Modern Slavery Statement in relation to the Modern Slavery Act 2015
for the financial year ended 31 December 2023
Introduction
This statement sets out the actions and activities that Likewise Group plc (‘the Group’) has taken during the financial year ended 31 December 2023 and is continuing to take, to ensure that modern slavery or human trafficking is not taking place within the Group or its supply chain.
We recognise that modern slavery is a global issue, a long-term risk, and that no supply chain is without risk. It is, however, our responsibility to ensure we understand these risks, work in partnership with our suppliers to identify and mitigate them, and look for ways to improve our practices to best prevent modern slavery within our organisation and supply chain.
Our business structure and supply chain
This statement covers the activities of Likewise Group plc and its subsidiaries, a flooring and matting distribution business operating in the UK, with international trading partners in Europe, Asia and the Far East. We have a small manufacturing presence in Sudbury. During the financial year ended 31 December 2023, we held business relationships and partnerships with approximately 159 suppliers in 16 countries.
Due Diligence process
We map, assess, and prioritise risks of modern slavery and related exploitation in our operations and supply chain:
Our employment practices and operations
We have assessed our employment practices to ensure that they are fair and working conditions are decent. To this end, all of our workers are paid on time and no workers are required to work excessive overtime. All staff have access to safe and sanitary working conditions and we have made considerable investment in our locations and operations to ensure that working environments are high quality. All workers have access to their passports/ID documents at all times and are free to leave their employment at all times. All workers ages are checked and child-labour is prevented. All employees are free to ensure their workers’ interests are adequately represented and are free to join a trade union or workers association of their own choice, without fear of reprisal.
Our direct (Tier 1) suppliers
We currently conduct due diligence on our suppliers or other business relationships to assess their modern slavery risks by asking questions about their own due diligence capabilities via a self-assessment questionnaire, we visit various suppliers’ sites and facilities and conduct a social audit on an annual basis.
Our high-risk areas
We assess whether or not a particular activity is at risk of modern slavery or human trafficking by undertaking a risk assessment with any new and existing suppliers.
During the period ended 31 December 2023, our reviews have not identified any activities to be at high risk of slavery or human trafficking within the Group’s supply chain. Other risks considered during the period covered the sourcing of materials from China, India and South Korea in respect of terrorist attacks on commercial ships.
The company is aware that some communities and groups, in the market it operates in, may be particularly vulnerable to impacts in certain circumstances, for instance, indigenous peoples, children, women or ethnic groups. In the event of any breach of the Modern Slavery Act, our internal processes ensure that the Board are alerted. A response and mediation plan is planned for delivery by the end of 2024.
Our policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
Our suppliers
The Group is developing a procurement policy and maintains a preferred supplier list. We conduct due diligence on all suppliers with an annual spend in excess of £250k. This due diligence includes an online search to ensure that an organisation has never been convicted of offences relating to modern slavery.
As part of due diligence and developing our governance framework, the Group’s risk assessment process now considers the type of product or service being supplied, the area of operation, whether a supplier has published a policy and statement in relation to modern slavery and whether any of its services are outsourced. Where the supplier provides goods and services from abroad, they are asked to demonstrate that employment practices are ethical and comply with good practice. This process was introduced in March 2024 for all new and existing suppliers with an annual spend in excess of £250k.
An annual review is completed in respect of any new supplier that could be deemed at risk or where they are obliged to provide a statement under the Modern Slavery Act. During the 2023 financial year, no risks were identified within the Group’s supply chain.
Our suppliers are expected to comply with all legislation in relation to the Modern Slavery Act, to commit to not taking part in any action that might cause or lead Likewise Group plc or its subsidiaries to be in violation of the Act, to assist us in the performance of activity by any regulatory body for the purposes of the Act, and to provide assurance that there is no Modern Slavery taking place in their supply chain.
Training
A Modern Slavery training course is planned for managers in the first half of the year and further training and compliance led activities are planned for all staff in 2024.
The training outlines the signs of modern slavery coupled with the steps and procedures to follow and take if modern slavery is suspected within our supply chain.
Our performance indicators
We will know the effectiveness of the steps we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from our colleagues, the general public or law enforcement agencies to indicate that modern slavery practices have been identified.
During the year ended 31 December 2023, no issues were highlighted through the Group’s Whistleblowing Policy.
We will continue to monitor key controls in respect of Modern Slavery and Human Trafficking during 2024/25 and we will take appropriate action if we suspect or are advised of any instances of modern slavery or human trafficking within the Group or our supply chain.
This statement was approved by the Board of Likewise Group plc and signed on its behalf by
Tony Brewer
Chief Executive
8 March 2024
