MODERN SLAVERY STATEMENT

Introduction

Walstead Group Limited (“Walstead”) is a socially responsible business headquartered in the UK. Walstead published its initial Modern Slavery Statement in 2017 as required under the Modern Slavery Act of 2015. This document provided a brief overview of Walstead’s business in the UK and the steps we took to manage the risks associated with modern slavery in the supply chain. The 2020 statement will show what we have learned and expand upon Walstead’s aims for enabling continued transparency and vigilance in our employment and procurement practices.

As the largest independent commercial web-offset printing group in Europe, we recognise that modern slavery, forced labour and child labour are real issues of global concern. We understand the affect this has on individuals and communities and are aware that being a European organisation does not insulate us from the effects of unethical practice directly on our shop floors, or indirectly through third parties in our supply chain.

Our Business and Supply Chains

Walstead has grown by winning new business and by corporate acquisitions enabling the provision of a wide range of print and content services for our customers. In the UK we operate as Walstead United Kingdom with seven sites including four print works, a bindery, and two offices. Walstead also owns and operates Walstead Iberia, consisting of two print sites in Spain; Walstead Leykam, consisting of five print sites in Austria, Czech Republic and Slovenia; and Walstead Central Europe, consisting of three print sites in Poland. Rhapsody, the creative media production agency has three operations in the UK, Spain and Poland.

The size of Walstead’s offering enables us to serve a wide customer base including globally recognised blue- chip corporations, high street brands and local businesses. We work in partnership with our clients to ensure our supply chain vendors meet the high standards of social responsibility demanded by us as a business and by the end users of our products.

Our supply chain is complex and may consist of different tiers between our direct suppliers and the producers of raw materials. We source our requirements from highly regarded global suppliers who enable us to rely on the integrity of their supply chain, particularly in relation to suppliers of paper, inks and other constituent materials required for the manufacture of printed products.

Our Controls and Procedures

we continue to conduct training with relevant internal stakeholders and completed an internal audit of our UK subsidiaries and their suppliers. We discovered that the areas of high risk are not large corporate suppliers, but more local and less publicly transparent service providers. We identified that seasonal peaks and troughs in product demand means that our business uses contingent labour, which is a widely accepted area of risk prone to potential abuse.

In addition to areas of risk exposed within our business through internal audit, we continue to issue modern slavery compliance questionnaires to our suppliers, asking a range of questions including whether or not they are aware of the practice of modern slavery, do they have any company standards, policies or other statements relating to human slavery and trafficking, do they audit their own supply chain in relation to these issues, and have or do they intend to provide training for their workforce.

Thus far we have received a positive response from the majority of our suppliers and were able to identify, through lack of response, the areas of highest risk. This enabled us to focus on improving awareness within our business, providing in-house training to teams that are more likely to be affected by the issue. Additionally, we have issued a poster campaign in different languages to raise awareness on the shop floor, providing a safe avenue for whistle blowing should any of our contingent workers be the victims of such practices or know of anyone affected.

Future

We are continually trying to improve our modern slavery processes and we are working towards including a modern slavery awareness module, which includes a training pack and video awareness, on our in-house training portal. We also intend to include modern slavery awareness in our business inductions & refreshers which all employees must undertake. Modern slavery awareness is now included in our tender processes & our modern slavery questionnaire will be issued when tendering supplies & services. Our modern slavery questionnaire will also be issued to all new suppliers at point of implementing trading accounts. Walstead has continued to grow as a business and since the introduction of the Modern Slavery Act 2015, we have not only become more aware of the issues and areas of risk for our business but, more importantly, our responsibilities in relation to victims, the community and all our stakeholders. Our aim is to introduce a European wide standard within Walstead Group that can enable the local sites and their suppliers to identify any occurrence of practices that are deemed unlawful under the Act and to act accordingly, always considering the victim’s welfare first.

We will continue to perform due diligence exercises when on boarding new suppliers and work to place similar contractual obligations in our contracts throughout Europe.

What is clear is that the purpose of the Act is to introduce a culture of transparency that can enable socially responsible businesses such as ours and those of our suppliers to continue to develop awareness, raise standards and deliver an excellent service from a position of ethical best practice, thus ensuring a viable and satisfactory experience for all stakeholders.

This statement was approved by the board of Walstead Group Limited and signed by

Matthew Carter, Group Procurement Director