ROBERT LEE DISTRIBUTION LTD, MODERN SLAVERY COMPANY POLICY.
This statement applies to Marchase Limited and subsidiary companies, New River Holdings Ltd and Robert Lee Distribution Ltd. (referred to in this statement as “the Organisation”). The information included in the statement refers to the financial year 2020/2021.
The organisation is the largest independent distributor of bathroom, kitchen and plumbing products, supplying to retailers in the UK. Demand for our service is consistently high throughout the year and is therefore not seasonal. The organisation is controlled by a Board of Directors.
Our London Head Office is based in Waltham Abbey, Essex, with 4 main operational sites located in Waltham Abbey, Tamworth, Manchester and Swindon. The labour supplied to the Organisation in pursuance of its operation is carried out solely in the UK.
The Organisation considers that modern slavery encompasses:
• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• being dehumanised, treated as a commodity or being bought or sold as property
• being physically constrained or to have restriction placed on freedom of movement
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.
The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Organisation does not enter into business with any other organisation — in the UK or abroad — which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking.
The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK.
In order to fulfil its activities, the main supply chains of the Organisation include those related to the supply of bathroom products and goods from various suppliers in the UK, Europe and the Far East.
We understand that the Organisation’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.
As part of the supply chain to the wider construction industry the Organisation considers its main exposure to the risk of slavery and human trafficking to exist for several reasons:
• fragmented supply chain
• High Proportion of low -skilled workers
• Tight time contraints
• Price driven culture
• Procurement of goods with complex supply chains
In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
Impact of Covid-19
During the reporting period covered by this statement, the Covid-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of Covid-19. This created several challenges for the Organisation, as it did for others across the nation.
The Organisation welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.
Despite the permitted, delay, the Organisation remains in a position to publish its statement for the financial year 2019/2020 in line with the original publishing requirements.
The Organisation concludes that the Covid-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under “Potential Exposure” above.
Its use of suppliers dropped significantly due to the fact that homeworking was swiftly implemented in March 2020 which meant that its premises, from which it usually conducted day-to-day business, was temporarily closed. Several of our workforce were placed on furlough as a result of the drop in demand for our services, meaning there were no additional temporary labour needs.
During the pandemic, the Organisation’s employees still had access to the grievance procedure to raise any concerns that they may have had. In line with emergency legislation passed by the Government, employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking.
The Organisation’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times
The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with s.54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to minimise the risk that modern slavery is not taking place:
• We regularly review our supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery.
• We have measures in place to identify and assess the potential risks in its supply chains.
• HR procedures including – ensuring all employees have the appropriate ‘right to work’ documents, are paid fairly and in accordance to the National Living Wage, processes are in place to safeguard the interests of all employees, including those undertaking unpaid work where applicable.
• A Whistleblowing procedure is in place to report suspected dangers or wrongdoing in the workplace. Any concerns are duly investigated with action taken as necessary.
• We ensure that adequate information and training on all relevant matter is provided to all our employees. This includes managers actively receiving support on employee issues such as recruitment, remuneration, and employee wellbeing to embed a zero tolerance policy towards modern slavery.
Due Diligence and supplier Performance
Many of our suppliers import goods from sources from outside the UK and EU and are potentially more at risk for slavery/human trafficking issues. Our centrally controlled suppliers all go through a process of due diligence including a contractual commitment to our ethical requirements.
Standard business practices are in place to ensure effective reporting and action to address any reports of modern
slavery incidents. These include:
• Factory & Supplier evaluation reports
• Proof of minimum working age requirements.
• Proof of right to work documents
• Risk management processes
• Communicated grievance procedures
• The Organisation actively encourages a culture of respect for human rights and zero tolerance of modern slavery.
The organisation conducts regular supplier audits which incorporates an Ethical Assessment.
There were no risks identified in the 2019 / 2020 financial year, however the evaluation and assessment was reduced due to the impact Covid pandemic as outlined above.
The process of these ongoing audits will be reviewed in 2021 as part of our ongoing commitment to improve.
Focus for 2021
The Organisation is committed to an ongoing process of improved supplier risk assessment. Suppliers will be profiled to best focus our efforts for due diligence. Higher risk suppliers that are identified will be subject to greater scrutiny and an ongoing audit processes.
The organisation will seek a greater level of control with labour agencies providing manual labour to our distribution centres, with clear expectations around modern slavery due diligence. This gives confidence to the Organisation that the right workers are coming to our sites and that these workers are in possession of their own identification documents.
We will work with selected suppliers and customers to share best practice. Learn from others and support industry-wide improvements.
The Organisation has a Human Resources Manager, to who all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.
This statement is made in pursuance of s.54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
Print name: Matt Earle
Job title: Managing Director
Date: 6th April 2021