“Slavery affects more than 40 million people worldwide – more than at any other time in history” – Kate Hodal, The Guardian, 2019.
Slavery and human trafficking is a truly abhorrent practise which is constantly adapting as wider global forces influence its form and momentum. Surrey Satellite Technology Limited (“SSTL”) has prepared this statement, published in accordance with the UK ‘Modern Slavery Act 2015’, relating to our actions and activities to tackle modern slavery during the year ending 31st December 2021.
We have been building world-leading small satellites for 40 years and have earned a reputation as one of the world's premier providers of operational and commercial small satellite programmes. SSTL is a wholly owned subsidiary company within Airbus and we are governed by a Board of Directors overseeing our Executive team who manage our 360 staff across two UK locations.
Procurement and Subcontracts report directly to the Finance Director who is a member of the SSTL Executive Team. Our Head of Procurement and Head of Subcontracts are responsible for the SSTL supply chain, which comprises ‘Direct’ (colloquially known as “Flight” procurement) and ‘Indirect’ (“Non-Flight”) which includes procurement of products and services for Facilities, I.T. and other operational requirements. The SSTL “Approved Supplier List” (“ASL”) is 80% UK based.
Our Policies on Anti-Slavery and Human Trafficking
SSTL has policies and processes 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 or supply chain as follows:
- Employee Code of Conduct - we fully endorse the principles of the Airbus Employee Code of Conduct which, for the purposes of this Statement, gives clear and comprehensive instruction to all employees in respect of protecting human rights and maintaining positive and healthy labour relations. It is available to our staff on our Intranet site and it is part of our new starter Compliance induction. New revisions feature on our internal news carousel.
- The Airbus Supplier Code of Conduct is also embedded within our own standard contractual terms. Prospective and existing suppliers are also required to confirm their understanding and acceptance of the Airbus Supplier Code of Conduct during their ‘Know Your Supplier” On-boarding / Re-evaluation Assessments.
- The Compliance Block List is a formal listing of individuals or companies who are to be blocked in all ERP systems and are to have no dealings with Airbus under any circumstances. This includes suspected or actual ethical conduct risks such as modern slavery as described in the Airbus SE Modern Slavery Statement 2021. It is maintained by the Ethics and Compliance, Procurement and Finance teams at Airbus and is applied across Airbus and its main subsidiaries, including SSTL. The Compliance Block List is an integral part of the ‘Know Your Supplier’ supplier approval process at SSTL.
- Whistleblowing Policy – we continue to encourage all our new starters, employees, workers, customers, suppliers 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 2021
We have continued to invest in screening, monitoring and training as well as implementing new category strategies which also serve to mitigate the risk of human trafficking entering our supply chain;
- The mining of virgin materials for use in new electronic equipment such as laptops and smart phones is a high risk area for human trafficking and forced labour, not to mention the devastating impact on the environment. In September 2021 we began buying OEM-approved refurbished servers, data centre equipment and server support packages from a leading UK SME in this field in order to further mitigate the risk of forced labour where virgin materials are not required to manufacture new items for our use. We also performed a successful ‘Know Your Supplier’ Deep Dive into the sourcing and procurement practises of our two key I.T. hardware suppliers which confirmed the comprehensive methods and strategies employed to mitigate against the risk of modern slavery as well as to help protect the environment.
- Members of the Procurement Team continue to maintain their CIPS Ethical Procurement and Supply certification with includes modern slavery as a specific module.
- We have made a substantial investment in Dun & Bradstreet Risk Analytics which provides a real-time ‘dashboard’ view, with alert functionality of supply chain health, against criteria such as financial health, adverse media screening including ethical performance criteria, corporate linkage and a risk scorecard.
- The ‘Know Your Supplier” process suite has been enhanced and continues to help us ensure our SSTL Approved Supplier List meets our values criteria which includes our modern slavery commitments. We were successful this year in validating the ‘Know Your Supplier’ process suite in compliance with the Airbus Supplier Compliance Review Process Deployment.
The impact of the Covid-19 pandemic is still reverberating around the world although international travel restrictions have eased, making it easier to traffic people across borders to work as forced labour. In February 2022, the Russia-Ukraine conflict began which is serving to compound raw material and supply chain issues brought on by macro-economic events such as Covid-19. As ever, criminals will be looking to profit from the situation through unethical business practise and promoting the proliferation of human trafficking and forced labour to achieve their ends.
In 2022, the following actions have either already started or are due to commence this year:
- In alignment with the ‘Training and capacity building’ section of the Airbus SE Modern Slavery Statement, as a subsidiary a dedicated eLearning module on human rights will be made available by Airbus through our integrated training portal later this year, targeting senior managers.
- The Procurement and Subcontracts teams will undergo a modern slavery workshop, with eLearning and interactive content so as to challenge and enhance their understanding of where risks could be in their particular purchasing categories and how to critically evaluate an organisation’s Modern Slavery Statement.
- In early 2022 we were proud to be awarded a contract by the UK Ministry of Defence; our first to contain specific Social Value Model Award Criterion (‘MAC’s) in accordance with the UK Government’s PPN (Procurement Policy Note) 06/20. The supporting ‘Social Value Model’; (Theme 4: Equal Opportunity, Policy Outcome: Tackle workforce inequality”) makes it unequivocally clear that the government is “committed to tackling the scourge of modern slavery” and our Social Value commitments serve to help achieve this through skills development, progression opportunities and enhancing awareness of what modern slavery could look like in our business and our community.
- 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. Currently about 30% of our Approved Supplier List are UK-based SMEs and we plan to on-board even more this year. We will raise awareness of modern slavery with our UK SME supply chain through sharing relevant content with practical ways to identify it, tackle it and help eradicate it.
This statement has been approved by the SSTL Executive Team and is signed by Philip Brownnett, SSTL’s Managing Director.
Managing Director, SSTL