Slavery and Human Trafficking Statement for the financial year ending 31st December 2019
This statement is a response to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps SAGE Publishing is taking to ensure that slavery is not taking place in our supply chains or in any part of our business.
Our commitment
SAGE is committed to maintaining and developing our processes to tackle slavery and human trafficking violations related to our own operations, our supply chain, and our products. We have zero tolerance towards slavery and require our supply chain to comply with our values.
About us, our operations and supply chain
SAGE is one of the world's leading independent academic and professional publishers. We publish more than 1,000 journals and more than 800 books a year, reference works and electronic products covering business, humanities, social sciences, science, technology and medicine.
Most of our suppliers are based in the UK, the US and India. The bulk of our supply chain consists of:
Print services
Web services
Couriers
Financial intermediation
This statement covers SAGE UK, India and USA.
SAGE's slavery and human trafficking risks
As the majority of our supply chain is based in the UK, US and in lower-risk sectors such as web-based services, our exposure to risk is low. Our greatest potential exposures to the risk of modern slavery are in the part of our supply chain which deals with print media, in particular when it comes to the handling of paper-based materials; and in operations we undertake in the higher risk country of India. Our key areas of focus are:
Direct risk: print and information technology suppliers based in India, a country with a high level of modern slavery risk
Indirect risk: pulp / paper mills, ink manufacturers and the sourcing of timber
Our policies and contractual controls
We have the following policies to set the direction and manage modern slavery in our supplier base:
Supplier code of conduct – our code of conduct outlines the minimum requirements in relation to modern slavery and wider decent work practices
Supplier agreement terms and conditions - our standard terms and conditions include modern slavery clauses and decent work provisions which our suppliers are expected to adopt
Due diligence approach
To manage the risk of modern slavery in our supply chain we carry out the following steps:
All of our existing suppliers have been notified of our code of conduct and current terms and conditions
We have introduced modern slavery weighted questions in our tenders, to ensure that any new suppliers we onboard have their own modern slavery controls in place
In cases where we do not use tenders to appoint new suppliers, we have introduced new supplier checklists which our managers use when reviewing new potential suppliers
All our print suppliers and any handling paper-based products are required to complete SAGE’s modern slavery questionnaire, which are assessed by our procurement teams to ensure minimum requirements are met
For SAGE India where the risks of modern slavery are greater, suppliers are required to sign up to our code of conduct and they too are required to complete SAGE’s modern slavery questionnaire
SAGE India carries out site visits with all of its key suppliers
In addition, we have developed and manage a series of corrective action plans if any issues should arise
Effectiveness
To assess the effectiveness of our approach we review our processes and the results of our checks on an annual basis.
Training and capacity building
Key members of our organisation who oversee sourcing and manage our supply chain have received modern slavery awareness training This training covers an introduction to modern slavery in the publishing industry, what the signs are and the risks for our own organisation; and upskills staff on our policies and mitigation strategies as well as how to carry out a supplier risk screening.
Looking ahead
We will continue to focus in the coming year, on ensuring our policies and mitigation strategies are working effectively and are embedded fully in our current practices. We are looking to broaden the number of managers who have received modern slavery awareness training, to further cement these procedures within the business and continue to ensure all operations have integrity at their core. We will review our approach towards the end of our financial year to understand whether our procedures can be further refined or improved.
Approval
This Modern Slavery Statement was approved by the SAGE Publishing UK Senior Management Group on 29th June 2020.
Katharine Jackson, COO & CFO, SAGE Publications Ltd
29th June 2020