Modern Slavery Act Statement 2019/20
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 most recent Global Slavery Index (2018) estimates that 40 million people globally are 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 Modern Slavery legislation in the territories in which it operates1. 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 with legislation, 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. The below trading entities are subsidiaries of Reed & Mackay Holdings Limited –
• UK – Reed & Mackay Travel Limited
• USA – Reed & Mackay Travel Inc
• Canada – Reed & Mackay Canada Inc
• France – Frequent Flyer Travel Paris SAS
• Dubai – Reed & Mackay Travel Management Services FZE
• India – Reed & Mackay Travel India Private Limited
• Singapore – Reed & Mackay Travel Singapore Pte Limited
• Australia – Reed & Mackay Travel Australia Pty Limited
• New Zealand – Reed & Mackay Travel New Zealand Limited
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. Our Employee Handbook identifies codes of conduct related to Health & Safety, Equality, Dignity at Work and Ethical Conduct, and there are management approved policies for Health & Safety, Equality & Diversity and Corporate Social Responsibility. All staff must adhere to our codes of conduct and company policies.
A thorough recruitment and selection process is used 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.
As a responsible employer Reed & Mackay always pay at least the minimum wage rate applicable under local laws.
Our Supply Chain
We only work with reputable suppliers and endeavour to ensure our supply chain is free from slave labour. We will not work with a supplier before researching their business and we ensure they are appropriately licensed to carry out the service they are providing. Spend commitments are subject to internal Purchase Order approval and agreed legal contracts, and we do not pay cash for services.
Prior to approval, suppliers undergo a due diligence process which incorporates Modern Slavery requirements, and in order to do business with Reed & Mackay all suppliers are required to comply with our Supplier Operating Principles on an on-going basis. These principles, include adherence to all relevant legislation in the countries in which they operate and all relevant International Labour Organisation (ILO) conventions, and 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 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.
We visit all our partner offices, and where appropriate and practical, we visit our suppliers. 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 in 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 process.
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 to third parties 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 Modern Slavery legislation, 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 mandatory annual 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 recently reviewed and enhanced our supplier on-boarding process, helping to ensure due diligence is managed consistently across a range of topics, including Modern Slavery/Child Labour, Ethical Business Practices, Equal Opportunities and Diversity. We have implemented a supplier review process so that adherence can be monitored on an appropriate periodic basis. We will continue to review and update these processes as appropriate.
Our Commercial department maintain close relationships with the travel industry service providers who supply air travel, ground travel, hotels and ancillary services to our clients. Understanding the business practices of these service providers helps ensure that our clients make appropriate choices about their travel.
Our International department are developing a set of training materials, including Modern Slavery training, for our partner network.
Reed & Mackay is in the process of refreshing its Corporate Social Responsibility programme. Our Supplier and Partner Operating Principles are under-going review and will be updated in 2021. Our Modern Slavery training and risk assessment process will also be reviewed and updated in due course to reflect recent changes in the business, the travel industry and global Modern Slavery risk profile. More details on these and any other relevant activities will be shared in future Modern Slavery statements as appropriate.
Reed & Mackay maintain a commitment to conducting its business in an ethical way and 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 2020.
This statement is reviewed and updated annually.
Reed & Mackay’s financial year runs from 1st April – 31st March, and the organisation normally publishes its Modern Slavery statement well within the required 6 months of the financial year end. The challenges presented by the coronavirus pandemic have been particularly acute in the travel industry and have resulted in reductions in the workforce and in staff availability, and the curtailment of some planned improvement activities. As a consequence, and in accordance with Government Coronavirus guidance, the publishing of this 2019/20 statement has been somewhat delayed.
In accordance with Modern Slavery legislation this statement has detailed the actions taken during the financial year ending 2020.
Approved by the Reed & Mackay Board. Fred Stratford, Group CEO, Reed & Mackay, 18th December 2020
1 UK – Modern Slavery Act 2015 (MSA 2015); Australia – Modern Slavery Act 2018 (Cth) (Act)