About this statement
This is an updated statement from the Walker Group published in accordance with the Modern Slavery Act 2015. This statement demonstrates our compliance with the Modern Slavery Act 2015 and our progress during the financial year end 31 December 2021. The statement sets out the steps the Walker Group continues to take in order to address and eliminate the risk of modern slavery and human trafficking taking place within our organisation and supply chains. The Modern Slavery Act 2015 provides for the following offences: slavery, servitude and forced or compulsory labour and human trafficking.
The Walker Group
The Walker Group includes Walker Books Ltd, Walker Books Australia, Candlewick Press Inc and Walker Productions. As one of the world’s leading publishers of books and content for children and young adults, we are committed to protecting the fundamental human rights of all individuals involved in all aspects of our organisation and supply chains, and to improving our practices to combat slavery and human trafficking. The principles of sustained fair labour are embedded within our organisation.
Our aim has consistently been to create a safe environment for all those involved in our business. The Walker Group recognises and champions the need for transparency and accountability. Our focus is on children and young adults and we endeavour to enrich their lives through the products we produce. The need for a rigorous and responsible attitude to ensure that what we do in no way harms, prejudices or enables people to exploit anyone involved in the publishing process is never underestimated and remains at the forefront of how we conduct our business.
Our Supply Chain
The Walker Group continues to evaluate and assess its global impact in its production activities and the supply of books, merchandise and other content for children and young adults. The nature of our business requires a supply chain involving third party suppliers in the following areas: paper, printing, logistics (including transportation), repro and safety testing
Within our organisation itself, we do not discriminate in any way and ensure that all staff are treated fairly and equally. We employ a number of company policies which support our commitment to combatting modern slavery, and to creating a safe working environment for all employees. All relevant policies are outlined in the Policies and Procedures section of this statement.
As part of our business practices, in addition to producing our own books and related materials, we license others to produce products using our brands. Those merchandising licensees are required to adhere to the standards set out in the Walker Group’s Code of Conduct. We continue to follow our green approach to the way our offices are run and we purchase Fairtrade products wherever possible.
The Book Chain Project
Walker is a founding signatory of the Book Chain Project – a collaborative project involving leading publishers, suppliers and manufacturers, working together to ensure better supply chains by supporting publishers to make informed decisions throughout their supply chain activities. Walker is a member of two strands of the project – Forest Sourcing, which relates to responsible forestry sourcing, and Labour & Environment, which relates to labour practice, human rights and environmental standards within the print production supply chain. More information on our involvement in the Book Chain Project throughout our supply chain can be found in the Policies and Procedures and Due Diligence and Risk Assessment sections of this statement.
Policies and Procedures
Walker has a number of policies in place which contribute to our efforts towards addressing and tackling modern slavery in the workplace and beyond and continues to add to the list of policies. All our employees, contractors and, where relevant, visitors, are bound by these policies. All company policies are readily available on our HR system. The following policies are aimed at ensuring the correct conduct is followed at all times within our business. Our working environment adheres to best health and safety practices, no acts of bribery are tolerated, all individuals are treated equally and fairly, and our output reflects our company values in respect of sustainability and the environment. Relevant policies are listed below:
- Health & Safety Policy
- Anti-bribery Policy
- Anti-harassment and Bullying Policy
- Environmental Policy
- Whistleblowing Policy
- Grievance policy
Due Diligence and Risk Assessment
We continually assess our performance and that of our suppliers in order to mitigate the risk of modern slavery and human trafficking taking place. In doing so, we adopt the following procedures:
Identify and assess potential risk areas and mitigate the risk of slavery and human trafficking occurring in our supply chains: our risk assessment and due diligence process includes identifying high risk suppliers based on geography, using the Book Chain Project’s Country Risk Tool. This tool is available on the Book Chain Project website and helps to guide us regarding which suppliers to concentrate on in terms of risk and auditing requirements.
As part of our involvement with the Book Chain Project, members from our production team attend meetings twice per year in the Labour & Environment division. These meetings provide a forum for publishers to come together and discuss labour practices and environmental management. Publishers have the opportunity to review any issues encountered, along with any cause for concerns. Previous discussions have involved recruitment practices of suppliers in high-risk areas, as well as health and safety practices in factories and human rights issues. Those who attend these meetings are able to provide feedback to other team members, allowing us to constantly review our supply chain practices and highlight areas for change.
In addition, members of our production team attend meetings twice per year in the Forest Sourcing division – this provides an opportunity to discuss good practice in sourcing and helps us to identify responsible forest sources for our books. The Book Chain Project’s Forest Sourcing tool operates a grading system to analyse and distil data on tree species and country of origin – manufacturers are therefore held accountable and graded. This allows us to make better informed decisions. We also use the Forest Risk Assessment tool provided by the Project in order to identify high risk countries. We have also sent ‘Best Practice’ documents, through Book Chain, to our suppliers on responsible recruitment.
Monitor potential risk areas in our supply chain: if any of our suppliers are identified as operating in high-risk areas, including any of our printing suppliers, we ask those suppliers to upload valid audits i.e., valid audits which have been conducted in the last 12 months, from a third-party auditor (ICTI or SMETA), along with any relevant corrective action plans. Valid audits need to be provided before they can become an accredited supplier. Due to the COVID-19 pandemic, suppliers were given a six months’ extension for audit renewal. The audits focus specifically on labour standards, with the onus being on that supplier to improve their business practices. This information is uploaded to the Book Chain Project Labour & Environment tracker. This level of transparency and accountability allows us to monitor supplier performance and any potential threat of risk of modern slavery or human trafficking to our supply chain.
Monitoring Effectiveness
We continue to monitor our performance in recognising and eliminating the risk of modern slavery and human trafficking within our organisation and supply chains. By enabling individuals to raise concerns about any of our working practices, or those of our suppliers or contractors, we are able to continuously review compliance through investigating any concerns. In the last year, no concerns were raised by any of our staff members regarding our internal working practices within the Walker Group.
To ensure a high level of understanding of the risks of modern slavery and human trafficking, we support training to relevant departments and teams.
We ask that all our suppliers adhere to the Book Chain Project’s industry Code of Conduct, which outlines our commitments to our suppliers as publishers, and what we expect from those suppliers in return. The Code sets out standards of labour practice and environmental performance, and is based on internationally recognised standards, codes and laws, including; the ILO Conventions, the UN Declaration for Human Rights and the ETI Base Code (the “Codeâ€). The Code is regularly updated and includes statements regarding forced labour, sub-contracting, wages, discrimination and child labour. The Code includes a clause (Clause 1.1) which states that suppliers must not use forced or bonded labour, and upon signing into the Book Chain Project, the suppliers are deemed to have agreed to this clause.
In the event that we discover, or it is brought to our attention, that modern slavery or human trafficking is taking place within our supply chain, it is our policy to terminate our relationship with that supplier in line with our zero-tolerance approach. In 2019, Walker suspended relations with a new supplier after discovering that the supplier had outworked some of their printing workers. We would insist that any suppliers who wish to outwork should supply a valid audit for anyone the work is outsourced to.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Walker Group’s slavery and human trafficking statement for the financial year ending 31 December 2021. It was approved by the Board.
Karen Lotz
Group MD