Marston’s recognises the opportunity created by the Modern Slavery Act 2015 (the “Act”) for large organisations to play a part in reducing the exploitation of people around the world. We recognise that the economic benefit of a global supply chain carries with it a responsibility to consider how goods and services are produced and delivered ethically and without the exploitation of vulnerable persons. Marston’s is committed to respecting the human rights of our people and those with whom we interact.
We recognise our responsibility to identify and address potential or actual human rights infringements linked to the products and services we provide. We encourage our suppliers to uphold the same standards as we apply to ourselves.
Marston’s organisational structure is explained at our website www.marstons.co.uk. With the exception of some exporting of beer all of our activities are in the UK.
Essentially Marston’s is a UK brewer, retailer and distributor of drinks, pub operator and a large scale property owner. These operations focus upon our six key strategic objectives:
Given these operations human rights issues could arise within our overseas supply chain concerning:
Modern slavery is also an issue within the UK, and we particularly recognise the need to protect people working within our pubs, depots and breweries from all forms of exploitation. Compliance with all aspects of UK employment law is essential, both for ourselves and our suppliers.
Knowledge of any agencies supplying staff to work on our premises is essential. Such agencies may supply packaging staff at our breweries, security staff at depots, doormen, kitchen workers and cleaners in our pubs.
Marston’s purchases goods and supplies almost exclusively from the UK or European companies. Workers’ rights are legally protected within Europe, and therefore we have a reasonable level of expectation that those people employed by our European suppliers are not being exploited.
Despite Marston’s buying from European companies a high proportion of the food goods and resources upon which our business depends actually originate from countries outside of Europe eg chicken, beef, cooking oil, uniforms, beer kegs, diesel.
During the tender process of our main suppliers, Marston’s carries out due diligence in order to understand how the suppliers’ staff are treated, and how the suppliers source services, goods and resources throughout the world. Marston’s expectation regarding how suppliers treat their staff, and the people in their supply chain are treated is communicated during the tender process.
Marston’s expects its key suppliers to follow the Corporate Code of Ethics published by CIPS (Chartered Institute of Procurement & Supply) www.cips.org/en-gb/aboutcips/cips-code-of-conduct
The expectation that our suppliers will operate in accordance with the CIPS Code of Ethics is communicated to companies participating in a tender to supply Marston’s.
The Code sets out the values, business culture and practices which all organisations can adopt. The Code requires a commitment to the eradication of unethical business practices, including bribery, fraud, corruption and human rights abuses, such as modern slavery and child labour.
Marston’s is committed to compliance with all aspects of UK employment law, and particularly with those aspects of the law which protect individuals from exploitation. Important controls in this context are:
We expect the UK agencies supplying staff to all our pubs, production sites, depots and distribution centres to operate within employment law.
We intend to continue to form long term relationships with the UK agencies supplying workers to our sites to better understand their businesses, and their own compliance to employment law.
Marston’s values building and maintaining long term relationships with its suppliers, and recognises the need to be diligent throughout those relationships in order to understand the businesses we deal with.
Marston’s Group Purchasing Policy is applicable to purchasing contracts over £50k, and stipulates that the negotiation of all such new supplies should involve our Group Purchasing team. This policy supports the due diligence process of understanding our customers.
It is also expected that Marston’s Ethical Purchasing Policy is followed throughout the business, and the purchasing team look for compliance with it.
We carry out periodic site visits at our key food and drink suppliers.
Many of our new food suppliers are audited at site before appointment. The audit is primarily for food hygiene purposes, however we are considering in the future how the audit could encompass an ethical inquiry, particularly concerning the risks of modern slavery in the extended supply chain.
During the course of making this statement the Act has been explained to our Exec Committee, Corporate Responsibility Committee, and Risk and Compliance Committee.
The Act has been explained to the managers responsible for the majority of our purchase streams, who have in turn considered the risks of modern slavery in our supply chain, and the appropriate wording of this statement.
Our managers have considered and support our future intentions as stated above so that we may continually improve our approach on this important matter.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 1 October 2016.
Ralph Findlay Chief Executive Officer
Marston’s Trading Limited
Marston’s Operating Limited
Marston’s Pubs Limited