Modern Slavery Statement

Introduction.

This policy sets out Mark & Graham's (The Board of Wray Brothers Limited) wishes to operate in a manner that is conducive to the promotion of good practice in relation to Modern Slavery and Human Trafficking. This is the first attempt by both Mark & Graham to embed such a policy into the fabric of the business.


Modern Slavery Statement for Financial Year 2016/17

The Board members of Wray Brothers Limited are committed to acting ethically and with integrity and transparency in all business dealings.
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Wray Brothers Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within its business or supply chain.


Compliance, Monitoring and Reporting

Compliance with this policy will be continuously monitored and subject to review by the Board of Wray Brothers Limited. Compliance will be reported on after, the annual review date.
Each line manager is expected to ensuring that the principles set out in this policy are communicated to, understood and observed by all employees and for ensuring compliance in their area of responsibility.
Employees who reasonably suspect that there has been a breach of this policy must report it to their line manager, or Graham Wray (the company secretary). We recognise that employees may be reluctant to report concerns for fear of retaliation and will take disciplinary action against any employee who threatens or engages in retaliation, retribution, or harassment of any person who has reported or is considering reporting a concern in good faith.
The Board of Wray Brothers Limited will not criticise management for any loss of supply chain resulting from adherence to the principles set out in this policy.
Wray Brothers Limited, Corporate Social Responsibility Policy underpins this Policy.


The Business of Wray Brothers Limited

Wray Brothers Limited operates predominantly within mainland UK. Wray Brothers Limited is a member of Jangro Limited. Jangro Limited is a Janitorial, PPE and Catering buying group.
100% of Wray Brothers Limited products procured, directly or non-directly, are from low risk sources.
Any changes in the company's business activities, an assessment will be undertaken to determine whether the intended activities or the sourcing countries are a high risk in relation to modern slavery or human trafficking.

Definitions

Wray Brothers Limited considers modern slavery encompasses: Human trafficking
Forced work, through mental or physical threat
Being owned or controlled by an employer through mental or physical abuse of the threat of abuse.
Being dehumanised, treated as a commodity or being bought or sold as property
Being physically constrained or to have restrictions placed on freedom of movement.
Wray Brothers Limited has a zero tolerance approach to any form of modern slavery & human trafficking.

Exposure

The Board of Wray Brothers Limited considers its exposure in its day-to-day activities to the potential of slavery & human trafficking as low risk. This said; it continually monitors & reviews its policies, the effectiveness of these polices and in communicating these policies believes it can only do good in adding & aiding to the greater awareness.


Our Policies

Wray Brothers Limited operates a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.


Recruitment

Wray Brothers Limited uses accredited only agencies in its recruitment requirements
We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.


Whistleblowing

We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.


Corporate Social Responsibility Policy

The Board of Wray Brothers Limited seeks to be a good corporate citizen in everything that it does. We have determined to bring together our existing operating principles into one framework policy under the heading of Corporate Social Responsibility
This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.


Suppliers

For the most part and in tandem with Jangro, Wray Brothers Limited operates a supplier policy and maintains a preferred supplier list. Together we conduct due diligence on all suppliers before allowing them to become a preferred supplier.
This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery
Our policies form part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
They have taken steps to eradicate modern slavery within their business
They hold their own suppliers to account over modern slavery
UK based suppliers. They pay their employees no less than the national minimum wage
International suppliers. They pay their employees no less than any prevailing minimum wage applicable within their country of operations

Training

We regularly conduct training for our procurement/buying team
Our Performance Indicators
We will know the effectiveness of the steps that 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:
Employees,
External stake holders
Law enforcement agencies
The media .

For a copy of our Modern Slavery Policy please contact a member of the team on 0151 709 2271 and we will email it to you straight away.