RWS Modern Slavery Statement 2017/18
RWS Holdings plc and its subsidiaries (the “Group”*) are committed to understanding modern slavery risks and ensuring that its businesses and supply chain are free from modern slavery and human trafficking. This statement (made pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”)) sets out the steps that the Group has taken during the financial year ended 30 September 2018 and will continue to take to meet this commitment. We intend to review this statement annually.
Business and organizational structure
The Group is the world leader in translation and localization, intellectual property support solutions and life sciences language services, focusing on key market segments where the quality of its services is of critical importance to its clients. The Group has a blue-chip multinational client base spanning Europe, North America and Asia that is particularly active in the technology, pharmaceutical, medical, chemical, automotive and telecommunications sectors. It employs almost 2,500 permanent staff and is headquartered in the UK with offices in Europe, the United States, Canada, China, Japan, Australia and Argentina. RWS Holdings plc, the parent company, is listed on the Alternative Investment Market (AIM), part of the London Stock Exchange.
Policies and supply chain
RWS adopts a zero-tolerance approach to Modern Slavery within the Group and its supply chain. The Group already has a robust control environment in place, holds ISO 9001 certification and has a number of policies and procedures designed to ensure that its activities, and those of its suppliers, are conducted ethically and in accordance with all applicable laws. These include policies and procedures relating to bribery and corruption, money laundering, share dealing, procurement and whistleblowing. The Group intends to enhance and strengthen these policies and procedures and implement and enforce effective systems and controls across its businesses to ensure compliance, with the aim of ensuring that those businesses and their supply chains are free from modern slavery and human trafficking.
The Group’s key suppliers are firms providing professional services to support the Group’s client-facing activities as well as a range of suppliers providing other services to support the operation of the Group. The Group and its suppliers do not engage in activities relating to manufacturing or natural resources. We therefore believe that the Group’s supply chain poses a lower risk of slavery and human trafficking than that of companies operating in other sectors; however, some risk does exist, and the Group is committed to assessing and mitigating that risk.
The Group has reviewed its supply chain to identify areas that may pose a higher risk of modern slavery and human trafficking and has reviewed existing controls to mitigate these risks. The Group is committed to monitoring the control environment to ensure that appropriate oversight of the Group’s supply chain is maintained.
The Group’s commitment to compliance with the Act applies equally to its own staff. Through its selection, recruitment, induction and training procedures and programmes, the Group aims to ensure that the people it employs are not subject to modern slavery and human trafficking and are afforded the rights and protections that they are entitled to by law.
The Group encourages staff to report concerns they may have about the Group’s compliance with applicable laws and/or breaches of its own ethical standards, without fear of retaliation.
This Statement is made available on the company website www.rws.com.
The Group intends to identify meaningful indicators and assurance activity with which to monitor compliance with the requirements of the Act. These will be reported to the Board of Directors which is responsible for overseeing compliance with all the Group’s policies and procedures.
This statement has been approved for release by the Board of Directors.
Group CFO, RWS
13 February 2019
*Within the Group, only one UK subsidiary of RWS Holdings plc, RWS Translations Ltd, is required to produce a statement.