The below policy sets out how Sheard Properties along with S. Sheard & Son Ltd intends to comply with the Modern Slavery Act 2015.

OUR BUSINESS

S. Sheard & Son Ltd operates three business units, Sheard Packaging, Sheard Security and Heath Recycling, incorporated into Sheard Properties.

1. Sheard Packaging purchases flat sheet corrugated board from UK Suppliers and converts it into plain or printed corrugated packaging.
2. Sheard Security is involved in the destruction of confidential items and data.
3. Heath Recycling collects waste materials for processing and subsequent recycling.
4. The organisations financial year runs from 1st May to 30th April. This statement covers the period May 18 to April 19.

OUR POLICIES

1. Ethical Policy. The policy states that the organisation is committed to protecting all employees, customers, contractors and the company from illegal or damaging actions by individuals either knowingly or unknowingly. Employment is freely chosen and no forced, bonded or involuntary labour shall be used.
2. Policy Statement (Sheard Security). Ensures all personnel working in the confidential unit undergo screening procedures in accordance with BS7858:2006. We also operate a robust induction procedure which includes eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
3. Whistleblowing Policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
4. Anti-corruption and Bribery Policy. It is our policy to conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

OUR SUPPLIERS

S. Sheard & Son Ltd maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

1. They have taken steps to eradicate modern slavery within their business
2. They hold their own suppliers to account over modern slavery
3. They pay their employees at least the national minimum wage
4. We may terminate the contract at any time should any instances of modern slavery come to light

OUR PERFORMANCE INDICATORS

We will know the effectiveness of the steps we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

TRAINING

We are continuously increasing awareness and understanding within our Company of our commitment to eliminating the risk of forced labour and human trafficking occurring in our direct operations and supply chain. We will provide specific formal training courses as necessary.

Approval for this Statement
This statement was approved by the Board of Directors on 4/4/19.

Lee Shackleton
Managing Director