1 About this Statement
This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes the r2p Group’s slavery and human trafficking statement for the financial year ended 31 March 2020.
We understand that slavery, servitude, forced labour and human trafficking (Modern Slavery) is a global and growing issue given the rapid rise in global migration, existing in every region in the world and in every type of economy, whether industrialised, developing or in transition. No sector or industry can be considered immune or untainted.
r2p has a zero-tolerance approach to Modern Slavery of any kind within our operations and supply chain. We all have a responsibility to be alert to any risks, however small, in our business and in the wider supply chain. All our staff and contractors are expected to report concerns and management is committed to act upon these concerns.
This statement is available to the public on www.r2p.com. New team members will be given a copy of this statement at their induction and their consent will be documented. Managers and supervisors will remind team members of this statement at team briefings.
2 Organisation Structure and supply chains
The r2p Group was founded in 2009 and has its headquarters in Flensburg, Germany. We operate internationally in 45 countries, with subsidiaries and sale offices in Denmark, UK, Switzerland, the Czech Republic, Brazil, Australia and Malaysia. As a market leader, we distribute software and hardware for rail and road vehicles, mobile video protection and telemetric solutions. Our in-house production depth reaches only the use of intermediate goods such as components but never the use of any raw materials.
We cooperate with a good handful of long-standing suppliers that provide around 65% of our purchase value. These main suppliers are located in Taiwan, Germany, Denmark and Norway. A broader range of varying suppliers provide components and consumable material of lesser value.
3 Policies in relation to slavery and human trafficking
3.1 Code of Conduct
We are committed to our Code of Conduct (CoC) which applies to all employees of the r2p Group. The CoC affirms in its section 2, paragraph Human Rights and Modern Slavery Ban, that the r2p Group is vehemently opposed to the use of slavery in all forms (ILO Conventions 29 and 105), cruel, inhuman or degrading punishments and any attempt to control or reduce freedom of thought, conscience and religion. It also states that we will ensure that all of our employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998. Furthermore, it clearly disclaims any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities.
3.2 Grievance mechanism
For any concerns regarding possible breaches of Human Rights including Modern Slavery, the CoC encourages our employees as well as third parties to contact our ombudsman. Up to now, we received no reports suggesting such cases. Any upcoming reports will be fully investigated, and appropriate remedial actions taken. Any concern or suspicion will be kept confidential until investigations are completed. Any concern must be made in good faith. That is, it should not be made in a malicious or reckless manner or where it is known that the complaint is false or misleading.
4 Due Diligence and Risk Assessment
We have analysed potential risks in our business operations according to literature provided by the UN Global Compact’s German section [DGCN 2019]. These can be divided by geography and branch.
4.1 Geographic risks
Due to our activity in Australia and Malaysia, we must be aware of the fact that there is a relatively high prevalence of Modern Slavery in the Asian-Pacific region (6.1 per 1000 workers) [ILO 2017, p. 10]. On the upside, our branch requires rather highly qualified staff that is less likely to fall victim to Modern Slavery than unskilled workers in farming or other seasonal jobs [DGCN 2019, p. 8].
4.2 Branch-specific risks
Today’s electronic technology relies heavily on minerals whose global occurrences are concentrated in few, politically instable and poor regions of the world, where the risk for Modern Slavery is significantly higher . This is also true for the technologies used at the r2p Group: tantalum capacitors are a standard component for on-board PCs, for example. Our business is therefore dependent on these minerals. Their exploitation can be linked to armed conflicts, the violation of human rights and environmental damages – if we do not take measures against it.
4.3 Actions taken in response to those risks
For these measures to work, we depend on our suppliers’ support and commitment, as our in-house production depth reaches only the use of intermediate goods such as components but never the use of any raw materials, where the highest risks occur.
During our start-up time, we expressly encouraged our suppliers to monitor and certify their own supply chains and honoured this effort in our sourcing decisions. One of our main suppliers affirms that they trace the origin of relevant minerals in their supply chain, whereby conflict regions are excluded as possible sources. We strive to obtain this commitment from all our main suppliers.
Now, our organic growth and acquisitions of the last few years both allow and require a more stringent approach towards these issues, which we are preparing at the time being. From 2021 onwards, we will regularly audit our main suppliers to support their ongoing development of Environmental, Social and Governance (ESG) procedures including the ban of Modern Slavery.
Regarding the supply of consumable goods, we have next to zero market power. We take small steps here, e.g. we purchase solely fair-trade coffee at our headquarters in Flensburg.
5 Key performance indicators to measure effectiveness of steps being taken
KPIs should include the number of audits conducted at suppliers, per year and accumulated. If any concerns should come up, an indicator for the progress of investigation could be designed. Indicators will be established during the audit phase starting in 2021.
6 Training on the ban of Modern Slavery
Every team member throughout the r2p Group is required to read and understand the CoC which includes Human Rights and the ban of Modern Slavery, confirming this by their signature of their employment contract. We also expect our suppliers and partners to concern themselves with the values and guidelines provided in the CoC, making sure that they act accordingly throughout their entire business conduct with us.
New team members will be given a copy of this statement at their induction and their consent will be documented. Managers and supervisors will remind team members of this statement at team briefings. A dedicated training programme is not yet in place but could be needed for Purchasing and Quality Management.
This statement has been formally approved and signed by the Directors of r2p.
CORE 2016: Beyond Compliance: Effective Reporting Under the Modern Slavery Act. A civil society guide for commercial organisations on the transparency in supply chains clause. Downloaded from corporate-responsibility.org/wp-content/uploads/2016/03/CSO_TISC_guidance_final_digitalversion_16.03.16.pdf on October 17th, 2019.
DGCN 2019: Moderne Sklaverei – Risiken verstehen, Anforderungen kennen. Webinar held on September 18th, 2019, by Laura Curtze (DGCN) and Carolin Seeger (twentyfifty).
ILO 2017: Global estimates of modern slavery: Forced labour and forced marriage. Downloaded from www.ilo.org/wcmsp5/groups/public/---dgreports/---dcomm/documents/publication/wcms_575479.pdf on October 29th, 2019.
Verité 2014: Forced Labor in the Production of Electronic Goods in Malaysia. A Comprehensive Study of Scope and Characteristics. Downloaded from www.verite.org/wp-content/uploads/2016/11/VeriteForcedLaborMalaysianElectronics2014.pdf on October 17th, 2019.