Modern Slavery Act
ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT, 31.01.19
Introduction from the Managing Director, Rupert Berkmann
We are committed to improving our practices to combat slavery and human trafficking. Although we believe that the wine industry is not one of the industries that traditionally uses enforced labour, and that the regions where wine is made are not typically known for abusive labour practices, we still believe it is our responsibility as a good corporate citizen to do what we can. We have begun a plan to review our suppliers, and our main business partners to make sure they are aware of our commitment, and our zero-tolerance policy on slavery and human trafficking.
We are the largest family owned and family run wine importer in the UK. We have been selling wine to restaurants since 1964 and have over 200 employees. Our head office is based in London, but we have branches around the UK in Birmingham, York and Scotland.
Berkmann Wine Cellars Ltd, incorporated in 1964 is currently divided into 3 separate trading divisions: On Trade, Off Trade and Spirits.
The On-Trade division supplies the hospitality sector and the Off-Trade division supplies supermarkets and regional wholesalers. Spirit Cartel is our spirit division and supplies to all sectors, but primarily through regional wholesalers.
Our Supply Chains
Our supply chain primarily consists of independent wine producers and wholesalers, who are on the whole, based in the same country as that where the grapes are grown, and the wine produced.
In most cases, we source the products directly from the producers, although occasionally we have to go through distributors and resellers.
In many cases, we have exclusive UK distribution rights and we take care to visit our growers and producers regularly to verify their continuing quality and commitment to service.
The physical importing and transportation of the products we buy is contracted out to third parties and we select these third-party hauliers with the greatest of care and after appropriate due diligence checks. We visit our hauliers on a regular basis to ensure their continual professional service.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we have started a process of reviewing our suppliers and business partners, on a risk-weighted basis, starting with those from whom we purchase the most. As at the date of publication, we have contacted 70 suppliers asking them to complete a comprehensive questionnaire to ensure that they are also committed to eradicating slavery within their own supply chains.
We have received a number of responses and will continue with this process until we have contacted all of our suppliers.
We commit to keeping the questionnaire updated and relevant for our business model and to request further information or clarification where necessary.
Over the next year or two, we intend to put in place systems to:
- Identify and assess potential risk areas in our supply chains, building in additional enquiries into our existing visit schedule.
- As part of our new supplier due diligence, we will include our anti-slavery questionnaire, and our bribery and corruption questionnaire.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains by completing personal visits where possible and ensuring we ask relevant questions in meetings with our producers, hauliers and wholesalers.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we plan to put in place a supply chain compliance programme. This is likely to consist of:
Risk assessment based on country and industry;
Supplier visits; and
Our contractual terms will undermine our commitment to eliminating modern slavery and all new supplier agreements to include an anti-slavery commitment.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we are planning to introduce training to our staff where appropriate.
Following a review of the effectiveness of the steps we have taken this year to ensure that here is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:
We will roll out our supplier questionnaire to further suppliers and we will look to introduce a supplier due diligence process that goes beyond the usual quality and financial checks we currently perform.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2019.
Berkmann Wine Cellars Limited