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Stuart Delivery Ltd: Modern Slavery Statement for FY 2023
This Statement is being published in accordance with Section 54 of the United Kingdom’s Modern Slavery Act 2015. It outlines the steps taken by Stuart Delivery Ltd (“Stuart”) during the 2023 financial year to address the risk of modern slavery in its own operations or in the suppliers of Stuart, as well as Stuart’s future plans in that regard.
Stuart is a tech logistics company that connects businesses of all sizes to geolocalized couriers allowing them to meet their customers’ needs for on-demand, same day and next day delivery. This service is in operation across many sectors including restaurants, grocery, retail, luxury and e-commerce. The Stuart platform allows millions of deliveries to take place every month across over 150 cities in the UK, France, Spain, Portugal, Poland and Italy.
The company has been operating in the last mile since 2015, and in 2017 joined GeoPost/DPDGroup, the branch of La Poste Group specialising in parcel delivery.
In the UK, the majority of Stuart’s business operations are concerned with the on-demand platform offering, where Stuart acts as an agent and deliveries are carried out by independent self employed couriers. In addition to its activity as an intermediation platform, Stuart also operates as a parcel carrier, providing delivery services via subcontractors to clients on a same day / next day service, with its own urban warehouses.
Details of the countries and industries in which we operate can be found on our Group website (About Stuart and our vision to empower your businesses).
Stuart endeavours to do business by conducting its operations in ways that attempt to preserve, protect, and promote the full range of human rights, such as those described in the United Nations Universal Declaration of Human Rights (UDHR), the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work (ILO), and the UN Guiding Principles on Business and Human Rights (UNGP).
It continues to be a priority to Stuart to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chains. This statement highlights the key initiatives we have undertaken during this financial year (FY 2023) to strengthen our approach to the detection and prevention of modern slavery within our business and supply chains.
As part of GeoPost/DPDGroup, Stuart applies a global Risk Management/internal control framework that ensures that Stuart’s risks are managed in a sound manner and escalated as appropriate.
Inside Stuart’s Group, Modern Slavery risks are handled at a global level.
Our policies on slavery and human trafficking
We have appropriate policies that underpin our commitment to ensure there is no modern slavery or human trafficking in our business or in our supply chains.
Our Modern Slavery Policy sets out our commitment to acting ethically and with integrity in all our business relationships and to implement and enforce effective procedures to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Furthermore, Stuart has published a new Code of Conduct (deriving from the code of GeoPost/DPDGroup). It underpins the standards of behaviour we expect from all our people worldwide. It provides a clear set of standards for the way we conduct business as well as ethical and behavioural guidance to help our people put the principles into action in their day-to-day work.
Our Code makes it clear that our people also have a responsibility to report (directly to their manager or using our new Whistleblowing system) any behaviour which is inconsistent with the principles set out in the Code.
These policies are communicated to the employees as part of their induction process and are available at any time via our intranet.
Due diligence processes for slavery and human trafficking
In order to identify and mitigate modern slavery risk within our business, we ensure all employees are subject to pre-employment checks to confirm their identity and right to work in the UK. All employees are paid above the National Living Wage and are provided with all statutory rights and benefits in line with our legal obligations.
We also have systems in place to mitigate the risk of slavery and human trafficking occurring in our supply chains.
Our supply chains
Stuart’s Procurement Department is in charge of onboarding new suppliers.
Due diligence is carried out using a risk-based approach, assessing risks associated with third-party suppliers.
Relevant assessments are conducted by the Procurement, Finance, Cybersecurity and Legal departments.
The reviews endeavour to identify any potential risks associated with the supplier. Where appropriate, potential issues are escalated to senior management.
Given the nature of the services provided by Stuart, the skilled nature of its workers, and the fact that it is a tech logistics company relying mainly on IT providers, it considers there is a low risk of modern slavery in its supply chain.
Supplier, contractor and courier adherence to our values and ethics
We have a “zero tolerance” approach to slavery and human trafficking. To ensure all of our external stakeholders comply with our values, we have specific checks in place.
This consists of taking a risk based approach to ensuring those contractors/suppliers that present the highest degree of risk from a modern slavery perspective are required to commit to appropriate ethical standards in contractual agreements, including slavery and human trafficking within their own supply chains.
Also, a new Sustainable Procurement Charter has been implemented in 2022. The Charter, which is publicly available on the company’s website, sets out clear standards of business conduct and ethics that we require our suppliers to abide by. Our suppliers are required to adhere to the Charter (or equivalent standards).
Regarding independent couriers who are Stuart’s clients and operate via the Stuart platform, we have in place robust terms and conditions and ensure all account holders are subject to pre-onboarding checks to confirm their identity and right to work in the UK. The Courier Compliance Team’s mission is to perform compliance checks of this nature and ensure that we comply with all relevant laws and regulations.
Our Whistleblowing system is also available externally and contains guidance on how to raise any questions or concerns that any person may have about modern slavery in our business or supply chain.
The system is hosted by an independent external organisation, Safecall which then forwards the online report to the company’s Ethics Committee for review and investigation. This process ensures the whistleblower can remain anonymous if they wish and that the report is reviewed at the most senior level of management within the company.
During FY23, no complaints or concerns were raised about modern slavery or human trafficking taking place in Stuart.
On an annual basis, Stuart identifies and maps risks relating to human rights issues, including modern slavery and human trafficking. It also identifies the steps already in place to mitigate those risks and further steps to be taken to enhance current mitigations.
Stuart does not routinely carry out specific training in respect of modern slavery issues, although employees do receive more general training on ethics issues and guidance is given on how to identify potential modern slavery issues in Stuart’s applicable policies.
General Manager approval
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2023. It was approved and signed by the General Manager of Stuart Delivery Ltd, John Gillian.