Modern Slavery Act Statement 2020
Slavery and human trafficking is a truly abhorrent practise which is constantly adapting as wider global forces influence its form and momentum. 2020 saw the sudden and catastrophic onset of the COVID-19 pandemic across the world and Surrey Satellite Technology Limited (“SSTL”) believes that this has served to dramatically increase the risk of modern slavery and unethical practise, both in areas already identified as well as in parts of the supply chain and communities previously considered at lower risk.
SSTL remains steadfast in our commitment to help the total eradication of modern slavery and human trafficking, both in the U.K and around the world. This is our fifth statement to be published in accordance with s.54 of the Modern Slavery Act 2015 and relates to actions and activities between 1 January 2020 and 31 December 2020.
We have been delivering small satellite missions for over 35 years, giving us the experience to justify our reputation as one of the world's premier providers of operational and commercial small satellite programmes.
In 2008 Airbus bought the majority shareholding from the University of Surrey, allowing SSTL to fulfil its growth potential. SSTL Ltd is now a wholly owned subsidiary company within Airbus. We are governed by a Board of Directors overseeing our Executive team who manage our 375 staff across two UK locations.
Our Head of Procurement and Head of Subcontracts are responsible for the SSTL supply chain. Both teams report directly to the Financial Director who is a member of the SSTL Executive Team.
Our Policies on Anti-Slavery and Human Trafficking
SSTL operates certain policies that support our commitment to identify slavery risks and take the necessary preventative steps to ensure there continues to be no known slavery or human trafficking in our own operations as follows:
- Code of Conduct - we fully endorse the principles of the Airbus Code of Conduct which, for the purposes of this Statement, gives clear and comprehensive instruction in respect of protecting human rights and maintaining positive and healthy labour relations. It is made available to our staff on our Intranet site and new revisions feature on our internal news carousel.
- The Airbus Supplier Code of Conduct is also embedded within our own standard contractual terms and makes our expectations clear from the outset to prospective suppliers.
- Whistleblowing Policy – we continue to encourage all our employees, workers, customers and other business partners to report any concerns related to the activities of SSTL or our supply chain. This includes any circumstances that may give rise to the risk of slavery or human trafficking. Our Whistleblowing policy is designed to make it easy for all parties to make disclosures without fear of retaliation. Employees, customers or others who have concerns can contact any member of the SSTL leadership team, the Compliance Officer or the Managing Director. They may also make use of the “OpenLine” system put in place by our shareholder, Airbus either by telephone on 0800 27 00 00 07 or through the OpenLine website: www.airbusopenline.com
Our Supply Chain in 2020
We are fully aware that slavery and human trafficking could be happening in our current supply chain right now. We have continued to enhance our collective awareness and governance and successfully implemented a number of initiatives in 2020, including:
- All Procurement team members successfully maintained their CIPS Ethical Procurement & Supply certification in 2020-21. This continues to be a key source of knowledge and helps us to be vigilant to existing and emerging risks, as well as current Best Practise in environmental procurement, protecting human rights and preventing fraud, bribery and corruption.
- Our investment in a new supply chain monitoring algorithm-based tool has proved to be essential addition to our “Know Your Supplier” (“KYS”) process suite. Together with the Airbus solutions available to us, it has enabled a much more agile response more suited to the small business we are.
- Our agile approach coupled with our in-depth KYS assessment capabilities have been a cornerstone in delivering a successful “In-country Supply Chain Development” package as part of Know-how Transfer and Training (“KHTT”) programme in collaboration with a key international customer in 2020. We were delighted to be invited to co-author a paper describing our approach, with the customer which was presented to the International Astronautical Congress in October.
- The KYS Assessment process suite has continued to help us ensure our SSTL Approved Supplier List meets our value criteria. We were successful this year in passing all internal QMS, Airbus and third party accreditation audits.
- Achieving a completion rate of 97% for the Modern Slavery e-Learning that all staff were asked to complete.
- A new SSTL Intranet section was launched and is dedicated to news articles, videos and other media related to Modern Slavery and is of specific relevance to SSTL, our supply chain, our products and the wider space industry.
Our Response to the Increased Risk of Modern Slavery during the on-set of COVID-19
Like many businesses in March 2020, SSTL’s day-to-day business operations had to make the sudden switch from an office-based workforce to having the majority working from home as per the UK Government mandate. We had a sudden and urgent requirement for more electronic equipment such as laptops, monitors and webcams as well as PPE and furniture to ensure we could continue to meet our employee health and safety commitments fully and effectively. We are aware of the higher risk of modern slavery in the material sources and manufacture of electronic goods as well as the risk of accidently buying electronics, PPE and furniture from unethical sources in the rush to acquire these items to secure business continuity.
SSTL would like to take this opportunity to thank all of our Approved Suppliers, both in the UK and across the world for their ongoing support in ensuring we had an adequate and ethically sourced supply of all of these items throughout the year. We continue to work with them on the same strong foundations in what has been the most challenging of circumstances.
The COVID-19 pandemic serves only to exacerbate the risks that existed previously as well as introducing new victims and communities to the risk of becoming victims of Modern Slavery.
Whilst it has become much harder for criminal organisations to traffic people across borders in the past year, opportunities for legal, gainful employment at home would have also diminished, bringing the slavery risk to the door of more areas of our society.
Exploitation will now be much easier. The Authorities could be less able to counter it due to COVID restrictions and having to divert resources to managing the pandemic. Where some businesses have closed, people may be forced to look elsewhere for income in desperation. COVID restrictions could also reduce visibility and traceability of a company’s workforce. There are also the economic impacts still to come. The UK now has the worst debt position since World War II. Unemployment is at a four year high with job losses more heavily concentrated among young workers (R. Partington, “UK Unemployment Reaches Four Year High in COVID-19 Lockdown”, The Guardian website, 26 January, 2021).
The SSTL Corporate Objectives for 2021 mandate that at least two further e-learnings on the subject of Ethics and Compliance must be completed by all staff this year. Furthermore, the dedicated Intranet section on Modern Slavery and other ethical procurement subjects will be made more prominent and easily accessible through one click on the homepage to help the wider organisation maintain its vigilance and understanding.
In 2021, with regards to the SSTL supply chain, particular focus areas include:
- SMEs (small to medium-sized enterprises). SMEs fall below the threshold for mandatory Government reporting and yet may present a higher probability of risk, for e.g., the outsourced service workforce, low skilled labour, site maintenance requirements, etc. Whilst we have made the KYS On-boarding and re-evaluation process less cumbersome for smaller organisations, we will continue to scrutinise against the key themes and risk profiles to the enhanced standard with regards Modern Slavery.
- PPE manufacturers and distributors – 2020 saw an explosion in global demand for personal hygiene items such as hand sanitiser, masks, gloves and visors (“PPE”). We are not usually heavy users of these products in our industry so had we approached unknown suppliers, our reduced influence, unprecedented demand and urgent timescales would have meant a huge increase in the risk of forced labour entering our supply chain. Our existing Indirect Supply Chain has proven invaluable in their support in the implementation of our COVID-Secure workplaces across our estate and the provision of PPE and other safety consumables to keep our on-site staff safe at all times. We will maintain vigilance here throughout the remainder of the pandemic and any residual needs we may have longer term.
- Waste electronics disposal – as part of “cradle to grave” procurement life cycle methodology, we will ask our key suppliers of IT consumables and equipment to present their current processes and associated accreditations for responsible waste disposal and ensure it does not end up in “stripping centres” where people are made to remove valuable materials from waste electronics in very poor conditions.
SSTL whole-heartedly supports the UK Government’s PPN (Procurement Policy Note) 06/20 for “Social Value in the Award of Central Government Contracts” which states that the Social Value Model be applied to all new procurements from 1st January 2021. We have been working alongside Airbus on our commitment to Social Value for some time as part of the “MyWay” Social Value program and have identified objectives and work-streams which we believe will help us drive the flow of monies from awarded all customer programs and build projects into the communities and under-represented areas of society local to SSTL, as well as around the United Kingdom. We have made Social Value part of our 2021 Corporate Objectives and we look forward to reporting on our journey in our next Modern Slavery statement in early 2022.
This statement has been approved by the SSTL Executive Team and is signed by Philip Brownnett, SSTL’s Managing Director.
Managing Director, SSTL