Modern Slavery And Human Trafficking Statement
Introduction
The respect for human rights and that it acts with responsibility and integrity forms an integral part of the corporate culture of Retail inMotion Limited (Retail inMotion/ the company).
Retail inMotion is an Irish registered company which was acquired by the Aurelius Group in April 2023. Modern slavery is a crime and a violation of fundamental human rights. The company is committed to improving its practices to combat modern slavery and human trafficking. Our statement outlines the steps we have taken to prevent Modern Slavery within our company and our supply chains and sets out our plans for future improvements.
This statement corresponds to section 54 (1) of the Modern Slavery Act 2015 (United Kingdom) and constitutes our company’s slavery and human trafficking statement for the year ending 31 December 2023.
In conformity with section 54 of the Act, in this statement we report about:
- About Retail inMotion – our organizational structure
- Our policies regarding Modern Slavery and Human Trafficking
- Further safeguarding measures
- Our supply chains
- Our further steps to prevent Modern Slavery
- The approval for this statement
1. About Retail inMotion Limited – our organisational structure
Retail inMotion Limited is part of the Aurelius Group. Amongst other services, the company provides inflight payment solutions and onboard retail services to airlines globally.
2. Our policies regarding Modern Slavery and Human Trafficking
Retail inMotion conducts its business in line with internationally acknowledged principles and is committed to embedding respect for human rights as an integral element of its corporate culture.
Retail inMotion operates a binding Code of Conduct which documents the values, principles, and standards of conduct of the company. The Code of Conduct expressly states: “We respect and uphold the dignity of our employees, customers, and business partners. In all our actions, we ensure that we act in accordance with human rights, the principles of the UN Global Compact, and recognize international labour and social standards. In particular, we reject child labour, forced labour, and exploitation or discrimination of any kind.”
The Code of Conduct is binding for all managers and employees of Retail inMotion.
The following policies are in place relevant to modern slavery and business relationships, which are reviewed and updated regularly:
- Code of Conduct
- Recruitment Policy
- Procurement Policies
- Whistleblowing Policy and procedures1
- Anti-Bribery and Corruption Policy
- Grievance Policy
- Bullying and Harassment Policy
The company is committed to sourcing quality products from, and building relationships with, suppliers who share our values and ethical standards. We do not do business with organisations who do not share these values.
3. Further safeguarding measures
As a former member of a major international airline group, Retail inMotion adopted the binding due diligence obligations for companies under German Supply Chain Due Diligence Act (LkSG) when it was introduced on 01 January 2023. This act is intended to ensure that human rights are respected in the supply chain. The LkSG addresses 12 human rights-related and eight environmental risks. The human rights-related risks, such as child labour, forced labour, slavery, and slavery-like practices, are directly related to the measures and practices that Retail inMotion already undertakes today to prevent them.
4. Our Supply Chains
Supply chain sustainability is an important element of responsible production. This means that, in addition to economic aspects, impacts on the environment and society are taken into consideration during the procurement process. To meet the standards Retail inMotion sets for the sustainability of its own products, Retail inMotion relies on close collaboration with suppliers who share and implement these standards. This also forms part of the Retail inMotion’s Code of Conduct.
Retail inMotion’s procurement policy includes the obligation to assume social and environmental responsibility. It is to be understood as an overriding specification for all procurement units at Retail inMotion. In addition, it serves as a handbook for buyers and all employees with contacts in the procurement markets. Appropriate training is available to all employees and is mandatory for the management level. Among other considerations, it requires that these obligations be included in contracts with suppliers:
- to comply with the ten principles of the UN Global Compact,
- to comply with the four basic principles of the International Labour Organisation (ILO),
- the right to consent to announced and unannounced audits by Retail inMotion,
- to accept the termination of the contract if these contractual obligations are breached.
By imposing these obligations, Retail inMotion endeavours to ensure responsible practices by its direct suppliers and so to meet its own standards for corporate responsibility. Retail inMotion’s expectations of its suppliers in terms of social, environmental, and ethical responsibility are summarised and published in its Supplier Code of Conduct. To identify the type and level of supplier risks, the procurement units responsible for product groups carry out a risk assessment for the suppliers. The risk assessment is included in the result of Retail inMotion’s risk management. The procurement process also includes supplier screening to identify risks during the onboarding process so that appropriate measures can be taken. To ensure compliance with Retail inMotion standards, new suppliers are subject to a business partner due diligence before being contracted. If a supplier falls into a risk category, a screening is conducted, including consultation with external sources if necessary. The screening process is designed to help identify potential problems, determine what mitigating measures are required, or prohibit cooperation with the supplier in question. The required obligations are included in supplier contracts.
5. Our further steps to prevent Modern Slavery
As part of an international group of companies, Retail inMotion sees it as its responsibility to contribute to eliminating Modern Slavery. Companies do not control political developments in countries they operate in; however, they have a responsibility in the sphere of their work, especially towards their employees, suppliers, and customers. In the coming year, Retail inMotion will continue to look to further improve its structures, practices and trainings to fight Modern Slavery and Human Trafficking.
6. Approval for this statement
On 27 May 2024, this statement was approved by the company’s CEO with respect to 2023.
John Moriarty
Chief Executive Officer
Monday, 27 May 2024