SCOTTS LTD (SCOTTS & CO) MODERN SLAVERY POLICY STATEMENT
Financial Period Ended 31st December 2021
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory 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.
This statement is published in accordance with the Modern Slavery Act 2015 and sets out the steps that Scotts Limited (Scotts & Co) has taken during the previous financial period to prevent modern slavery and human trafficking from operating within its own operations or within its supply chain.
Scotts & Co.has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
Scotts & Co is a multi-channel retail business with five active brands trading through the legal entity Scotts Limited. With brands including “Scotts of Stow”, “Gift Discoveries from Scotts of Stow”, “Expert Verdict”, “Bloom” and “Viva Vitality”. We largely trade with our customers through catalogue mail order, supported by two flagship retail outlets in Stow-on-the-Wold in addition to increasingly successful web businesses. Scotts & Co’s Cotswold heritage dates back 30 years, to when our first shop in Stow first opened its doors in 1991. Since then, the Scotts & Co business has grown significantly with sales exceeding £50m. The business is privately owned with sites in Groundwell, Wiltshire and Stow-on-the-Wold.
Modern Slavery Within Our Business
We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
Customers and suppliers should be confident that all employees of the business are treated fairly, with respect for human rights and are not exposed to unsafe working conditions or in any way forced to work under slavery. Ethical standards are in place to protect employee well-being and to improve quality and productivity. We do this through a series of measures and policies covering equal opportunities, positive working and health and safety, and by ensuring that all employees have an employment contract. We monitor employee remuneration, benefits and working hours to ensure we meet local and European legislative requirements. Over the next 12 months we will continue to educate all employees on modern slavery at every level and in every department of the business in a format appropriate to their role.
Our Risk Assessment
We have assessed the risk of slavery occurring within our business. As a retailer, the most likely source of slavery occurring in our course of business is via the product supply chain. We have attempted to mitigate this by increasing our knowledge of our suppliers’ businesses and how they source materials and manufacture the products they supply. For our own-sourced products, we endeavour to trace back to factory level. This allows us to satisfy ourselves, and our customers, that the products are not created as a result of slavery.
Modern Slavery & Our Supply Chain
Scotts and Co has built long-standing relationships with our supply chain and work with suppliers globally, sourcing our products from around countries, including China, USA and Hong Kong, as well as European countries such as Spain and France.
We understand that respecting human rights is ultimately our suppliers’ responsibility and expect the same high standards from suppliers, contractors and business partners, that we exhibit within our own internal operations. However, we also recognise our own involvement in ensuring that there are good working conditions for all workers, despite not owning the factories that supply our products. To this end, we work closely with our supply base, both UK-based and abroad, to ensure that they are compliant with a code of conduct that covers the following key areas:
- No forced labour.
- Freedom of association and the right to collective bargaining.
- Safe and hygienic working conditions.
- No child labour.
- Payment of living wages.
- Working hours are not excessive.
- No discrimination is practised.
- Regular employment is provided.
- No harsh or inhumane treatment.
Compliance with this code forms part of their contract to supply our company. Any suppliers found to be in breach of the Modern Slavery Act will be asked to take immediate action to improve conditions. Business relationships may be terminated swiftly if the required improvement is not forthcoming.
Due Diligence Process
In 2021 we continued to maintain a register of those suppliers signing up to the Scotts Code of Conduct or adopting their own similar policy. Maintaining these high standards is central to our commitments in 2022 and we will again focus our due diligence on the higher risk areas of our supply chain, particularly those suppliers based overseas. In the event of travel restrictions resulting from ongoing pandemic conditions, we will work closely with our local agent in the Far East to conduct site visits.
Key Performance Indicators
To measure the effectiveness of steps being taken in relation to this policy, our key performance indicators will continue to be assessed using the following parameters in 2022:
- Training – Equality, diversity, and Modern Slavery training will be given to all current staff and new starters. Going forward all staff will receive refresher training every two years.
- Regular reviews - a wider project team will constantly review and adjust current processes in our supply chain.
- Board level awareness – the Board of Directors and Senior Management Team will review any incidents of Modern Slavery and resultant actions every quarter.
We will continue to focus on our supply chain as this is where we recognise many of the issues relating to Modern Slavery could potentially reside. This statement is made in accordance with the Modern Slavery Act 2015 and constitutes the company’s Modern Slavery Policy Statement for the current financial year.
Approved by the Scotts & Co. Board of Directors on 9th August 2022
Nigel Swabey
Chairman – Scotts & Co.
9th August 2022
