Modern Slavery Policy

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015.

About Us & Our Commitment

We are Ian Macleod Distillers, a successful and respected Scottish, family-owned spirits company, rooted in traditional values of independence, quality and customer service. We are brand led with a strong focus as an international and entrepreneurial family company. While we are based in the UK, where over 95% of our workforce is located, Ian Macleod Distillers also have legal presence in Taiwan and in India and are currently expanding our operations on the latter.

 

As a business, we are dedicated to playing our part in the eradication of modern slavery and human trafficking and ensuring compliance with the UK Modern Slavery Act.

Ian MacLeod's distilling operations are supported by key business areas of private labelling and bulk trading. Our business activities are delivered by a variety of departments, including Operations; Finance & Central Services; HR; and Sales & Brand.

This Statement applies to all our sites:

• Ian MacLeod Distillers -Head Office -Russell House Broxburn - Company No SC032696
• Glengoyne Distillery & Visitor Centre, Glasgow
• Edinburgh Gin Distilleries & Visitor Centre, Edinburgh
• Tamdhu Distillery, Aberlour
• Rosebank Distillery & Visitor Centre, Falkirk

Our aim is to offer our customers a choice of top-quality spirit brands. By continually investing heavily in our exquisite portfolio to build a range of strong, niche brands, we are creating long term value. International market demand for premium spirits is at an all-time high and in a marketplace increasingly dominated by a few multi-national companies with global brands, as an entrepreneurial and family business, we are thriving through customer demand for our products with heritage, history and quality.

Aligned to our own overarching cultural ethos, we are fully supportive of the aims of the UK Modern Slavery Act 2015 and as such remain wholly committed to tackling modern slavery and human trafficking wherever possible. We continue to expect the same high standards from all of our partners, distributors and suppliers and expect that these standards are in turn applied throughout their own supply chains. We do at times work with third parties, suppliers, distributors and other customer bases across national and international markets. We therefore recognise potential modern slavery risk and proactively engage with business partners who reflect our own values, culture and approach in all of these regards. We promote corporate social responsibility in all aspects.

 

Our policies

Our policies set out our commitments to acting fairly and ethically, preserving the trust and confidence of our customers, partners, and anyone else in contact with Ian MacLeod’s operations and business activity.

We communicate to all our employees our standards on our zero tolerance to modern slavery and our actions to tackle it through our Employee Handbook, which is shared with all employees and available at any time. We aim to develop formal policies for communicating these standards to our suppliers in the near future.

All policies are approved at Board level.

 

Our due diligence processes

At Ian MacLeod, we aim to work with trusting and responsible businesses. The long-standing nature of our business relationships with our suppliers, some almost as old as Ian MacLeod itself, means that we are working to become a more sustainable and ethical business alongside our suppliers, using our leverage for upholding ethical standards and preventing modern slavery.

As part of our due diligence processes, we use Sedex’s world leading ethical data online platform which enables us to connect and share information with both our suppliers and customers, providing us with increased visibility of our supply chain and helping us identify and manage any modern slavery risks in our operations and supply chain. We upgraded our Sedex membership in 2020 to an A/B (Buyer/Supplier membership) in order to more effectively manage our supply chain risk and mitigate risk.

Risk assessment

We source mainly from the UK, which is considered a low-risk country for modern slavery, according to RADAR, Sedex’s risk assessment tool. Outside the UK, we mostly work with suppliers on sourcing packaging materials. Some of these suppliers are based in Portugal, which is considered low risk for modern slavery, and China, which is a higher risk sourcing location.

For new suppliers, Ian MacLeod uses a pre-screening questionnaire to understand what ethical practices are in place by prospective core suppliers.

For current suppliers, over the last financial year, we continued to ask suppliers to complete the self-assessment questionnaire on Sedex, which can help us understand modern slavery risk and prioritise areas for improvement.

Auditing and visits

In 2021, we continued to encourage our suppliers to join Sedex, complete the selfassessment questionnaire and have a SMETA audit or equivalent ethical audit. We ensured that any issues flagged by ethical audits were addressed and proportionally remediated. If modern slavery suspicions were found in our supply chain, Ian MacLeod would investigate the incident and escalate it to the appropriate channels.

The sharing and analysis of the ethical supply chain data helps us understand the risk and impact of our business, and work towards continuous improvement and building a more sustainable and resilient supply chain, with the highest confidence in our ethical standards. By doing so, we contribute to safeguarding human rights of the people and communities involved or impacted by our business, promote safe working conditions across own and supplier production sites, and uphold our business ethics.

In addition to ethical audits, Ian Macleod aims to visit all supplier sites every year. While COVID-19 made this process more difficult, we are pleased to report that we have been able to visit all UK based suppliers in the last financial year.

Grievance mechanism

There is a grievance procedure for employees to raise any problems or issues, including modern slavery suspicions. We have a trusting and open culture with our employees,and encourage everyone to feel comfortable raising any queries or concerns at any time, whether informally with colleagues or through formal escalation mechanisms or procedures. Our grievance procedure can be accessed in our Employee Handbook. We aim to extend our grievance procedures to our business partners and suppliers.

 

Training

We offer an information and awareness raising pack to all employees on Modern Slavery & Human Trafficking compiled by Stronger Together. Our annual modern slavery statements are made known and available to all new employees and remains easily accessible to all existing staff members via our employee self-service system. Additionally, all employees are provided with an online modern slavery training via our e-learning system.

We are currently working to develop and roll-out a more comprehensive modern slavery training programme in the upcoming months. This additional training will focus on specific job roles and activities, working across our operations and supply chain, and be led and managed by the relevant departments.

 

Present and Future Commitments

Our continuing aim is to ensure a zero-tolerance approach to modern slavery and human trafficking, and to act in ethical, fair and just manner, in all our business relationships.

We continue to:

• Encourage all of our customers and suppliers to have their own suitable anti-slavery and trafficking policies and processes;
• Enhance our internal policies on modern slavery for employees and develop formal policies for communicating modern slavery standards to our business partners and suppliers;
• Cascade information to our employees to help them understand the importance of, and our zero tolerance towards, any type of modern slavery, especially through comprehensive training on the topic;
• Encourage employees to report potential concerns through our grievance mechanism and extend our grievance mechanisms to our supply chain;
• Report on our commitments in tackling modern slavery and human trafficking as part of Board discussions and in line with annual business reporting and priorities;
• Assess risk and where applicable table recommendations, actions and follow up as required, prioritising the areas of our business that require the most attention;
• Empower our business areas to readily complete appropriate due diligence requirements regarding engagement with new customers and maintaining business relationships with existing customers, in line with these principles.

We remain wholly committed as a business to proactively prevent and tackle modern slavery, and have a zero-tolerance approach in dealing with, any business or individuals knowingly involved in modern slavery or human trafficking.

The present modern slavery statement has been approved by Ian MacLeod Distillers’ Board and signed by its Managing Director.

 

Leonard Russell

Managing Director, Ian Macleod Distillers

25th November 2022