Modern Slavery Statement 2019
Modern slavery is a crime. At Concha y Toro UK Limited (hereafter also referred to as “we”, “our”), we are committed to ensuring that no instances of slavery, worker exploitation or human trafficking take place within our business or supply chains.
We understand businesses have a vital role to play in tackling modern slavery and human trafficking. As such, we continuously aim to improve our practices and remain vigilant to any abuses.
Vina Concha y Toro S.A. is the world’s second largest vineyard owner, employing over 4,000 people in winemaking, bottling and business operations in Chile, Argentina, USA and subsidiary offices around the world including the UK. The trading company in the UK is Concha y Toro UK Ltd, and has as its business the marketing, sale and distribution of wines produced by Viña Concha y Toro S.A., our ultimate parent company.
Prevention of slavery and human trafficking in Concha y Toro UK Ltd
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Code of Business Conduct and Ethics
Viña Concha y Toro S.A. has had a Code of Business Conduct and Ethics in place for many years, which outlines the ethical principles, values and minimum standards of conduct with which directors, executives and personnel should adhere. This Code applies to all subsidiaries, and as such we too hold all personnel to this high standard.
You can view a copy of the Code of Business Conduct and Ethics here.
Ethical Trade Initiative Base Code
Compliance with the nine points of the Ethical Trade Initiate Base Code (ETI base code) is a requirement of all subsidiaries within the Viña Concha y Toro group, with a high level of awareness of this code at each site. Temporary staff are provided by reputable agencies which are audited to ensure compliance with local regulations and the provision of the ETI base code. The company aims to conduct audits of suppliers/partners to ensure compliance and take corrective action where necessary.
We have in place a comprehensive whistleblowing policy which applies to all employees, officers, consultants, contractors, casual workers and agency workers. This is to ensure that should any of our personnel feel concerned about an area of our business, they can raise their concern in accordance with the policy and feel reassured that their disclosure will be taken seriously and investigated appropriately.
In 2015, Viña Concha y Toro S.A. introduced an “Anonymous Complaints Procedure”, allowing anonymous concerns to be raised about practices or situations that might be a violation to the Code of Business Conduct and Ethics. This scheme was further updated in 2017, allowing concerns to be made by smartphone in order to maximise accessibility. This Channel is accessible through the portal on the website of Vina Concha y Toro S.A.
Prevention of slavery and human trafficking in Concha y Toro UK Ltd’s supply chain
Supplier adherence to our values and ethics
Concha y Toro UK Ltd is solely supplied by Viña Concha y Toro S.A.
Viña Concha y Toro S.A has in place a robust system to ensure supplier adherence to their values and ethics.
Viña Concha y Toro S.A. seeks to develop strong partnerships with its suppliers through joint work, encouraging them to carry out their productive and commercial activities in accordance with their Code of Ethics and Conduct and the Code of Conduct for Suppliers, which establish guidelines on compliance with regulations, occupational health and safety, non-discrimination, freedom of association, child and forced labour, and transparency, among others.
These Codes specify the minimum ethical and behavioural principles and values that must guide the actions of suppliers, contractors and subcontractors of Viña Concha y Toro S.A. In all matters, the Code of Conduct for Suppliers specifies that Suppliers must act with the utmost good faith in relation to the provision of goods and services.
The Code of Conduct for Suppliers reserves the right to verify that the Supplier complies with the Code, and furthermore reserves the right to ask the Supplier to take necessary corrective actions to ensure compliance and even terminate the respective contract with any Supplier that fails to comply with the Code.
Monitoring and Audits
Viña Concha y Toro S.A. and Concha y Toro UK Ltd are committed to ensure that their suppliers comply with the Corporate Ethical Standards outlined above. During 2017 Viña Concha y Toro S.A. conducted a thorough survey among its key suppliers, which were subsequently categorised according to the potential risk of adverse impact on people, the environment and the Company’s economic development.
Also, in 2017, Viña Concha y Toro S.A. carried out internal audits by reference to its Corporate Ethical Standard, to verify compliance with social and environmental requirements of external service providers for 11 of their 14 production facilities. The audits showed minor deviations, mainly related to Occupational Health and Safety, underlining the need to carry out reinforcement training.
Through a review of the implications of the Guiding Principles on Business and Human Rights of the United Nations (Ruggie Framework), Viña Concha y Toro S.A. identified the main potential impacts on human rights relating to their operations and businesses, in order to guarantee that its activities do not violate human rights.
Any impact detected was addressed through Viña Concha y Toro S.A.’s Ethical Management System. This system aims to improve the handling of such issues as well as the detection and prevention of practices that could negatively impact the human rights of those who make up Viña Concha y Toro S.A.’s value chain, with particular emphasis on migrant and seasonal workers.
In terms of sustainability, Viña Concha y Toro S.A. identified risks in the supply chain through internal audits, which verified compliance with the Corporate Ethics Standard, as well as external audits of the SA8000 standard in 11 production facilities in Chile.
Since 2017, Viña Concha y Toro S.A. have conducted annual evaluations of their key suppliers to measure their social and economic impact, including their risk of human rights violations. In addition, they have implemented systems to identify the areas of their supply chain most “at risk” of human rights violations, and conduct thorough yearly audits to ensure their legal, social and environmental compliance.
In 2018, 18 “at risk” links in their supply chain were subject to such audits.
Viña Concha y Toro S.A.’s supply chains include 5 key areas:
All supply chain partners are required to comply with all applicable laws, statutes, regulations and codes.
Viña Concha y Toro S.A. has defined, as one of its essential aims for the development of its activities, that in each stage of the products’ preparation, distribution and sale, every one of its suppliers, contractors and subcontractors complies with existing rules and regulations of the jurisdiction in which they operate. Also, Viña Concha y Toro S.A. requires its suppliers, employees, agents and subcontractors, to meet and fully commit to their ethical values and integrity in the pursuit of excellence and transparency.
Viña Concha y Toro S.A. has summarised the minimum ethical and behavioural principles and values that must guide the actions of suppliers, contractors and subcontractors of Viña Concha y Toro S.A. and Concha y Toro UK Ltd in its Code of Conduct for Suppliers. In all matters, Suppliers will act with the utmost good faith in relation to the provision of goods and services.
Due diligence processes for slavery and human trafficking
As part of Viña Concha y Toro S.A.’s initiative to identify and mitigate risk they are currently moving forward with the certification of their Ethical Management system under the SA8000 standard, closing 2017 with enological wineries in Chile externally audited. In 2018, again under the SA8000 standard, their agricultural farms were externally audited and in 2019, packaging plants are due to be externally audited.
There are systems in place to:
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have recently communicated this statement to all employees and we are also in the process of organising training for relevant members of our staff.
Following a review of the effectiveness of the steps we have taken this year to ensure that here is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:
- Roll out comprehensive training for relevant employees within Concha y Toro UK Ltd
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 31st December 2018.
Concha y Toro UK Limited
Date: 13th May 2019