Modern Slavery & Human Trafficking Statement
This statement sets out the steps that Affinity for Business (Retail) Limited (“Affinity for Business” or “we”) have taken to ensure that slavery and human trafficking is not taking place in any part of its business or supply chain.
Affinity for Business supplies clean water and wastewater services to businesses in England and Scotland. We have in the region of 55,000 customers, with the vast majority being in the South East of England (although we are licensed by the Water Services Regulation Authority (Ofwat) to sell services to any non-household business across the whole of England and the Water Industry Commission for Scotland to sell services to any non-household business in Scotland).
We are owned by Affinity Water Capital Funds Limited. Our ultimate parent is Daiwater Investment Limited, which is owned by Allianz Capital Partners on behalf of the Allianz Group, HICL Infrastructure Company Limited (advised by InfraRed Capital Partners Limited) and DIF.
We employ around 90 people and our business is focused on the supply of clean water and wastewater services to circa 70,000 non-household customers. We are organised in the following way:
• Customer services – providing telephone, email, and online support.
• Account managers – providing personal support and advice to our larger customers.
• Switching team – managing the on-boarding of new and dual service customers.
• Debt team – providing support to customers who are in arrears.
• Marketing and Communications – responsible for our digital presence, acquisition of new and dual customers, and all communications and printed literature.
• Commercial and Finance – responsible for all financial reporting to the business (including compliance and SHEQ), managing our finances, and supporting the teams with quotes to customers, bids, procurement and legal.
• HR – responsible for onboarding new employees, employee support and employee policies and benefits.
Our supply chain includes around 60 suppliers of varying size and location. Our key suppliers are licenced water and wastewater undertakers who provide the wholesale provisions to our primary services. We expect our suppliers to understand their obligations with respect to modern slavery and human trafficking and to ensure that they, and their own supply chains, meet those obligations.
Our largest supplier by value is Affinity Water Limited, a member of our group, which provides us with services that enable us to supply our customers with water together with other corporate support services.
Responsibility & Due Diligence
We expect our suppliers to understand their obligations and ensure that they, and their supply chains, are compliant. We consult and inform our employees on all aspects of our business and employment practices both directly and with the trade unions to which several employees belong.
Our main supplier, Affinity Water Limited is subject to the Modern Slavery Act 2015 and publishes a modern slavery and human trafficking statement along with a variety of policies committed to corporate responsibility and combatting modern slavery and human trafficking. Affinity Water has a stringent procurement process and adopts an independent qualification system for all medium and high-risk suppliers. Achilles, the system used, requires registering suppliers to complete a comprehensive qualification document which includes questions on human trafficking and slavery. Suppliers who have ‘Verify’ status on this system are subject to additional screening questions and are audited by Achilles at the supplier’s site on an annual basis.
We have a “Suppliers and Subcontractors Guidance” policy, whereby suppliers and subcontractors must meet the requirements of legislation and regulation and are subject to audit. We have also finalised a supplier questionnaire to be provided to all new suppliers ahead of onboarding, including questions regarding compliance with the Modern Slavery Act, and requesting policies focused on labour, supply chain transparency, ethical trading, antislavery/
human trafficking and anti-bribery and corruption. We are onboarding a Supplier Performance Manager, who will have focus on procurement processes. We also have a detailed employee whistleblowing policy in place.
We therefore have systems in place to identify, assess and mitigate potential risk areas in our supply chains, which are continually improving. We have a dedicated compliance team, which consists of involvement from the following departments:
• Audit and compliance
• Health and safety
• Commercial and Finance
Staff are advised to contact the Modern Slavery Helpline if they are at all concerned that modern slavery or human trafficking is taking place either at Affinity for Business, at our suppliers, or taking place within our customer’s businesses.
08000 121 700
Our staff are also aware of our detailed whistleblowing policies, by which reporting can be made via an internal process or by contacting an external service provider directly.
Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:
• Introduce an Anti-Slavery Policy.
• Improve our procurement processes in relation to vetting and onboarding processes of new suppliers.
• Update training of staff regarding the detection and prevention of human trafficking and slavery.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2019. It was approved by the board on 30 January 2020.
Managing Director, Affinity for Business (Retail) Limited
Date: 30th January 2020