IntroductionModern slavery, including human trafficking, forced and child labour is one of the most abhorrent practises in society across the globe. Surrey Satellite Technology Limited (“SSTL”) has prepared this statement in compliance with the UK ‘Modern Slavery Act 2015’, which describes our activities and actions to tackle modern slavery during the year ending 31st December 2023.
Organisational StructureWe have been building world-leading small satellites for 40 years and have earned a reputation as one of the world's premier providers of commercial and operational small satellite programmes and customer training. 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 365 staff across two UK locations in the Southeast of England.
Our Policies and Actions on Anti-Slavery and Human TraffickingSSTL 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:
• 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 embedded within our own standard contractual terms. Prospective as well as existing suppliers are 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” Onboarding / 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 Executive 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.• In alignment with the commitments made within ‘Training and capacity building’ section of the Airbus SE Modern Slavery Statement, as a subsidiary all staff were required to complete the ‘Introduction to Modern Slavery’ eLearning in 2023.
• As an Airbus affiliate, we also complete an annual internal controls self-assessment to identify any gaps and put remedial action plans in place where required. This can be updated quarterly with progress and is audited regularly by Airbus.
Our Supply Chain in 2023
The SSTL “Approved Supplier List” (“ASL”) is 80% UK based at Tier 1, over half of whom are ‘SME’s (small to medium-sized organisations, as defined by the UK Government). The SSTL supply chain teams report ultimately to the Finance Director who is a member of the SSTL Executive Team and a Board Director. Our Procurement Manager and Head of Supply Chain are responsible for the teams and the entire 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. In 2023
• We have continued to invest in screening, alert monitoring and training as well as implementing new category strategies which also serve to mitigate the risk of human trafficking entering our supply chain.
• As supply chain facing personnel, 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.
• We continue to 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. SMEs fall below the threshold for mandatory Government reporting and yet may present a higher probability of risk, fore.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.
Future ActionsIn 2024, the following actions have either already started or are due to commence this year:
• 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.
• We will continue to review and implement the recommendations pertaining to our own staff as identified in the Airbus Social Assessment that took place in September 2023.
• 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.
• The ‘Introduction to Sustainability’ course, ighly recommended by Airbus as an eLearning for 2024 will be made available to SSTL staff.
This statement has been approved by the SSTL Executive Team and is signed by SSTL’s Managing Director, Philip Brownnett.
Signed
Philip Brownnett
Managing Director, SSTL