Modern slavery and human trafficking statement
We are committed to improving our practices to ensure that slavery and human trafficking is not taking place anywhere within our business or within our supply chain. We continue to take positive steps to this end and describe below the progress that has been made over the last year.
About JLA
JLA was founded in 1973 in West Yorkshire, and has grown to become a leading Critical Asset Supply & Service business offering end-to-end solutions in laundry, catering, fire safety, heating ventilation and air conditioning. Following a number of acquisitions and significant organic growth the JLA Group now employs over 1,000 people operating across the UK and Ireland. The JLA Group supplies goods and services to its customers via a number of trading entities and associated group companies and this statement and the commitments made below apply in respect of the entire JLA Group. JLA is owned by private equity firm Cinven Partners LLP (“Cinven”). Cinven does not tolerate modern slavery and seeks to prevent any form of slavery or human trafficking in its business and supply chains. As an investment advisor it also recognises the importance of engaging with portfolio companies, such as JLA, on this important subject. JLA works with Cinven on an ongoing basis on a variety of Environmental, Social and Governance (ESG) matters. One such matter relates to our commitment to preventing any form of slavery or human trafficking in its business and supply chains through.Organisation structure and supply chains
JLA has a zero tolerance approach to modern slavery in its business and that of its supply chain. Our employment practices are compliant with applicable employment and health and safety legislation, and as a result, we are confident that there is no slavery, human trafficking or child exploitation taking place within our organisation. As part of the on-boarding process, all employees are required to provide documentary evidence of their entitlement to work in the UK and all employees are required to hold a UK bank account. JLA is fully compliant with the legislative requirements of both the National Minimum Wage and the National Living Wage. Furthermore, we ensure that the employment agencies that we deal with are also fully compliant with the applicable legislation.Our supplier code of conduct
JLA is proud of the strength and longevity of the relationships that it has with a number of trusted key suppliers both in the UK and around the world. Notwithstanding the length of those relationships, we remain vigilant against modern slavery practices. Last year we developed a Supplier Code of Conduct which we issued to all our suppliers to ensure they exhibit the same standards we demand of ourselves when it comes to combatting Modern Slavery and implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place anywhere in their organisations and supply chains. This year we have updated the Supplier Code of Conduct to align ourselves with the international standards set out in the UN Guiding Principles on Business and Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. We will keep the effectiveness of the Supplier Code of Conduct under review and will take appropriate action if our suppliers are not willing to comply with our code, or cannot otherwise demonstrate that they comply with international standards on modern slavery.Our due diligence processes
Given the number of its suppliers, JLA implements a risk based approach in seeking to ensure that there is no slavery or human trafficking in its business or supply chain. As part of our initiative to identify and mitigate risk, we have for a number of years carried out a review of our equipment supply chain across the Group to identify and assess any areas of potential risk. Given the responses received, the nature of our suppliers’ business operations and their location we consider the risk to be low. We will terminate our relationship with any supplier who fails to engage in this process and continue to request that any new supplier confirms their adherence to the Supplier Code of Conduct as a mandatory part of the supplier on-boarding process. This year we will undertake a structured overview of our supply chain and categorise the material suppliers by high, medium or low risk. A supplier evaluation document will score the suppliers across a number of criteria, including the Global Slavery Index, and this evaluation will then be used to create a Supplier Development Programme for those suppliers that are either high inherent risk, or where we have identified room for improvement. We will then work with the supplier to address and agree a rectification or improvement plan where necessary.Staff training and identifying risk
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we continue to take steps to raise awareness amongst our suppliers, contractors and our employees. We will ensure that for any employee involved in the supplier onboarding process they will have access to and full awareness of the Supplier Code of Conduct and the supplier due diligence process. Last year we rolled out e-learning for all our staff regarding Modern Slavery. We also have a comprehensive suite of online training for all staff, to ensure that they are up to date with the latest legislation and understand the actions they need to take if necessary. In addition, this year we shall deliver bespoke training to all our procurement and supply chain staff regarding our policies and procedures on Modern Slavery. All staff are required to confirm acceptance of our suite of policies, which includes information on our approach to combatting modern slavery and our Whistle Blowing procedure. We have made it clear to all staff that we take any concerns raised regarding modern slavery extremely seriously and we will act on them quickly.Our objectives for the next 12 months
- As we continue to move into new sectors and markets we will ensure that we continue to implement our partnership approach to working with our suppliers and ensure that new relationships are based on the same ethical principles to build long term, strong and mutually beneficial partnerships. This will include requiring all new suppliers to accept our Supplier Code of Conduct.
- We will ensure that all new businesses joining the JLA Group are included in the review process and are educated in and adopt JLA’s existing policies on Modern Slavery. This typically occurs within 3 months of the new business joining the Group.
- By the end of current financial year we will have completed a risk-based evaluation of our most material suppliers and devised Supplier Development Programmes for those demonstrating higher risk characteristics.
- We will continue deliver online training to all our staff on modern slavery on an annual basis, and by June 2024 we will have delivered bespoke training on our Modern Slavery policy and procedures to all our procurement and supply chain staff.