“We dream of a world where people are not bought or sold but right now an estimated 40 million people are currently trapped in modern slavery” – Stop The Traffik (www.stopthetraffik.org).
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 2022.
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 385 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, over half of whom are ‘SME’s (small to medium-sized organisations, as defined by the UK Government).
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 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 as well as existing suppliers are also required to confirm their understanding and acceptance of the Airbus Supplier Code of Conduct, which contains clauses pertaining to human rights and employment practises, during our “Know Your Supplier” On-boarding / Re-evaluation assessments.
- The Compliance Block List is a formal listing complied and distributed by Airbus, 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. It is maintained by the Ethics and Compliance, Procurement and Finance teams at Airbus and is applied across Airbus and its subsidiaries, including SSTL. The Compliance Block List is an integral part of the ‘Know Your Supplier’ supplier assessment and 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 Airbus through the OpenLine website: www.airbusopenline.com. Content is available in 13 languages.
Our Supply Chain in 2022
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;
- All members of the Procurement Team continue to maintain their Chartered Institute of Purchasing and Supply (“CIPS”) Ethical Procurement and Supply certification which includes human rights as a specific module.
- The Direct and Indirect Procurement teams each took part in a separate Modern Slavery Workshop in recognition of the different risk profiles posed by each supply chain. Both teams undertook the Airbus Modern Slavery e-learning and discussed various examples from the media, the impact and the importance of ‘critical thinking’ when thinking about where it could be in our community and supply chain. The teams then had a group session to assess and discuss real Modern Slavery Statements published by organisations in our supply chain against the criteria recommended in the ‘CIPS Statement Checker’.
- 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. We contacted ‘Stop The Traffik’, a UK based charity dedicated to prevention of human trafficking by disrupting the business model of the criminals involved, as well as the rescue of the victims. The Stop The Traffik SME Toolkit helps small businesses identify and reduce the human trafficking and modern slavery risk within their operations. We now include Stop The Traffik content and a link to the SME toolkit in every “Know Your Supplier” assessment form to raise awareness and empower small organisations to help eradicate modern slavery.
In 2023, 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 has been made available by Airbus through our integrated training portal later this year, targeting senior managers.
- The Airbus-led ‘Social Assessment’ audit of SSTL, focusing on human and labour rights throughout our sites, will take place in Q3.
- We fully support the Human Rights Policy Statement by Guillaume Faury, Airbus CEO and through our “Know Your Supplier” screening and assessments, we will continue to insist on the same high standards in our supply chain.
- As part of our efforts towards helping to achieve the Airbus-nominated United Nations Sustainable Development Goals (specifically Goal 8 ‘Decent Work and Economic Growth’, for the purposes of this statement), as well as being part of our commitments to achieving Social Value, we are now aligning Outreach careers and STEM skills events and activities towards underrepresented members of our society and geographical areas of deprivation in the UK who, due to essentially economic circumstances, could be at greater risk in the medium to long term of falling into exploitative situations, including modern slavery.
This Statement has been approved by the SSTL Executive Team and is signed by Philip Brownnett, SSTL’s Managing Director.
Managing Director, SSTL