This statement has been published in accordance with the Modern Slavery Act 2015 which requires businesses to disclose the steps they have taken to combat Modern Slavery.
Bluestem Group (operated by Lancaster Holdings Ltd, registered in England & Wales, Number 11089637) have taken the following steps to prevent modern slavery in its own business and supply chains for the financial year ending 30th April 2022.
At Bluestem Group we respect human rights and have a zero-tolerance approach to any forms of modern slavery. We recognise that no supply chain is without risk of modern slavery and it is our responsibility to ensure we understand the risks in partnership with our suppliers to mitigate them.
We are committed to acting ethically and with integrity in all activities and business relationships and we expect our supply chains, contractors, employees and all other business partners to commit to the same.
At the time of publication we are not aware of any circumstances of modern slavery occurring either within our business or supply chains.
OUR BUSINESS
The economic, social and environmental footprint of our business activity is a fundamental consideration in the Company’s commitment to responsible and sustainable business growth.
Bluestem Group have been suppliers of electrical appliances since 1988. As a manufacturer of product with a portfolio of the multichannel brands, Bluestem Group operates in several sales channels; supporting independent and national retailers, wholesalers and distributors as well as B2B and facilities management. Based in Ipswich, Suffolk, the day to day operation of the business is the responsibility of the Group Manager, who in turn reports to the Director of Operations.
We listen to customer needs and provide information to help customers make an informed choice.
OUR COMMITMENT
Bluestem Group are committed to respecting human rights and to ensuring there is no modern slavery or human trafficking in its business or in any part of its supply chains. We have implemented employee training via our E-Learning portal and raised supplier awareness by writing to them to request their assistance to help us to fulfil the obligations we place upon them to take measures to ensure their own supply chain is free of slavery and human trafficking.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We have several internal and external policies which set out our expectations and requirements, copies of these have been made available to each employee. These policies are reviewed by the Directors and Senior Management of the company on an annual basis, an additional review would be undertaken in the event of any changes to the Modern Slavery Act 2015.
Modern Slavery and Human Trafficking Policy
The policy sets out Bluestem Group’s commitment to the prevention, detection and reporting of modern slavery in any part of our business or supply chain. It mandates all persons working for us or on our behalf in any capacity, including our employees, suppliers, workers, directors, agents, distributors and all third-party business partners to comply with the policy. The policy forms part of the Company Employee Handbook which is available to all employees, it also forms part of the new employee starter pack and will be available via our onboarding portal. Our Human Trafficking
E-Learning module is reviewed annually to ensure maximum employee awareness of the company’s ongoing commitment.
Ethical Trading and Modern Slavery Supplier Policy
Our Ethical Trading and Modern Slavery Supplier Policy forms part of our Terms and Conditions of Purchase. It requires our suppliers to comply with the Ethical Trading Initiative (ETI) Base Code, National and International Laws, statutes and regulations, relating to minimum wages, working hours, working conditions, child labour, discrimination, health & safety and the Modern Slavery Act 2015.
Anti-Bribery, Hospitality and Gifts Policy
Bluestem Group have a zero-tolerance approach to anti-bribery, we are fully committed to acting ethically and with integrity in all of our business activities and relationships and expects our supply chains, contractors, employees and business partners to commit to the same. Training on this policy is provided to all employees via our E-Learning module, the policy is included in the Company Employee Handbook which is distributed to all current and new employees.
Whistleblowing Policy
Our Whistleblowing Policy sets out the internal procedure an employee should follow to make a disclosure should they observe any malpractice, impropriety, fraud or the maltreatment of people within the company or our supply chains. All reported incidents are treated in the strictest confidence, taken seriously and fully investigated. At the date this document was signed we have not received any disclosures relating to slavery or human trafficking.
PREVENTING SLAVERY AND HUMAN TRAFFICKING IN OUR BUSINESS
Employees – Permanent and Temporary
Bluestem Group employs over 65 employees in the UK, all of whom are subject to UK employment laws.
Recruitment is handled locally; all applicants are required to provide photographic evidence to prove their identity and evidence of their Right to Work in the UK. Copies of these documents are taken and signed by the interviewer.
Driving licence checks are also made at the same time; the results are printed and signed by the interviewer.
If the applicant is successful all documents are forwarded onto the Payroll Department where further checks are carried out, including verification that the bank account details provided are held in the name of the new employee. Once all checks have been satisfied the employee is processed onto the payroll.
Current employees with work permits giving them the right to work in the UK are subject to review prior to the expiry date of the permit.
Occasionally we employ temporary staff; these are sourced locally using approved specialist employment agencies. These agencies have in place stringent recruitment processes to help ensure there is no existence of modern slavery in any of the temporary staff they provide, including identity verification, right to work checks, bank account checks and employment history checks.
Whistleblowing
Anyone employed within our business whether on a permanent or temporary basis wishing to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains is encouraged to speak with their immediate Line Manager as a matter of urgency. As a matter of policy, we will support any whistleblower who raises a genuine concern even if this turns out to be mistaken.
Awareness and Training
Management at all levels are responsible for ensuring the employees reporting to them understand the seriousness of Modern Slavery and Human Trafficking and they are given adequate training on it and the effect it could have on the Company’s business and supply chains.
As part of their induction to the Company, all new employees receive training on the risk faced by our business from Modern Slavery and Human Trafficking.
During the financial year ending 30th April 2022 the Company actively increased employee awareness of the Modern Slavery Act 2015, via its E-Learning portal.
The E-Learning module continues to be used to train employees in the Management, Sales, New Product Development and Purchasing and Marketing Teams. Regular refresher training will be provided as required.
The issue of Modern Slavery and Human Trafficking together with our policy is included in the Company Employee Handbook which is distributed to all employees of the Company.
A copy of the Company Handbook was included in the employment pack which was distributed to all new employees joining the business during the financial year ending 30th April 2022.
The Procurement Team through ongoing dialogue with existing and new suppliers continue to raise awareness of the importance Bluestem Group places on its approach to Human Rights and its zero tolerance to any form of modern slavery.
We continue to include in our procurement procedure the importance of including in our negotiations with any prospective new suppliers our requirement for them to provide evidence of their compliance with the Ethical Trading Initiative (ETI) Base Code, National and International Laws, statutes and regulations, relating to minimum wages, working hours, working conditions, child labour, discrimination, health & safety and the Modern Slavery Act 2015.
We will only trade with a new supplier once they have signed and committed to our supplier policy for Ethical Trading and Modern Slavery.
OUR SUPPLY CHAINS
We purchase goods and services mainly from suppliers based in the UK, China and Turkey who we have forged long term relationships with and who share the same commitment to the Modern Slavery and Human Trafficking Act as ourselves.
The Company Ethical Trading and Modern Slavery Supplier Policy and Terms and Conditions of Purchase have been reviewed during the financial year ended 30th April 2022, at that time it was felt both documents continued to support and reflect Bluestem Group’s zero tolerance to Modern Slavery.
As part of our due diligence process we have continued our on-going dialogue with our major suppliers who fully understand and fully support our zero tolerance to modern slavery. All new suppliers and prospective suppliers are sent a copy of our Modern Slavery and Human Trafficking policy and Supplier Charter.
Bluestem Group expects all of it suppliers to ensure, as far as is reasonably practicable that their own suppliers and agents, who are directly or indirectly involved in the provision of goods to Bluestem Group, comply at all times with all applicable national and international laws, statutes and regulations including the Modern Slavery Act 2015.
We recognise that collaborative working with our suppliers is vital to effectively mitigating the risks to ensure continual improvements to the standards in our supply chains.
We work with a large number of suppliers who are responsible for the production of products for our own exclusive brands. As these suppliers present a higher risk due to their geographical location, we monitor their compliance continually. As part of our due diligence process, each of these suppliers are independently audited and site inspections are carried out on a regular basis. A detailed assessment is then compiled which includes a check to ensure there is no forced, bonded or involuntary labour, the employees’ working conditions, working hours, there is no child labour and all applicable national and international laws, statutes, regulations and our Anti Slavery and Human Trafficking Policy are adhered to at all times.
The supplier assessments have been reviewed by Senior Management and nothing has been found which indicates non-compliance with the Ethical Trading Initiative (ETI) Base Code, National and International Laws, statutes and regulations, relating to minimum wages, working hours, working conditions, child labour, discrimination, health & safety and the Modern Slavery Act 2015.
We may terminate our relationship with any organisations working on our behalf if they fail to comply as a minimum with the Ethical Trading Initiative (ETI) Base Code, National and International Laws, statutes and regulations, relating to minimum wages, working hours, working conditions, child labour, discrimination, health & safety and the Modern Slavery Act 2015
ONGOING REVIEW
Bluestem Group’s Directors and Senior Management team will continue to review the effectiveness of the steps taken to ensure that there is no slavery or human trafficking in the business or supply chains.
We will continue to conduct risk assessments of our supply chains, external operations and internal operations to ensure compliance with the Modern Slavery Act 2015.
The Modern Day Slavery E-Learning module is key to our employee training, the effectiveness of the module to communicate clearly and accurately the issue of modern slavery will be reviewed on a regular basis and updated where necessary to ensure maximum employee engagement.
The module sends out a clear message to all employees about Bluestem Group’s zero tolerance approach to modern slavery and the actions an employee should take if they wish to raise concerns about an issue or suspicion of modern slavery in any part of the business or supply chains.
This statement was approved by the Board of Directors of Bluestem Group Limited and Lancaster Holdings Ltd on 11 October 2022 and 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 30th April 2022. Kim Davies was authorised by each Board member to sign the statement on their behalf.