This statement is made by the Schouw & Co. Group (the “Group”) pursuant to Section 54 of the UK Modern Slavery Act 2015 and applies to all the Group’s wholly owned portfolio companies and subsidiaries. The Group has commercial activities in the UK and an annual turnover of more than GBP 36m.
This statement was approved by the Group Executive Management on 15 June 2021.
Structure and supply chains
The Group is an industrial conglomerate with diversified activities across various business sectors and locations. The majority of our activities are located in Denmark and elsewhere in Europe. The Group also has considerable business operations in non-European countries, mainly in Thailand, Malaysia, Sri Lanka, China, Chile, Ecuador, Brazil, South Africa, USA and Mexico. The production facilities which are operated in non-European countries are generally equivalent to the European units.
The supply chains of the Group include the following:
- production processes of raw materials including marine and vegetable materials;
- processing operations for sourced components;
- contract manufacturing agreements; and
- distribution arrangements.
Through the Group’s close work with its supply chains, we have substantial monitoring and compliance controls with respect to our raw material suppliers.
Policies on human rights
Regardless of which country we operate in, each company in the Group is dedicated to observing human rights and treating employees with dignity and respect. The Group supports and respects the protection of internationally proclaimed human rights as set out in the UN Universal Declaration of Human Rights and the declarations and recommendations of the ILO.
Risk Management
We are committed to ensuring that our business and supply chains are free from slavery or human trafficking. We expect our portfolio companies to understand and address our expectations related to human rights, and to inform management and employees if expectations are not being met.
We have performed general assessments of the primary risks affecting the Group in relation to human rights and strive to uphold the same high standards on all production units, particularly where units are located in what are defined as high risk countries. These assessments were carried out in collaboration with representatives from the Group’s major businesses.
Due to the nature of our business and the policies already in place, modern slavery and human trafficking is not believed to constitute a significant CR risk within the Group. Nevertheless, the Group pay considerable attention to ensuring that high standards are maintained in terms of human rights. The Group is committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. We will continue to monitor our supply chains and business operations in relation to slavery and human trafficking through future general risk assessments.
Due diligence and risk management
We have performed a general assessment of the primary risks affecting the Group in relation to human rights. Extending on this, it is the responsibility of our portfolio companies to carry out the general due diligence in terms of adverse impacts on human rights. The portfolio companies’ own operations are generally of high standard in terms of quality and occupational health and safety, and several of our sites across the world are certified according to international standards. The risk of modern slavery in our own operations is therefore considered low.
Our general human rights risk assessment has showed that our global supply chains are characterised by production of raw materials and processing operations of sourced components which can cause risks in terms of human rights violations including slavery and human trafficking. To address this, all our portfolio companies have substantial compliance procedures in place. All our portfolio companies have a Code of Conduct that requires suppliers to uphold and respect international human rights including non-tolerance of bonded or forced labour. The companies also have due diligence processes that typically includes self-assessment, regularly risk assessments as well as audit schemes to address any potential risks in their supply chains.
Reporting and training
As part of our annual ESG reporting, the Group has started to measure the efforts in responsible supply chain management. In four of our six portfolio companies, suppliers covering more than 75% of our spend has confirmed compliance with our Code of Conduct, and actions will be taken to address the remainder. At group level we have further scheduled an update of our Policy on Corporate Responsibility this year. Since the last statement, there has not been conducted any group-wide training and capacity-building on human rights, modern slavery, or human trafficking.
