in the supply chain. We have also established a procurement working group focused on Modern Day Slavery.
Our supply chain targets for 2021-2022 are:
- Review and enhance our Supplier Code of Conduct and issue to all suppliers. To clearly share our commitment in addressing modern slavery and setting out the minimum expectations required by our suppliers.
- Following our high-level risk assessment of the Supply Chain, our focus is to work with suppliers to mitigate the risk of modern slavery in identified high-risk categories/suppliers.
- Develop a toolkit for the team to assess risk and educate suppliers on MDS and our expectations for the supply chain.
Identification of risk and steps taken to prevent and manage risk
Following our Modern Slavery gap analysis conducted by the Slave Free Alliance, our independent anti-slavery partner, in October 2019, the inaugural Modern-Day Slavery (MDS) working party meeting took place on January 7th January 2021. During the meeting it was agreed who would take responsibility for each of the recommendations from our gap analysis, along with producing a timeline for actions to be completed which would be reviewed at our second meeting. Our second meeting took place 13 February to review and agree the timeline collectively. We agreed that in March we would launch the training needs analysis (TNA).
Due to COVID in March we were not able to proceed with the TNA. Although we did continue with our meetings every couple of months progress was hindered due to the business focus on delivery of essential waste services during a very challenging year.
To support more progress during 2021 we have engaged with Slave Free Alliance and agreed to co-opt a consultant onto our working party to support and guide our plans for 2021.
Effectiveness in ensuring slavery is not taking place – performance indicators
Training and building capacity
The training of our employees during the pandemic was not viable due to the impact of the pandemic on our services and resource levels. Being a waste management organisation, continuance of our services was seen as essential and this was hindered by the need to manage self-isolation and covid-related illness, shielding of those who are clinically vulnerable and a reduction in resources due to the need to furlough a significant number of our workforce due to the financial impact of lockdown on our customers and thence ourselves.
However, our intentions to undertake a training needs analysis and action the requirements arising from that remain in place.
Next steps 2021/2022
- Developing online training for delivery from August 2021, intended for all employees.
- Develop a formalised response plan, including remediation of victims and circulate to line management and HR Teams by the end of 2021.
The Company will consider the impact on any person working for us, or on our behalf, who believes they are a victim of slavery, human trafficking or forced labour, and aims to support any such person, including assisting that person in reporting their concern to the appropriate authorities.
This statement has been approved by the board of SUEZ on 21 June 2021 who will review and update it annually.
John Scanlon, Chief Executive Officer, SUEZ recycling and recovery UK