Modern Slavery Act Statement 2018/19
Modern slavery is a form of organised crime in which victims are treated as commodities and exploited for criminal gain. The victims of modern slavery come from all walks of life and can be found all over the globe.
The International Labour Organisation estimates that in 2016 40 million people globally were victims of modern slavery.
Reed & Mackay is committed to undertake due care and diligence to ensure that it conducts its business in accordance with its obligations under the Modern Slavery Act 2015 (MSA 2015). We recognise that in addition to a legal obligation we have an ethical responsibility to support this Act and endeavour to ensure there are no Modern Slavery risks within our own business or our supply chains.
In that spirit, we have published our annual statement of slavery and human trafficking, made in compliance section section 54 of the Modern Slavery Act 2015, in which we explain how slavery and human trafficking can affect our business and the steps we are taking in the fight against it.
Our Company Structure & Vision
Reed & Mackay was established in 1962 expanding into strategic travel management in 1988, with a view to specialising in travel management services for the professional services sector. We operate from Australia, Dubai, France, Germany, the UK, USA and Singapore and have over 800 employees within our organisation. Our vision is ‘To be the best in class travel management provider in chosen international markets’.
To support our vision, our mission is ‘we live to deliver unrivalled business travel management harnessing leading technology and our dedication to remarkable service’.
Our values which include passion, fun, care & consideration, making a difference, open mindedness and participation help drive our commitment to service, the core of what we do and with this in mind, we work with likeminded partners and suppliers whose values and ethos align with our own.
There are many aspects of Reed & Mackay’s culture which go to make up our unique environment. Maintaining and strengthening the culture is part of our everyday working life and underpins much of our corporate policy. We strive to create an enjoyable and safe working environment where staff can excel. We recognise our staff as our most important asset and employee welfare is a key objective that is linked to the company’s unique culture and values. We do not tolerate discrimination, abuse or harassment of any kind and we expect the same of our suppliers. All staff must adhere to our codes of conduct and company policies.
We operate a thorough recruitment and selection process for all our hiring decisions. This includes obtaining documented proof of an individual’s right to work in the country in which they will be employed. Should a concern arise we operate an open door communication policy and we also provide a protected disclosure facility should a staff member require confidentiality.
Reed & Mackay always pay at least the minimum wage rate applicable.
Our Supply Chain
We only work with reputable suppliers and we take responsibility for endeavouring to ensure our supply chains are free from slave labour. We will not work with a supplier before carrying out research into their business and we ensure they are appropriately licensed to carry out the service they are providing. Spend commitments are subject to legal contracts and we do not pay cash for services.
Suppliers undergo a due diligence process which incorporates Modern Slavery requirements, and are required to comply with our Supplier Operating Principles, including adherence to all relevant legislation in the countries in which they operate and all relevant International Labour Organisation (ILO) conventions. The principles set expectations around the adoption of standards regarding forced and compulsory labour; child labour; health, safety and hygiene; abuse and discipline; freedom of association and employee representation; remuneration; employment terms; working hours; equality of treatment; and community impact.
Our Partner Operating Principles set the same Modern Slavery expectations on our global partner network. In addition to this, our contractual agreements with partners require their compliance with the Modern Slavery Act, and that they take reasonable steps to ensure that their business and supply chain remains free of slavery, servitude, human trafficking, forced or compulsory labour, and/or child labour.
Where appropriate and practical, we visit our supplier and partner offices. This helps us become familiar with how they operate and the safeguards they have in place to reduce, remove and prevent the use of slave or forced labour in their organisations and their supply chains.
Our Corporate Risk Management Framework specifically identifies “Supply Chain” as a category of risk and, as such, risks within this category, including any related to Modern Slavery, are regularly reviewed and mitigated. Risks previously identified in this area have resulted in the development of our Supplier and Partner Operating Principles, and enhancements to both our supplier due diligence and our supplier review.
Our Activities to date & Future Plans
We have a Modern Slavery and Human Trafficking Policy which requires all staff to promptly report any concerns or suspicions of malpractice, and to avoid any activity that might lead to, or suggest, a breach of the policy. The policy is made available to all staff via the company intranet and publicly on request. Failure to comply with the policy will be investigated and may be treated as a disciplinary offence. We may terminate our relationship with individuals and organisations working on our behalf if they breach this policy.
We continue to make sure that our employees are aware of the Modern Slavery Act, of the definitions of slavery and human trafficking and that they know what to do should they suspect a case of slavery or human trafficking. Modern Slavery awareness is included in our employee induction and our compliance training.
In line with our ISO certifications we have a programme of regular internal and external audits to check compliance with all our policies and procedures.
We have updated our supplier on-boarding process to ensure that suppliers undergo appropriate due diligence, including adherence to the Modern Slavery act, and are implementing a revised supplier review process so that we can continue to monitor this adherence on a periodic basis appropriate to the supplier.
Our Commercial department maintain close relationships with our travel industry “trade” suppliers for air travel, ground travel, hotels and ancillary services, and will be reviewing the due diligence performed for these suppliers in 2019/20.
Our International department are developing a set of training material for partners which will include Modern Slavery training, and will look to include Modern Slavery requirements within their new partner Performance Framework.
Our Supplier and Partner Operating Principles are due for review in 2019/20, and will be updated as appropriate.
Reed & Mackay maintain a commitment to preventing Modern Slavery and will continue to operate a zero tolerance policy in this regard. In accordance with section 54 of the Modern Slavery Act 2015 this statement has detailed the actions taken during the financial year ending 2018/19.
This statement is reviewed and updated annually.
Reed & Mackay’s financial year runs from 01 April – 31st March.
Approved by the Reed & Mackay Board. Fred Stratford, Group CEO, Reed & Mackay, 01/04/2019