This Statement, pursuant to section 54 of the UK Modern Slavery Act 2015, sets out the steps that Lonrho Ltd. is taking to ensure that slavery and human trafficking are not present in any part of our Group businesses, nor in our supply chains. This is our second annual statement under the legislation.
Slavery and human trafficking are abuses of a person’s fundamental freedoms and rights. We are wholly opposed to such abuses in our direct operations, our indirect operations and our supply chains.
We are not complacent as to the risks of slavery and human trafficking and we are committed to the continual improvement of our policies, standards, practices and programmes with respect to combatting it effectively.
Lonrho currently has an operational presence in 14 countries, primarily in East and Southern Africa. As at end July 2017, our headcount was nearly 700 employees across those countries and in our headquarters in London, UK.
Our operations take place in those countries through a network of businesses under the core themes of Food Supply Chain Management, Market Expansion Services, and Infrastructure. The Group overall combines a mix of existing business and investments in different countries, including:
Our supply chains vary across those businesses and locations, but we are committed to applying commons levels of scrutiny and verification across all Group businesses to ensure that proper controls and standards are in place.
Further information on our structure and businesses, including the countries in which we operate, is available at www.lonrho.com
Policies, standards and practices in relation to slavery and human trafficking
Our Group-wide policy concerning slavery and human trafficking is covered in our five core company values:
These values are being set out in our Employee Handbook/Code of Business Conduct for all staff, with the aim of providing a platform for sustainable development across the Group, and the communities of which we are a part.
Lonrho have in parallel been Active members of the UN Global Compact (UNGC) since 2012, submitting our most recent annual Communication on Progress (COP) at end July 2017. We believe our Core Values closely match the UNGC’s Human Rights and Labour Principles, including:
Under the UNGC Labour Principles, Lonrho commits to adhere to the labour practices as per the Constitution in the country of operations, follow the entire stated SOPs that regards recruitment, selection of staff, and procurement of goods and services, and uphold labour standards across the business operations. This includes employment that is productive and delivers a fair income, one that ensures workplace security, social protection, better prospects for personal development and social integrations.
Lonrho focuses on non-discrimination, equal opportunities and treatment (including for men and women), and freedom to express concerns. Lonrho respects the rights of women by putting in place non-discrimination and sexual harassment policies and recognizes the importance of women as leaders, consumers, entrepreneurs, workers and caretakers. Lonrho prohibits employment of children and forced labour.
Lonrho supports good relationships with employers, contractors and the labour unions that represent them and are vital in attracting the labour resources that the Group needs to maintain operational efficiency and licence to operate. Lonrho recognises workers’ rights to union membership and collective bargaining, and takes a proactive approach to dialogue with workers and their representatives.
Lonrho remains committed to and proud of our diversity, employing more than 18 nationalities across our Africa network. We favour employing local nationals wherever possible, and offer challenging career opportunities regardless of age, ethnicity, religion or gender.
In addition, the Lonrho Board have agreed the relevance of the UN Sustainable Development Goals (SDGs) to our operations. The Board agreed in January 2016 that as a Group we should support the implementation of four SDGs in particular, including SDG8 on Decent work and economic growth. That gave further expression to Lonrho’s determination to work with others (under SDG Target 8.7) “to eradicate forced labour, end modern slavery and human trafficking” .
Risk assessment and due diligence, and steps to mitigate risk
In addition to the standards set out in the Employee Handbook/Code of Business Conduct at Group level, staff across the Lonrho Group are kept up to date on business and corporate matters through face to face meetings, newsletters (including messages by email from individual Board members), and through a Group-wide intranet. That includes the dissemination of information to all on the principles and commitments outlined above, including regarding the Board and Group’s approach to the UNGC and SDGs.
We recognise the need for specific additional steps to assess risks in this area, including in our supply chains, and have therefore set up internal systems to ensure that each component business of the Group operates to these collective standards. That includes issuing in 2017 local supplier questionnaires where needed which are designed to identify:
Who is making or sourcing a product that we use, including associated component parts or sub-contractors where relevant; all relevant stakeholders including investors, customers, suppliers and contractors.
Through this approach we are building up our awareness of risk both in our own businesses and related areas. We consider that the greatest risks are in our supply chains, where relevant to particular businesses – but will continue to monitor and assess all our businesses in this regard.
We will also ensure that risks and compliance in this area are fully factored into future investment decisions, up to Board level.
Our HR processes give us the ability to track issues which may arise, especially through our staff assessment system and whistle-blowing procedures – as set out in the Employee Handbook/Code of Conduct. We keep this under active scrutiny.
Our HR Director and Government and Political Advisor have day-to-day lead on maintaining and developing staff awareness and procedures in this area, reporting to the Board. We ensure that staff compliance training, including at induction, fully covers this area.
This Statement was approved by the Board of Lonrho Ltd. on 21 September 2017.