Modern Slavery Act

Modern Slavery Act

FOR THE FINANCIAL YEAR 1 MAY 2022 TO 30 APRIL 2023

Introduction

Recork Ltd (“Recork”) is committed to conducting its business in a lawful and ethical manner. Recork will tolerate neither slavery nor human trafficking and applauds efforts being made globally to eliminate such practices. Recork expects its suppliers, contractors and service providers (“Suppliers”) to also support it in eliminating such practices. This Statement is made by Recork Ltd as the body required to make a Section 54 statement in respect of the financial year ending 30 April 2023. It sets out a summary of the steps Recork has taken and is currently taking to help prevent slavery and human trafficking in its business and supply chains. It is published in accordance with the reporting obligation in the Modern Slavery Act 2015 (“MSA”). Notwithstanding the steps Recork is already taking to help prevent slavery and human trafficking, Recork views the steps being taken as an evolving process and will continue to monitor and review its risk profile and the steps being taken to improve and strengthen its practices.

1. Policies

To help prevent modern slavery or human trafficking in our business and supply chains we have adopted an Anti-Slavery Policy which sets out our position on the issue. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity and to implementing effective systems and controls to prevent any slavery or human trafficking from taking place in our business and supply chains. We will monitor and update the policy as necessary.

Our standard Supplier contract terms contain specific clauses which require our Suppliers to warrant that they will comply with our Anti-Slavery Policy and the issue is further considered as part of the due diligence we undertake with our Suppliers.

Our Code of Conduct and Business Principles (the “Code of Conduct”), sets out our commitment to upholding, in our business operations, the internationally accepted standards on human rights, labour and employment laws including legal requirements related to minimum wage.

The Code of Conduct and Anti-Slavery Policy also applies to all our employees and to permit a proper understanding of the risks of modern slavery and human trafficking, we provide training to relevant members of staff on the policy. All Directors are briefed on the subject and review this statement on an annual basis.

2. Due Diligence

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, child labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Recork expects all of its Suppliers to act ethically and with integrity and to have in place effective systems and controls to prevent modern slavery from taking place anywhere in their own business or in any of their supply chains.

Before a new Supplier is approved, Recork will carry out appropriate due diligence on the Supplier. As part of this process, Recork will review the Supplier’s policies and systems on anti-
slavery and human trafficking. Where a Supplier does not provide a copy of their policy, then a copy of the Recork Anti-Slavery policy will be made available to them. New Suppliers will only become approved Suppliers once Recork has completed its due diligence.

3. Risk Assessment and Management within our business and in our Supply Chain

Our business is within the UK and all our direct employees are based and employed entirely within the UK and paid the Living Wage or above. Accordingly, we consider the risk of slavery or human trafficking occurring within our own business to be very low.

In our supply chains, we see our main sector risk as being manufacturing. We contract with a number of EU-based Suppliers in these sectors.

For material and higher risk Suppliers, Recork endeavours to include contractual clauses within its agreement with the Supplier placing contractual obligations on the Supplier to monitor that its own suppliers comply with the law on anti-slavery and human trafficking.

As part of this, we endeavour to contractually oblige these Suppliers to inform us as soon as they become aware of any breach or potential breach of our Anti-Slavery Policy and, in particular, any actual or suspected breach in their supply chain in relation to the services they provide to Recork.

4. Effectiveness of our Anti-Slavery processes

We take a zero-tolerance approach to modern slavery and human trafficking in our business. During the year we have not identified any instances of modern slavery or human trafficking in our business.

Recork has in place a Code of Conduct and Anti-Slavery Policy with which Recork’s Suppliers are expected to adhere.

Recork views any breaches by a Supplier of our policies or the Supplier’s contractual commitments very seriously. Breaches may result in Recork requiring an immediate remediation plan. Recork may also terminate its relationship with any Supplier that is in breach or fails to cooperate with remedying a breach.

5. Training

Our Code of Conduct and Anti-Slavery Policy contain specific provisions on human rights, employment rights and anti-slavery practices. Training on these documents is provided to all new starters as part of their induction programme and periodic reminders are sent to all staff as appropriate.

We will continue to monitor the above safeguards and consider implementing further measures as required.

This statement was approved by the Board of Recork Ltd on 30 April 2022.