WW Modern Slavery Act and Human Trafficking Statement | WW UK
WW Modern Slavery Act and
Human Trafficking Statements
Introduction
As part of the world’s leading commercial provider of wellness technology, operating globally through a network of Company-owned and franchise operations, our organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
Our organisation is committed to preventing slavery and human trafficking in all our corporate activities, and to ensure that our supply chain reflects our values and respect for human rights. WW fully supports efforts to combat, prohibit and prevent slavery and human trafficking.
This statement sets out the steps that WW GBR Ltd has taken during the financial year ending December 2020 to understand all potential modern slavery risks related to its business and to put in place policies and procedures that are aimed at ensuring that there is no slavery or human trafficking in our business, or our supply chain and procurement network.
Our business
WW offers services and products that are built upon global wellness technology, inspiring millions of people to adopt healthy habits for real life. We do this through engaging digital experiences, face-to-face workshops and sustainable programs that encompass healthy eating, physical activity and positive mindset. By drawing on over five decades of experience and expertise in behavioural science, WW builds communities in order to deliver wellness for all.
Approach and principles
WW recognises that there are heightened risks with complex procurement and supply chain networks, and we do everything possible to ensure that there are no instances of slavery in either the manufacture or delivery of our goods. WW has a Supplier Policy that provides that all suppliers must comply with applicable international, federal, state, provincial and local laws, rules, regulations and ordinances in connection with the design, manufacture, sale, delivery and use of their products, which includes laws regarding slavery and human trafficking.
Supply chain structure and activities
WW sources products, packaging and services to support our members on their weight loss journey. We have adopted a Code of Business Conduct and Ethics for our officers, including any principal executive officer, principle financial officer, principle accounting officer or controller, and our employees and directors. Our Code of Business Conduct and Ethics is available on our website at www.corporate.ww.com/Investors/corporate-governance/documents. These values are mirrored across the organisation and with all those we interact with both internally and externally. WW achieves this by acting ethically, building long-standing relationships with our suppliers and implementing and enforcing effective controls to ensure slavery and human trafficking does not take place within our supply chain.
Due diligence
The organisation already has an established due diligence programme in those areas of the supply chain where we know there may be a heightened risk of modern slavery. We have conducted audits by a specialist third party on the majority of suppliers in potentially the highest risk areas. Where no report has been completed, we will look to undertake an independent audit and have requested a declaration confirming their commitment to the Modern Slavery Act. As part of our new supplier onboarding process, we assess any risk of modern slavery and will conduct audits where deemed necessary. It is also a requirement of any third-party provider to demonstrate their compliance of the Modern Slavery Act.
We have contacted our remaining suppliers who we have perceived as low risk due to their business location, to submit a declaration on the steps they have taken both internally and in their supply chain to ensure that slavery and human trafficking is not occurring. The Supplier Policy also provides that all suppliers are required to allow WW representatives access to their manufacturing and storage facilities.
WW policies and code of conduct
WW operates an all-encompassing set of policies which sets out clear expectations as to the conduct and behaviour of all our employees, managers and consultants with a view to promote an ethical company culture which extends to identifying any modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. This is underpinned by key company policies and procedures including:
- Code of Conduct and Ethics Policy
- Anti-Corruption Policy
- Supplier/Procurement Code of Conduct
WW recognises the importance of strengthening our policies to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains and as a result continues to review the training provided across the organisation to enable employees to:
Assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
Identify the signs of slavery and human trafficking.
Explain what initial steps should be taken if slavery or human trafficking is suspected.
Know how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation.
Understand what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies.
WW is committed to driving awareness of the issues of modern slavery and human trafficking within its operations and would invite any comments or questions about our statement at SupplyChainUK@ww.com.
Anna Hill
WW GBR Ltd. - General Manager