This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps the Company has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.

Our procedures

We have a number of procedures in place that contribute to ensuring modern slavery does not occur in our business or supply chains.

Transparency in our supply chains:

We recognise our firm is exposed to greater risk when dealing with its suppliers, particularly those who have operations in other territories.  The following measures to review and manage this risk are in place:

  • a commitment to collaborate closely with suppliers to help them understand and work towards their own obligations under the Modern Slavery Act.
  • a Responsible Purchasing Policy, which reflects our commitment to and focus on suppliers' ethical supply chain(s).
  • a Supplier Code of Conduct, which is used for all new major suppliers of goods or in re-tendering, clearly stating the firm's intention to step away (without penalty) if any occurrences of modern slavery are discovered.

Both the Responsible Purchasing Policy and Supplier Code of Conduct will be reviewed annually, and updated as and when deemed appropriate by the Ethics Team, to ensure they are continually developed and remain fit for purpose.


  • Robust recruitment processes in line with UK employment laws, including: 'right to work' document checks; contracts of employment and checks to ensure everyone employed is 16 and above.  
  • Market-related pay and reward, which is reviewed annually and linked to professional services firms' benchmarks.

Employee training:

We want to help our people to understand more about this growing issue and how to report any suspicions they may have, whether in a business or personal context.  We have highlighted the site to all our employees, which holds useful information on how to recognise different types of slavery, how to spot the signs and provides details of a telephone helpline.

We have developed resources and made them available to our people, including summary documents with an overview of the Modern Slavery Act, and links to the site.

Looking forward key performance indicators

Going forward, we aim to work towards:

  • developing an employee training module that will be undertaken by all Hamilton Wine Company employees. This training will outline what modern slavery is, how to identify it and what individuals should do if they suspect there are any cases of slavery occurring. Completion of this training will form a compulsory part of our employees’ annual review and new starter induction processes.
  • developing a procedure to monitor how our suppliers comply with our supplier Code of Conduct.