Modern Slavery Statement 2022
Introduction
Section 54 of the Modern Slavery act 2015 sets out our legal requirement to publish an Annual Modern Slavery Statement. This statement sets out the steps we are taking to tackle modern slavery in our business or supply chain.
Our Business
We are a UK registered Wine Shipper & Distributor, importing Champagne, Wine (including Fortified Wine) and Spirits and then distributing to the UK Drinks Trade. We sell only in the UK and have 42 employees, all based in the UK. Our Head Office is The Woolyard, 52 Bermondsey Street, London SE1 3UD. We are owned by the Société Jacques Bollinger (France) (80%) and Wine Investments Holdings Ltd (Malta) (20%). We operate at the premium end of the UK Drinks Trade with very little selling for less than £10/bottle (retail).
Our Supply Chain
We ship products from all around the world (see Our Brands- below) using two specialist, well-established drinks logistics partners both based in the UK – JF Hillebrand and Kukla. We utilise Great Bear, a specialist UK Bonded warehouse keeper for storage and onwards distribution of our products to our customers all based in the UK. Great Bear are part of Culina Logistics Ltd. We have satisfied ourselves in relation to their own Modern Slavery Statements as this legislation will be relevant to them.
Our Brands (Suppliers)
We have 22 Wine, Fortified Wine, and Champagne suppliers worldwide.
Of these, 5 are owned by our majority shareholder in France, and all are well-established, premium suppliers in their category (Bollinger Champagne, Ayala Champagne, Chanson Pere & Fils (Burgundy), Langlois-Chateau (Loire) and Delamain (Cognac).
Our minority Shareholder owns the 3 Port Brands that we represent and are based in Porto, Portugal. Additionally, in Portugal, we represent FEA (Fundacao Eugenio de Almeida) in Evora, Alentejo.
We have 3 additional suppliers in France – Jean-Luc Colombo (Rhône), Chateau La Fleur de Brouard (Bordeaux) and Aix (Provence).
We have 2 suppliers from Spain – Bodegas Roda (Rioja) and Bodegas Hidalgo la Gitana (Sanlucar de Barrameda).
We have 3 Italian Suppliers – Tenuta Fertuna, Ciacci Piccolomino, and Ceretto.
We have two suppliers in South Africa, Klein Constantia and Hamilton Russell.
We have 3 suppliers from Australia, Tapanappa, Kilikanoon and Turkey Flat.
We have 2 suppliers from New Zealand, The Crossings and Akitu.
Additional, we now represent Hambledon Vineyards, an English Sparkling Wine producer based in Hampshire, England.
All of our suppliers are independently owned family-run businesses passionate about their brands and the values they represent.
Our Policies
We have the following internal policies to help mitigate the risk of modern slavery throughout our business and supply chain.
Employees
As part of our recruitment process, we ensure that all prospective employees are entitled to work in the UK. As part of their induction process, they would be briefed about the existence of the Modern Slavery Act, dependent on their role in the organisation. In addition, all employees would obtain a copy of this statement.
The Company Handbook covers the company’s Whistleblowing policy; hence employees are aware that they can raise any concerns they may have about any relevant matters under this legislation should they feel the need to. The Company Handbook also gives guidance on all HR matters in accordance with best practices and current legislation.
We occasionally recruit temporary staff but only from reputable Agencies for short periods. On those occasions, we would rely on the integrity of the recruitment agency to ensure adequate procedures are in place within their organisation.
Logistics Providers
As mentioned above, we use third-party shippers, warehouse keepers and distribution providers. These are all reputable companies that have operated in the UK for a number of years. We are aware that they do recruit temporary workers at peak times during the year (additional warehouse staff), mainly September to December.
However, for good measure, we regularly inquire about their policies in this area and obtain a copy of their most recent Modern Slavery Statement when they satisfy the requirement to do so.
Kukla – are not in themselves big enough to have to legally file a Statement, but comply with the legislation and perform the following due diligence on all of their operators around the world
In addition to Transport Legislation, Operating partners’ must comply with local, national and international regulations in respect of employee welfare, the Modern Slavery Act 2015, the National Living Wage, fiscal registration and licensing directives.
Great Bear – we have a copy of their latest statement
JF Hillebrand – we have a copy of their latest statement
Our Suppliers (Brand owners)
A list of the Brands we represent in the UK Market is shown above. Whilst we do seek to expand our supplier base, it is stable. This is by design, and we have a comprehensive Due Diligence process (conducted by the most senior individuals within our organisation) with any prospective new suppliers.
We only work with well-established family-owned businesses producing premium wines. We assess the core Management Team as part of that due diligence process.
An identified risk would be the casual labour recruited around harvest time each year. To mitigate that risk, we seek assurances as to these temporary workers directly from the Brand owners as part of our initial due diligence processes and ongoing by asking them to complete an annual declaration.
Approval
This statement was approved by the Board on 30th March 2022.