1. Introduction
This policy sets out Global Distribution's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
Global Distribution recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
Global Distribution is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
2. Organisational structure and supply chains
Global Distribution is primarily involved in the distribution of technology products to customers who are resellers/services providers in EMEA and North America.
2.1. Countries of operation and supply
Global Distribution currently purchases products from the following countries:
- USA
- UK
- Germany
- Taiwan
- China
- Austria
- Bulgaria
- Slovenia
- Japan
- Australia
- Thailand
- Mexico
Global Distribution currently operates within the following countries:
The company also has a third-party logistics warehouse in Germany.
2.2. Risk assessment
The following is the process by which Global Distribution assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
- Regular review of high-risk countries/vulnerable populations
- Regular review of high-risk activities
The above is carried out using reports from https://www.globalslaveryindex.org/ and https://www.stronger2gether.org/
2.3. High-risk activities
The following activities are considered to be at higher risk of slavery or human trafficking:
- Manufacturing and assembly of products.
- Responsibility
Responsibility for Global Distribution’s anti-slavery initiatives lies with the Procurement Director.
3. Relevant policies
Global Distribution operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
- Whistleblowing Policy Global Distribution encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Global Distribution’s whistleblowing procedure is designed to make it easy for workers to make disclosures – without fear of retaliation.
- Behavioural Expectations (Section 1 in Global Distribution’s Employee Handbook) Global Distribution’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
- Supplier/Procurement Questionnaires Global Distribution is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Our supplier questionnaire is used for all suppliers and audits may also be used where there are areas of concern.
4. Due diligence
Global Distribution undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. Global Distribution’s due diligence and reviews include:
- mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
- evaluating the modern slavery and human trafficking risks of each new supplier;
- reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
- conducting supplier audits or assessments through the organisation's own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
- creating an annual risk profile for each supplier;
- taking steps to improve substandard supplier practices, including providing advice to suppliers and requiring them to implement action plans;
- invoking sanctions against suppliers that fail to improve their performance in-line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
