Modern Slavery Act 2015 Statement
This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and sets out the steps Macdonald & Muir Limited has taken during its financial year ending 31 December 2018 to ensure that slavery, servitude, forced or compulsory labour and human trafficking (collectively “Modern Slavery”) is not taking place in any part of its business or its supply chain.
Business & Supply chain
Macdonald & Muir Limited is a producer of single malt scotch whisky.
Macdonald & Muir Limited is a direct subsidiary of The Glenmorangie Company, part of the Moët Hennessy Group, itself part of the LVMH – Moët Hennessy Louis Vuitton Group (“LVMH”).
Macdonald & Muir Limited produces single malt scotch whisky, under the brands Glenmorangie & Ardbeg, which is sold worldwide through the Moët Hennessy Group distribution channels and network.
Macdonald & Muir Limited purchases:
- Dry Goods from suppliers located in the following countries: UK, France, Portugal, Netherlands, Poland, Italy. Some suppliers source in China and Thailand.
- Casks from suppliers located in the following countries: US, France, Spain, Portugal.
- Malt from suppliers located in the UK.
- POSM from suppliers located in the following countries: UK, US and France. Some suppliers source in Bangladesh, China, Germany, Honduras, Indonesia, Italy, Netherlands, Philippines, Poland, Portugal, Romania, Taiwan, Turkey and Vietnam.
- Services from suppliers located in the following countries: UK, France, US.
Products produced by Macdonald & Muir Ltd are then principally sold intra-group to Moët Hennessy UK Ltd and MHCS (a company incorporated in France), while some products are sold directly to visitors of our distilleries.
Ethics & Compliance Governance
A global compliance governance is in place at Moët Hennessy, including notably a Compliance Committee chaired by Moët Hennessy CEO, a central Ethics & Compliance Team, and a network of Ethics & Compliance correspondents. A dedicated Ethics & Compliance Correspondent has been nominated for Macdonald & Muir Ltd.
Policies & practices
Macdonald & Muir limited is committed to act with integrity in all its business dealings, to promote ethical conduct, in compliance with applicable laws and to provide guidance about business conduct.
Macdonald & Muir has implemented various policies that are relevant to that goal and which sets out what is expected from its business, employees and external suppliers:
- The Glenmorangie Suppliers’ Code of Conduct, which has been updated in 2017 following the update of the LVMH Suppliers Code of Conduct (2017), states that:
- The LVMH Group expects its Companies to establish and promote exemplary relations with all their partners, anchored in responsibility, fairness and integrity. It requires exemplary integrity from its suppliers in the conduct of their business activities
- Third party suppliers as well as their subcontractors and their own suppliers must comply with the Supplier’s Code of Conduct and abide by the principles stipulated in the Convention of the International Labor Organization, the Universal Declaration on Human Rights, the UN Global compact, the OECD guidelines for multinational enterprises and the UN women’s empowerment principles.
- Any forced labor, child labor, illegal, clandestine and undeclared employment, harassment and abuse and discrimination are prohibited. It also requires suppliers to provide safe and healthy workplace, freedom of association, regular wages in accordance with applicable laws and reasonable working hours. More generally, it requires suppliers to comply with various environmental regulations and to act with exemplary integrity in the conduct of their business activities (including but not limited to act in full compliance with the laws, notably related to the prohibition of all forms of corruption, the prevention of conflicts of interests, the prohibition of money laundering, respect of competition, trade sanctions etc.)
- Suppliers remain guarantors for work performed by their subcontractors and suppliers and guarantee respect by their subcontractors and suppliers of this Suppliers Code of Conduct and relevant obligations.
- It requires that suppliers keep proper records to prove compliance with this code of conduct and provide access to complete, original, and accurate files to check compliance with the Code’s requirements and to conduct compliance audits. Suppliers must commit to improve or correct any deficiency identified.
- Any violation by suppliers or one of their suppliers or subcontractors can result in a review and possible termination of the business relationship in accordance with applicable law, without prejudice to other rights or remedies that may be sought.
- LVMH Code of Conduct, which has been updated in 2017, in which:
- LVMH expects exemplary behavior by its employees, fully respecting the Group’s ethical commitments to act to the highest integrity standards, respect and engagement in their behavior and in the way they conduct business every day and everywhere.
- LVMH ensures that the conduct of its businesses respects individual rights and encourages the continuous improvement of social and public health conditions, which are essential to the development and protection of individual rights.
- LVMH is committed to remaining vigilant in identifying any potential direct or indirect negative impact of its activities on society in order to prevent, or if necessary, remedy any such negative impact.
- LVMH respects and promotes the Universal Declaration of Human Rights and adheres to the principles of the United Nations Global Compact, as well as to the United Nations Guidelines on Women’s Empowerment. Within its sphere of influence, LVMH supports the values, freedoms and fundamental rights promoted in these texts.
- LVMH supports its partners to establish and respect good corporate social and environmental practices and encourages their awareness of the importance of these issues. In particular, LVMH requires suppliers to comply with the ethical principles set out in the Supplier Code of Conduct.
The 2017 updated LVMH Code of conduct is available online: https://r.lvmh-static.com/uploads/2017/12/lvmh-code-of-conduct-2017_122017.pdf. The 2017 updated LVMH Suppliers Code of Conduct is available at https://r.lvmh-static.com/uploads/2008/12/lvmh-supplier-code-of-conduct_122017.pdf.
The Glenmorangie Suppliers Code of Conduct is available upon request.
Due diligence processes for slavery and human trafficking
Prior to engaging with a new Supplier, Macdonald & Muir requires suppliers to acknowledge that they will comply with the Suppliers Code of Conduct.
Macdonald & Muir:
- Reserves the right to check adherence to these principles and to conduct compliance audits at suppliers and their own supplier sand subcontractors and specifies that Suppliers shall provide the necessary information and facilitate access to representatives from the companies of Moët Hennessy Wines & Spirits who seek to verify compliance with the requirements of this code.
- requires that supplier shall keep proper records to prove compliance with the supplier’s code of conduct and provide access to complete, original and accurate records.
- requests suppliers to agree to improve and correct any deficiency discovered.
Macdonald & Muir shall use its best endeavors to ensure that template contracts to be used with suppliers include clauses requiring suppliers to adopt similar anti-slavery standards and practices.
Training and awareness
Macdonald & Muir conducts regular trainings for its employees to ensure legal and human resources compliance. Examples of in person training include but are not limited to Ethics & Compliance, Responsible consumption, competition law, safety etc.
Policies and innovative sensitization content (videos etc.) are made available on a dedicated website accessible to all Moët Hennessy employees on an intranet. New content is regularly advertised to all employees through newsletters.
Macdonald & Muir’s aim is to eliminate risk of Modern Slavery in its business operations and its supply chains.
Macdonald & Muir Ltd will ensure that this statement is reviewed and updated on an annual basis.
The Board of Directors of Macdonald & Muir has approved this statement and it has been duly signed by the Chairman of the Board of Directors.
Macdonald & Muir Limited
28 June 2019