Sumika Polymer Compounds Group Statement against Modern Slavery and Human Trafficking
1. About the Statement
Sumika Polymer Compounds (Europe) Ltd (“SPCEU”) and its subsidiaries Sumika Polymer Compounds (UK) Ltd (“SPCUK”), Sumika Polymer Compounds (France) S.A. (“SPCF”), Sumika Polymer Compounds (India) Pvt Ltd (“SPCI”), Sumika Polymer Compounds Turkey Plastik Sanayi ve Ticaret A.S. and Almen Plastik A.S (“SPCT”) (together, the “SPCEU Group”)are fully committed to promoting human rights and preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and imposes the same high standards on its suppliers. This annual statement is made as part of its public commitment to promote human rights and pursuant to s54 of the UK Modern Slavery Act 2015 and the U.S. California Transparency in Supply Chains Act of 2010, and with consideration for the requirements of other laws and regulations in relation to modern slavery, human trafficking, forced labour, child labour and respect for human rights. This statement is made for the financial year commencing 1 April 2019 and ending 31 March 2020.
2. Our Business
SPCEU is the parent company of the Sumika Polymer Compounds group in Europe comprising companies in the U.K., France, Turkey and India. The group develops and manufactures plastic compounds, employing approximately 250 people across all group companies.
The SPCEU Group has a global annual turnover of £100M. To find out more about the nature of our business, please click www.sumikaeurope.com.
3. Our Supply Chain
Our business requires the purchase of various raw materials including polymers, chopped strand glass fibre, minerals such as talc and chalk, coupling agents, colourants, and other chemical additives. The suppliers we work with include companies affiliated with SPCEU’s four Japanese corporate shareholders – Sumitomo Chemical Co. (“SCC”), Toyo Ink, Itochu Europe plc and Itochu Corporation -, as well as unrelated suppliers.
The SPCEU Group implements policies put in place by the majority shareholder, SCC.
As part of our commitment to combating modern slavery, we have in place a code of conduct which sets forth a requirement that all relevant personnel must respect the human rights of others and comply with applicable laws, regulations and ethical standards.
In April 2019, the SCC Group established the “Sumitomo Chemical Group Human Rights Policy” based on the Universal Declaration of Human Rights, the International Labour Organization Declaration on Fundamental Principles and Rights at Work, the Ten Principles of the United Nations Global Compact and the United Nations Guiding Principles on Business and Human Rights, that includes the prohibition of forced labour and child labour.
The SCC Group statement against Modern Slavery and Human Trafficking can be accessed by clicking https://www.sumitomo-chem.co.jp/english/sustainability/files/docs/statement_20200401e.pdf
The SPCEU Group places high importance on building a reporting system in order to capture at an early stage signs of compliance violation, including any concern of SPCEU Group’s business having been involved in modern slavery or human trafficking, and to make sure those issues detected are removed promptly and appropriate measures are taken swiftly. Under our Speak-Up Reporting System any employee or third party can report any violation or suspected violation of compliance to the compliance committee or other similar governing committee through several different internal and external channels, including an external platform available for suppliers and anyone having any involvement in the companies’ business activities to report any concerns.
5. Due diligence
It is SPCEU Group’s policy to only procure supplies such as raw materials and packaging materials from suppliers that operate their business in a socially responsible manner, including operating their business free from modern slavery or human trafficking. As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have due diligence procedures which are designed to:
- establish and assess areas of potential risk in our business and supply chains.
- monitor potential risk areas in our business and supply chains.
- reduce the risk of slavery and human trafficking occurring in our business and supply chains.
- provide adequate protection for whistle-blowers.
We are currently in the process of revising the standard contractual terms of the SPCEU Group, to incorporate a human rights clause that requires our supply chain to promise and certify to comply with laws and regulations in respect of management of human rights risk including prohibition of modern slavery, human trafficking, forced labour and child labour.
6. Risk and compliance
SPCEU has begun the evaluation of the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by undertaking a survey of the anti-slavery policies and processes in place in the companies that supply to its UK subsidiary. This evaluation is ongoing and will eventually encompass the suppliers to all SPCEU Group.
Where we identify a potential risk, we will engage with those suppliers to establish appropriate measures and actions to address the risk, which may include focussed requests for improvement and/or offering to provide guidance and training to our suppliers and their supply chain. By seeking to raise awareness and cooperation in ensuring responsible procurement, SPCEU aims to prosper alongside our suppliers.
We will be investing in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees will be encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. Employees will be taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.
8. Effectiveness and KPIs
SPCEU will introduce key performance indicators (KPIs) to measure how successful we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains. These are as follows:
- % of suppliers whose anti-slavery policies and processes have been assessed and deemed adequate.
- number of anti-slavery interventions measured as a percentage of suppliers assessed as a potential risk for slavery and human trafficking.
- % of suppliers who have agreed to standard contractual anti-slavery wording (without substantive amendments).
- % of staff trained in identifying and mitigating risks of modern slavery.
9. Looking Ahead
The SPCEU Group believes that the promotion of respect for human rights and ensuring compliance with applicable laws, regulations and ethical standards, including those relevant to modern slavery and human trafficking, is vital for operating its business in a sustainable manner. As such, SPCEU Group will continue its initiatives as described above, to identify and address any issues associated with modern slavery and human trafficking throughout its operations and supply chains.
This statement was approved by the Board of Directors of SPCEU on 29 September 2020.
Sumika Polymer Compounds (Europe) Limited
Date: 30 September 2020