WW Modern Slavery Act and
Human Trafficking Statements

 

Introduction

As part of the world’s leading commercial provider of Weight Management Services, operating globally through a network of Company-owned and franchise operations, our organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Our organisation is committed to preventing slavery and human trafficking in all our corporate activities, and to ensure that our supply chain reflects our values and respect for human rights.  WW fully supports efforts to combat, prohibit and prevent slavery and human trafficking.

This statement sets out the steps that WW GBR Limited took during the financial year ending December 2016 to understand all potential modern slavery risks related to its business and to put in place policies and procedures that are aimed at ensuring that there is no slavery or human trafficking in our business, or our supply chain and procurement network. 

 

Our business

We offer services and products that are built upon our weight management programme which goes beyond a singular focus on weight loss, encompassing a holistic approach to a healthier, more active, happier life. It is comprised of a range of nutritional, activity, behavioural and lifestyle tools and approaches that can be personalised based on specific member needs.

 

Approach and principles

WW recognises that there are heightened risks with complex procurement and supply chain networks and we do everything possible to ensure that there are no instances of slavery in either the manufacture or delivery of our goods.  WW has a Supplier Policy that provides that all suppliers must comply with applicable international, federal, state, provincial and local laws, rules, regulations and ordinances in connection with the design, manufacture, sale, delivery and use of their products, which includes laws regarding slavery and human trafficking.

 

Supply chain structure and activities

WW sources products, packaging and services to support our members on their weight loss journey.  We have adopted a Code of Business Conduct and Ethics for our officers, including any principal executive officer, principle financial officer, principle accounting officer or controller, and our employees and directors.  Our Code of Business Conduct and Ethics is available on our website at ww.com. These values are mirrored across the organisation and with all those we interact with both internally and externally.  WW achieves this by acting ethically, building long-standing relationships with our suppliers and implementing and enforcing effective controls to ensure slavery and human trafficking does not take place within our supply chain.

 

Due diligence

The organisation already has an established due diligence programme in those areas of the supply chain where we know there may be a heightened risk of modern slavery. We have contacted those suppliers in potentially the highest risk areas to request copies of any recent workplace or social responsibly audits completed and where no report has been completed, we will look to undertake an independent audit by a specialist third party. Moving forward we will undertake annual audits of all areas of the supply chain where we know there is a heightened risk whether or not a supplier provided audit is already in existence.

We have contacted our remaining suppliers which we have perceived as low risk due to their business location to submit a declaration on the steps they have taken both internally and in their supply chain to ensure that slavery and human trafficking is not occurring.  The Supplier Policy also provides that all suppliers are required to allow WW representatives access to their manufacturing and storage facilities when a WW product is being manufactured or stored and moving forward we will look to put in a programme of random visits.

 

WW policies and code of conduct

WW operates an all-encompassing set of policies which sets out clear expectations as to the conduct and behaviour of all our employees, managers and consultants with a view to promote an ethical company culture which extends to identifying any modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. This is underpinned by key company policies and procedures including:

  • Code of Conduct and Ethics Policy
  • Anti-Corruption Policy
  • Supplier/Procurement Code of Conduct 

WW recognises the importance of strengthening our policies to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains and as a result throughout 2017/18, will be reviewing the training provided across the organisation to enable employees to:

  • Assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
  • Identify the signs of slavery and human trafficking.
  • Explain what initial steps should be taken if slavery or human trafficking is suspected.
  • Know how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation.
  • Understand what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies.

WW is committed to driving awareness of the issues of modern slavery and human trafficking within its operations and would invite any comments or questions about our statement at marketing@weight-watchers.co.uk

 

Corinne Pollier 

President – WW International 
October 17