This statement is made on behalf of water2business limited ("W2B") pursuant to section 54(1) of the Modern Slavery Act 2015 (the "Act") and constitutes its slavery and human trafficking statement for its current financial year (1 April 2021 to 31 March 2022).
W2B is a water retailer business serving 82,500 customers across the United Kingdom.
W2B is committed to meeting the aims of the Act and to having a work environment that is free from human trafficking, slavery, servitude and forced or compulsory labour. We strongly oppose slavery and human trafficking in our supply chains and in any part of our business.
W2B has no subsidiaries and all statements made relate to the W2B trading entity.
The employment and procurement practices which we operate contribute to identify, assess and monitor potential risk areas within our business and mitigate the risk of slavery and human trafficking occurring in our engagement of external contractors and suppliers. Being trusted in all things, including the moral obligation set out in the Act is one of our core values. We would never knowingly engage with suppliers or contractors involved in slavery or human trafficking.
W2B rigorously checks that all of its employees have the right to work in the UK and are paid at or above the minimum wage. The same rigour is applied to ensure that agency workers are subject to the same checks.
As well as setting out the rights and benefits which are available to W2B employees, the employee contracts of employment make it clear what actions and behaviours are expected of them.
Where possible, we have built and maintained longstanding relationships with trusted suppliers/contractors, making clear our expectations of business behaviour. The water sector trading environment means our largest supplier relationships are formed of the water wholesalers whom are heavily regulated, and all openly confirm compliance to the Act.
W2B's expectations for our supply chain are always clearly included in all procurement processes and where possible we source all our required goods and services from the local economy to match our ethical stance (Sourcing Ethically Policy) and to reduce risk of slavery.
Outside of regulated wholesale water purchase, W2B's supply chain is small with the major spends being on people, accommodation and a small IT cost. People based procurement remains our largest risk and the focus for both the prior year and the coming year.
The COO oversees the approval of any new contractors and completes an annual update of training on Modern Slavery to ensure continued compliance. All existing contract employing people have an annual review to ensure the commitments signed up to at the start for the framework arrangement are still current and correct. A risk assessment is in place for all 'people related contracts' and in the financial year we were 100% compliant with checks on suitability for work in the UK.
Supplementing these check we have a suite of employment policies aimed are fairness recruitment and removal of modern slavery including equal opportunities and diversity policy, safeguarding of children and adults policy, agency workers policy, internal recruitment policy and whistleblowing.
During this financial year all supplier shortlisting, covering both new or renewed supplier relationships have required statements and confirmation of monitoring arrangements to ensure compliance with the Act. These have featured in all considerations prior to engagement.
All our procurement is concluded as part of our accredited quality management system which ensures full checks are undertaken and routinely reported on.
This statement is available to all our staff to ensure a high level of understanding of the risks of modern slavery and human trafficking and we provide training to staff as and when it is deemed appropriate and necessary.
We have embedded our ethical obligations in our Corporate Social Responsibility (CSR) policy, including human trafficking and modern slavery expectations which all W2B's people are introduced to in the induction process.
We also aim to promote a company culture where the reporting of any concern is encouraged. Alongside our CSR policies we have a very clear Whistleblowing policy for our employees and supply chain.
Due Diligence Process
W2B has and will continue to review its own operations and supply chain to evaluate human trafficking and slavery risks with processes embedded in our ISO9000 accreditation. This includes our people risk assessment. At present W2B has uncovered no evidence of slavery and human trafficking within its own operations and those of its suppliers and contractors and therefore considers the risk to be low.
This statement was approved by the Board of Directors and will be reviewed on an annual basis.
Managing Director - water2business Limited