Child / Forced and Compulsory Labour / Modern Day Slavery Act


As a business with a history and an ethical framework of good employment practice, CNCo is committed to providing good working conditions for its employees, according to universal international standards, and to protecting their safety and health. We recognise that modern slavery (which includes child / forced and compulsory labour) as an issue that has become increasingly visible and we must take seriously all moral and legal duties in this regard.

CNCo’s Code of Conduct requires the entire CNCo group of companies to comply with all applicable local, national and international laws and regulations in each of the countries / jurisdictions in which it operates and with all CNCo’s company policies. That requirement includes ensuring that CNCo (and its suppliers) do not engage forced / child / bonded or prison labour, or apply unjustifiable disciplinary measures to our employees.

The Code of Conduct is supplemented by our Global HR procedures which ensure that pre-employment screening is conducted prior to the offer of employment. Our Supply Chain Sustainability Code of Conduct spells out all principles to which we require our suppliers to adhere covering, inter alia, forbidding forced and child labour.

CNCo’s CoC covers employment “not permitting any breaches of employment law or the use of children (under 18 years of age) or forced labour”. While the Code states the minimum age of a child as being 18 years of age, we ensure that we are aligned with that in the UNICEF / UNESCO Convention on the Rights of the Child (1989), and do not employ anyone of “less than 18 years of age”.

The sole exception to this would be that, in accordance with International Labour Organisation (ILO) Convention 138 (Minimum Age Convention, 1973) Article 6, we exclude from our definition of “labour” and “employment” any applicability to a person between the ages of 16 and 18, who is undergoing “a formal course of education or programme training being undertaken by young persons in schools for general, vocational or technical education or in other training institutions”.

As part of our compliance with the UK Modern Day Slavery Act (MSA) (2015), we carried out a number of self-assessments for our higher risk suppliers in 2017. These assessments gave us an insight into the state of supplier maturity against modern slavery areas and allowed us to propose improvements to strengthen their governance systems. No serious non-conformities were recorded. The next round of assessments is planned for 2019.

We also included contractual clauses related to slavery and human trafficking in all our new supplier agreements. We provided essential training on MSA to 94.7% of our relevant personnel assessed as most likely to encounter potential issues with regard to modern slavery during 2018.

The Australian Government has introduced a Modern Slavery Act which came into force on 1st January 2019. This Act, similar to the UK MSA, brings a modern slavery reporting requirement to certain businesses and other entities in Australia. CNCo will comply with Australian MSA and will be publishing one statement covering both Acts for the entire CNCo group of companies within the stipulated period after the end of each of our financial years (ending on 31st December).

For more information on MSA related actions taken and planned for 2018 please see our Statement on Modern Slavery and Human Trafficking for the financial year 2018 on CNCo’s website.

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The CNCo group will not tolerate the practice of modern slavery in any form and is committed to continue to work with all of its stakeholders and relevant regulators to combat this issue, wherever it may become aware of it.