Modern slavery statement
Modern slavery and human trafficking have no place in our business or our supply chain. Drinks21 Ltd is committed to acting ethically and with integrity in all our commercial relationships, and to implementing systems and controls that guard against exploitation anywhere in the chain that brings our products to market.
Drinks21 falls below the £36 million turnover threshold at which section 54 of the Modern Slavery Act 2015 makes a statement mandatory. We publish this statement voluntarily, because our customers and the brand owners we represent are entitled to know where we stand, and because the right time to build these controls is before you are required to.
Our business
Drinks21 Ltd is a UK-based international drinks distributor. We have traded since 2008 and were incorporated in 2010. We import, export and distribute beer, cider, wine and spirits to duty-free, travel retail, export and on-trade customers across the United Kingdom, Ireland, the Netherlands, wider Europe, the Middle East, Africa and Asia.
We are headquartered in Ascot, Berkshire, and employ a small team. We hold stock in HMRC-approved bonded warehouses in the United Kingdom and the Netherlands, operated by third-party logistics providers. Drinks21 Ltd is part of the Drinks21 Group, alongside General Wine & Liquor and GloBev Duty Free.
Our supply chain
We do not manufacture. We buy finished, packaged product predominantly from:
- Brand owners and their official distributors, including major international drinks groups with their own published modern slavery statements and supplier codes of conduct
- Established wholesale suppliers with whom we have long-standing trading relationships
Our onward supply chain consists of third-party bonded warehouse operators, freight forwarders, shipping lines and hauliers.
The principal modern slavery risks in the drinks sector sit upstream of where we operate, in agricultural production, particularly seasonal and migrant labour in viticulture and sugar cultivation, and in packaging and glass manufacture. We are some distance from those activities. That does not remove our responsibility to ask the right questions of those we buy from.
What we do
We buy from source
Approximately two-thirds of our purchases by value are made directly from brand owners, with the balance largely from their official distributors. That means the great majority of our supply chain is already covered by the published policies and audit programmes of large, publicly accountable drinks groups.
We apply our due diligence process to every trading partner
Our standard onboarding checks, covering identity verification, company and directorship confirmation, and financial standing, apply to suppliers as well as customers. Where a supplier is not a brand owner or a household-name wholesaler, we look more closely at who they are and how they operate. Our full approach is set out in our due diligence policy.
We flow down our expectations contractually
Our terms and conditions of sale require every trade customer to warrant that neither it nor, to the best of its knowledge, anyone in its supply chain has engaged or will engage in modern slavery or human trafficking, and to notify us promptly of any suspected breach.
We comply with the codes imposed on us
Several of the brand owners we represent require their distributors to adhere to a supplier code of conduct covering labour standards, human rights and working conditions. We accept and operate under those codes.
We do not accept cash
For any goods, from any counterparty, in any amount. Cash transactions are a recognised enabler of labour exploitation and financial crime.
Our expectations of suppliers and customers
We expect every business we trade with to:
- Comply with the Modern Slavery Act 2015 and equivalent legislation in their jurisdiction
- Ensure all workers in their operations are employed lawfully, of legal working age, and free to leave
- Pay at least the legal minimum wage in their jurisdiction and not withhold wages, documents or identity papers
- Not use forced, bonded, indentured or involuntary prison labour
- Not charge workers recruitment fees
- Extend equivalent expectations to their own suppliers
- Tell us promptly if they become aware of an issue in their own chain
Where we identify a concern, our first response is to engage and seek remediation. Where a partner is unwilling to engage, or the concern is serious, we will suspend or terminate the relationship.
Training and responsibility
Responsibility for this statement sits with the directors of Drinks21 Ltd. Staff with purchasing, account management or customer-facing responsibilities receive training on our due diligence procedures on joining and annually thereafter, covering recognition of red flags, document verification and reporting obligations.
Reporting a concern
If you have a concern about modern slavery or human trafficking connected to Drinks21 or our supply chain, email sales@drinks21.com marked for the attention of the directors, or call +44 (0) 1344 294 170. Concerns can also be reported confidentially to the Modern Slavery Helpline on 08000 121 700.
Review and approval
This statement is reviewed and republished annually, and is approved by the board of Drinks21 Ltd.
Approved by: Stephen Brogan, Director
Drinks21 Ltd, 9 Queen's Square, Ascot Business Park, Ascot, SL5 9FE, United Kingdom