Modern Slavery & Human Trafficking Statement

Introduction 

Off-Piste Wines Ltd recognises that all businesses have an obligation to prevent slavery and human trafficking and will do all in its power to prevent slavery and human trafficking within its business and within the supply chains through which it operates. 

Modern slavery can take many forms including the trafficking of people, forced labour, servitude and slavery.  We take our responsibility for supplying staff extremely seriously. Our own processes around candidate engagement ensure our employees are alert to the signs of exploitation, allowing necessary action to be taken promptly and effectively should it be identified.

This statement focuses specifically on the Company’s compliance with the Modern Slavery Act 2015 (the Act) and highlights the steps we take to ensure there is no slavery or human trafficking occurring within the organisation or its supply chains. Maintaining this reputation within our market is an essential pre-requisite to our continued success.

Organisation’s Structure 

Off-Piste Wines Ltd is a Private Limited Company based in Cheltenham, Gloucestershire employing circa 40 people.

Our Business

Not your average wine business, going Off-Piste since 2007, we work closely with some of the worlds’ best producers to bring a range of award-winning brands to the UK and global markets.

Our Supply Chains 

Our supply chains include, but are not limited to, sourcing these products for our client base. This may involve the production by external suppliers to Off-Piste Wines Ltd for onward supply to our clients. We expect our suppliers and potential suppliers to aim for high ethical standards and to operate in an ethical, legally-compliant and professional manner. We also expect our suppliers to promote similar standards in their own supply chain.

Our Policies including on Slavery and Human Trafficking

Forced or compulsory labour, human trafficking and other kinds of slavery represent some of the gravest forms of human rights abuse in any society. We all have a responsibility to be alert to the risks in both Off-Piste Wines Ltd and our supply chain. 

  • Off-Piste Wines Ltd is committed to conducting all aspects of its business in an ethical and transparent manner. We acknowledge our duties and responsibilities under the Modern Slavery Act 2015. 
  • Off-Piste Wines Ltd requires that all workers are treated with dignity and respect. We are fundamentally opposed to slavery, human trafficking, forced labour, debt bondage, the sale or exploitation of children and all exploitative practices in the workplace. 
  • Off-Piste Wines Ltd requires that all contractors and suppliers do not engage in any such practices, and do not knowingly themselves contract with third parties which do. 
  • Off Piste Wines Lts operates within strict values, that will require it terminates business relations with any contractor or supplier found to be in breach of anti-slavery and human trafficking obligations. 

Employees should be free to choose to work for their employer and to leave the company upon reasonable notice.

All employees must be provided with a clear contract of employment, which complies with local legislation.

All employees must be treated in a fair and equal manner and with dignity and respect.

Any form of discrimination, victimisation or harassment on the grounds of marital or civil partnership status, sex (including gender reassignment), race (including colour, ethnic and national origin, nationality), disability, sexual orientation, having or not having dependants, religious belief or political opinion, age, trade union activity and offending background should be prohibited.

All applicable laws and industry standards on employee wages, benefits, working hours and minimum age should be adhered to in all countries of operation, without any unauthorised deductions. Suppliers should observe the provisions of the International Labour Organisation such that any young persons under the age of 18 should not be employed to work at night or for any hazardous work and their employment should not harm the young person’s education, health or physical, mental, moral or social development. No young persons may be employed below the age of 16.

All slavery and human trafficking laws must be complied with including, but not limited to, the UK Modern Slavery Act 2015. Suppliers must ensure their business operations are free from slavery and human trafficking practices whether in the UK or elsewhere, both internally and within their supply chains and other external business relationships. 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.

Due Diligence Process for Slavery and Human Trafficking

Off-Piste Wines Ltd ensure strict compliance checks are carried for all suppliers. We verify the supply chain and their processes before supply commences.

All Off-Piste Wines Ltd employees have channels through which they may voice concerns. Off-Piste Wines Ltd is committed to protecting employees when disclosing malpractice and will ensure that all disclosures made in good faith will be treated confidentially and without fear of retaliation.

Training

All staff within Off-Piste Wines Ltd are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty.

Training provided for all employees covering the following:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • complying with processes at the start of new supplier relationships;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing policy We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

Employee code of conduct Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour. Where these expectations are not met, employees will be subject to disciplinary procedures as outlined in the employee handbook.

Supplier code of conduct We are committed to ensuring that suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.

This policy will be reviewed annually or as and when is required.

Andy Talbot

Managing Director

7th March 2023