Modern Slavery Statement

Introduction

Tuffnells is a leading next-day distributor of mixed and irregular freight, serving small and medium sized enterprises across the UK. Our niche is in the collection and delivery of items of irregular dimension and weight (IDW), examples of which include bulky furnishings, packaging and automotive parts. With a mix of local and national customers, Tuffnells offers a range of timed services, responsive to customer demand, via our network of 33 UK-based depots.

Our Anti-Slavery Position

Tuffnells is fully committed to preventing acts of modern slavery and human trafficking from occurring within our business, and we expect the same standards on our suppliers and delivery partners as we apply to ourselves. We take a zero-tolerance approach to non-ethical practices and we are committed to acting professionally, fairly and with integrity in all our business dealings and relationships, wherever we operate, implementing and enforcing effective systems to uphold ethical standards and to combat modern slavery and human trafficking.

“Modern Slavery” for us means the exploitation of people who have been forced, deceived, or coerced into a life of labour and servitude, including human trafficking. Management, team members and partners are alert to the risks of modern day slavery and we have a reporting line to bring any concerns to the attention of management who will act on all reports.
We expect anyone who has any suspicions of modern slavery in our business or our supply chain to raise their concerns without delay.

Our Operating Model

We operate from an extensive UK-based network of 33 depots, collecting and delivering to a predominantly business-to-business customer-base. The vast majority of our collections and deliveries are completed before 12pm, with an overnight operation servicing our trunking and sort operation, requiring a dedicated work team of both full-time and contract shift workers.

Our supply chains are mainly made up of the following:

  • The provision of staffing and agency workers, workwear and consumables;
  • A range of third-party suppliers providing digital services and solutions, both for internal and external use;
  • Contracted maintenance services, including the provision of cleaning, general building maintenance and vehicle supply and upkeep.

Our Modern 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 and risk assessment

To help identify and monitor the risk of slavery and human trafficking in our supply chain we are reviewing our processes, which includes the vetting of suppliers and sub-contractors in order to ensure their adherence to anti-slavery and human trafficking practices.

Effectiveness in combating slavery and human trafficking

We are committed to the introduction in 2021 of key performance indicators (KPIs) in order to measure the risk of such practices and our effectiveness in combatting them. This will be supported by our current programme to attain ISO 9001, 14001 and 45001 quality certifications, and includes the following:

  • The percentage of suppliers and sub-contractors vetted for ethical labour practices;
  • The number of inspections of direct suppliers and sub-contractors in our supply chains in the past year;
  • The number of reported breaches in the past year;
  • Percentage of staff receiving training on identifying and addressing the risk of slavery and human trafficking in our business and supply chains.

We will carefully monitor the sources of our workforce, and our employment policies support the individuals’ right to offer their services in exchange for a fair wage. We have strict policies and processes to regulate how we deal with both recruitment agencies for the supply of resource and service providers who undertake partnered collection and delivery services on behalf of Tuffnells, with the focus on an individual’s right to work in the relevant jurisdiction and ensure fair and transparent payment practices. We adhere to the minimum wage provisions and additional provisions applicable to night workers in respect of maximum weekly working hours and rest breaks.

Policies

As part of our commitment to combating modern slavery, we are implementing the policies listed below. We are also initiating a Policy Committee which consists of key functional teams to help monitor industry and legal developments, share best practice and explore methods of communication and training. This Policy Committee ensures that our policies are regularly reviewed and updated where necessary. We have a process of communicating our policies (new and revised) to ensure all of our work-force are properly informed.

  • Dignity at Work Policy;
  • Anti-Corruption Policy;
  • Whistleblowing Policy.

These policies have been developed and adopted by Tuffnells in order to ensure that we conduct all business in an honest and ethical manner.

Our Governance

We recognise that Modern Slavery is not something that only happens elsewhere and note that the UK Government estimates there are tens of thousands of people in slavery in Britain today, with UK nationals making up the biggest group of potential victims.

Training

The Company is committed to training relevant team members in how to identify Modern Slavery in practice and how to respond. We’re committed to having a clear and transparent Company statement which is reviewed regularly and is communicated to team members.

Working with our delivery partners

We strongly believe that we should work with suppliers and delivery partners in a collaborative manner and that it will not benefit marginalised and “at risk” people if we simply terminate partnerships where concerns are identified. We believe in constructive engagement through education and training programmes, coupled with capacity building, both internally and within our partnerships to identify and address any problem. While we recognise the reputational dangers of non-compliance within such partnerships, we believe that it is more beneficial to work for change and improvement rather than removing a partner and leaving the abuse unresolved.

Further steps

We intend to take further steps as outlined below:

  • Awareness training for all team members;
  • Specific training for managerial roles;
  • The introduction of key performance indicators (KPIs).

Concluding Remarks

This statement has been approved by the Executive Chairman & CEO and is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes Tuffnells’ modern slavery and human trafficking statement for the 2020 financial year (1 Jan. 2020 – 31 Dec. 2020).

March 2021