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Modern Slavery Statement

This statement has been published in accordance with Section 54 of The Modern Slavery Act 2015 and constitutes the anti-slavery and human trafficking statement for Berlin Packaging Holding UK Ltd and its subsidiaries, Berlin Packaging UK Ltd and The Bottle Jar Store Ltd (collectively, “(“Berlin Packaging UK” or the “Company”) for the fiscal year ending 31 December 2022.

Introduction

 Berlin Packaging UK recognises its responsibility and is committed to taking a robust approach to preventing slavery, child labour, servitude, forced labour and human trafficking (Modern Slavery).

This statement sets out the Company’s actions to understand all potential risks related to our business and to put in place steps that are aimed at ensuring that there is no manner of Modern Slavery in our business, whether directly or within our supply chains.

Modern Slavery is a global issue and a violation of fundamental human rights. No industry is immune to the issue, and we are committed to being alert to the risks and implementing strategies to prevent and manage those risks throughout the supply chain.

Company structure and supply chains

Berlin Packaging UK specialises in supplying a range of glass, metal and plastic containers, closures and machinery for customers in various end markets, along with providing technical and logistical support.

Our products are sourced from a global supply chain and, while business relationships with our supply base are long-term and well-established, we recognise that this introduces a risk of breaches to human rights that are not within the control of the Company and that we must therefore take steps to identify and minimise this risk. The Company also accepts that we cannot do this alone and relies on the transparency and cooperation of suppliers to identify breaches of the Modern Slavery Act 2015 within their own supply bases.

The CEO and Company Directors have overall responsibility for the Company’s anti-slavery initiatives and for ensuring that all those under Company control comply with it.

This statement covers the following activities of the Company:

  • Procurement
  • Logistics, Packaging and Distribution
    • Labour
    • Contracted services
  • Technical and Laboratory Services

 

Relevant Policies and Working Practices

 The Company operates the following policies that describe its approach to the identification of Modern Slavery risks and steps to be taken to prevent Modern Slavery in its operations:

  • Whistleblowing policy – The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or supply chains, of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures without fear of retaliation and provides the opportunity to report anonymously.
  • Employee Code of Conduct – The Company’s Code of Conduct clarifies to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating both domestically and abroad to manage its supply
  • Supplier/Procurement – The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, 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 required standards and improve their own and their supply chains’ working conditions. Any violations recognised within our supply chain through our whistleblowing policy or supplier audits and assessments shall be acted upon immediately with improvement measures and follow-up activities. Berlin Packaging UK may also terminate its business relationship with the supplier if it determines that a supplier or any of its subcontractors has violated the Company’s Supplier Code of Conduct or if the supplier has continued violations without improvement.
  • General Recruitment – We ensure that all our staff are legally able to work in the UK and provide information to all new recruits on their statutory rights, including sick pay, holiday pay and any other benefits they may be entitled to.
  • Agency workers policy – The Company uses only specified, reputable employment agencies to source labour.

Risk Management

Berlin Packaging UK sources from a global supply base with varying degrees of risk associated with the differing countries.  Where we consider the countries to be of a higher risk, we manage risk appropriately to approve suppliers on a case-by-case basis, after conducting due diligence specified below.

With membership to Ecovadis and Supplier Ethical Data Exchange (Sedex), the Company is developing its links to, and transparency with, both suppliers and customers to gain an understanding of where the highest risks to human rights exist within its tier 1 and tier 2 suppliers. The Company maintains close business relations with its suppliers which includes regular visits to review performance and development activities. Through a detailed supplier questionnaire, the Company identifies all suppliers who are also Sedex members.

Due diligence

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers.

The Company’s due diligence and reviews include:

  • conducting supplier audits or assessments;
  • conducting regular risk profiles for each supplier;
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our Supplier Code of Conduct, including the termination of the business relationship;
  • ensuring that all employees are made aware of this policy and their obligation to comply with this policy;
  • ensuring that staff involved in supplier audits, procurement, recruitment and deployment of workers are aware of the risks of modern slavery and ethical business practices; and
  • understanding that the risks of Modern Slavery are growing, and we will continue to monitor our approach to mitigating this risk in the year ahead.

This statement has been approved by the CEO and Company Directors, who will review and update it annually.