PremCom UK Ltd – Financial Year 2024/2025

Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that PremCom UK Ltd (PremCom) has taken, and continues to take, to ensure that modern slavery and human trafficking is not taking place in our business operations or supply chains.

PremCom recognises that modern slavery is a grave violation of human rights. We are committed to acting ethically, with integrity and transparency in all our business dealings, and to implementing effective systems and controls to safeguard against any form of modern slavery taking place within our business or supply chain. While our annual turnover is below the £36 million threshold that legally requires a modern slavery statement, we have chosen to publish this statement voluntarily. This demonstrates our commitment to ethical business practices and our determination to ensure transparency in our operations and supply chains.

About PremCom

PremCom is an established commercial printing and direct mail company based in Peterborough, Cambridgeshire. We have been operating for over 25 years, providing high-quality print and marketing communication services to clients across the UK.


Our Key Details
• Location: 1b Centurion Business Park, Sturrock Way, Peterborough, PE3 8YF
• Workforce: Approximately 15 employees
• Established: 1999
• Sector: Commercial printing, direct mail, and marketing communications

Our Services
We provide a comprehensive range of printing and communication services, including:


• Digital Printing: Full-colour printing across all formats
• Direct Mail Services: Print production, data processing, and fulfilment
• Variable Data Printing: Personalised marketing materials
• Multi-Channel Marketing Materials: Integrated campaign production
• Online Ordering Systems: Web-to-print solutions for clients
• Data Management: Secure data processing and management
• Delivery Services: Nationwide distribution

Our Supply Chain Structure
As a commercial printing company, our supply chain includes:


Primary Supply Chain (Materials and Services):

  1. Paper and Board Suppliers: UK-based suppliers sourcing from European FSC-certified sustainable forests
  2. Printing Equipment and Consumables: Ink, toner, and printing machinery maintenance from established UK and European suppliers
  3. Printing Equipment Manufacturers: Major international brands with UK service operations
  4. Packaging Materials: UK suppliers for protective packaging and mailing materials

Secondary Supply Chain (Supporting Services):

  1. Direct Mail Services: Royal Mail and courier services for distribution
  2. Facilities Management: Cleaning, maintenance, and utilities
  3. IT Services: Software, hardware, and technical support
  4. Professional Services: Legal, accounting, and business consultancy

Labour Supply Chain:

  1. Direct Employment: All permanent staff recruited directly through our HR processes
  2. Temporary Labour: Occasional use of local recruitment agencies for peak periods
  3. Subcontractors: Specialist print finishing services when required

Our supply chain is predominantly UK-based, with some materials sourced from established European suppliers. We maintain long-term relationships with our key suppliers, which enables us to conduct effective due diligence and maintain high ethical standards.

Our Policies in Relation to Modern Slavery

We have implemented robust policies and procedures to ensure that modern slavery and human trafficking does not occur in our business or supply chains. Our approach is guided by international standards including the UN Guiding Principles on Business and Human Rights and ILO Labour Standards.

Employment and Recruitment Policy

Our recruitment practices are designed to prevent exploitation and ensure fair treatment of all workers:

  • Right to Work Checks: We conduct thorough eligibility to work in the UK checks for all employees
  • Direct Recruitment: All permanent staff are recruited directly by PremCom, eliminating intermediary fees
  • No Worker-Paid Fees: We adhere to the “Employer Pays Principle” – workers never pay recruitment fees
  • Fair Contracts: All employees receive clear, written contracts in English detailing their rights, responsibilities, and terms of employment
  • Competitive Pay: We pay above the National Living Wage and comply with all UK employment legislation
  • Freedom to Terminate: Employees have the right to terminate their employment with appropriate notice
  • Document Retention: We never confiscate or withhold workers’ identification documents

Supplier Code of Conduct

We expect all our suppliers to:

  • Comply with the Modern Slavery Act 2015 and all applicable laws
  • Treat workers with dignity and respect
  • Provide safe and healthy working conditions
  • Pay fair wages and benefits in accordance with local laws
  • Prohibit forced labour, child labour, and human trafficking
  • Allow freedom of association and collective bargaining
  • Maintain transparent and ethical recruitment practices
  • Implement their own due diligence processes to prevent modern slavery

Whistleblowing and Reporting

We have established clear channels for reporting concerns:

  • Open Door Policy: Employees can raise concerns directly with management
  • Confidential Reporting: Anonymous reporting mechanisms are available
  • No Retaliation: We protect whistleblowers from any form of retaliation
  • External Reporting: Information on how to report concerns to external authorities is provided to all staff

Responsible Purchasing Practices

We recognise that our purchasing practices can impact working conditions in our supply chain:

  • Fair Pricing: We ensure our pricing allows suppliers to maintain ethical labour practices
  • Reasonable Lead Times: We provide adequate time for order fulfilment
  • Stable Relationships: We maintain long-term partnerships with key suppliers
  • Prompt Payment: We adhere to agreed payment terms
  • Clear Specifications: We provide accurate technical specifications to avoid last-minute changes

Assessing and Managing Risk

Our Risk Assessment Approach

We conduct regular risk assessments to identify and evaluate modern slavery risks in our operations and supply chains. Our assessment considers:

  • Geographic Risk: Countries and regions where suppliers operate
  • Sector Risk: Industries known to have higher modern slavery risks
  • Product Risk: Specific materials or services with elevated risk
  • Business Model Risk: Use of labour agencies, subcontracting, or complex supply chains
  • Worker Vulnerability: Presence of migrant workers, low-skilled workers, or other vulnerable groups

Identified Risks in Our Supply Chain

Through our risk assessment, we have identified the following areas requiring particular attention:

1. Paper and Board Supply Chain

  • Risk Level: Low to Medium
  • Description: While our direct suppliers are UK-based, paper originates from European forests. The forestry and paper manufacturing sectors can involve risks related to migrant labour
  • Mitigation: We source from FSC-certified suppliers who maintain ethical labour standards. We request evidence of their modern slavery due diligence

2. Printing Equipment and Consumables

  • Risk Level: Low to Medium
  • Description: Manufacturing of printing equipment and consumables may involve complex global supply chains, particularly in electronics and chemical production
  • Mitigation: We work with established, reputable brands with published modern slavery statements. We prioritise suppliers with strong ethical commitments

3. Temporary Labour

  • Risk Level: Low
  • Description: Use of recruitment agencies can present risks if agencies charge workers fees or exploit vulnerable workers
  • Mitigation: We use only established UK recruitment agencies and verify their compliance with employment law. We ensure workers are paid directly and fairly

4. Cleaning and Facilities Services

  • Risk Level: Low
  • Description: Cleaning and facilities management sectors have documented risks of worker exploitation
  • Mitigation: We conduct due diligence on service providers and maintain direct oversight of working conditions on our premises

Risk Management Actions

To manage identified risks, we:

  • 1. Prioritise High-Risk Suppliers: Focus due diligence efforts on suppliers in higher-risk categories
  • 2. Supplier Engagement: Communicate our expectations and requirements to all suppliers
  • 3. Contract Terms: Include modern slavery clauses in supplier contracts
  • 4. Regular Reviews: Conduct annual reviews of our supply chain risks
  • 5. Continuous Monitoring: Stay informed about emerging risks in our sectors and supply chains

Due Diligence Processes

Supplier Due Diligence

We implement a structured approach to supplier due diligence:

Pre-Qualification:

  • Assessment of supplier’s modern slavery policies and practices
  • Review of supplier’s own modern slavery statement (where applicable)
  • Verification of supplier’s compliance with relevant legislation
  • Assessment of supplier’s recruitment and employment practices

Ongoing Monitoring:

  • Regular communication with key suppliers about labour standards
  • Review of any changes in supplier operations or ownership
  • Monitoring of supplier performance and any reported concerns
  • Annual review of supplier risk profiles

Supplier Questionnaires:

  • We request information from suppliers about their approach to preventing modern slavery
  • Questions cover policies, risk assessment, training, and grievance mechanisms
  • Responses inform our risk assessment and engagement priorities

Internal Due Diligence

Within our own operations, we:

  • Regular HR Audits: Review employment practices, contracts, and working conditions
  • Staff Interviews: Conduct confidential discussions with employees about their working conditions
  • Workplace Inspections: Ensure safe, healthy working environments
  • Document Verification: Maintain accurate records of right-to-work checks and employment terms
  • Pay Audits: Verify that all workers receive at least the National Living Wage

Remediation and Corrective Action

If we identify or are made aware of modern slavery in our operations or supply chains, we are committed to:

1. Immediate Action: Take swift steps to protect affected individuals

2. Investigation: Conduct thorough investigation of the circumstances

3. Remediation: Work with relevant parties to provide appropriate remedy to victims

4. Corrective Action: Implement measures to prevent recurrence

5. Reporting: Report serious cases to relevant authorities as required by law

6. Transparency: Disclose incidents and our response in future statements

We recognise that responsible exit from supplier relationships should be a last resort, undertaken only when all other measures have been exhausted and when it will not cause further harm to workers.

Training and Awareness

Staff Training

We provide training to relevant staff members to ensure they understand modern slavery risks and can identify potential indicators:

Training Coverage:

  • What modern slavery is and how it manifests in business contexts
  • Indicators of modern slavery and human trafficking
  • Our policies and procedures related to modern slavery
  • How to report concerns or suspicions
  • The importance of ethical supply chain management

Training Audience:

  • Management team (comprehensive training)
  • Procurement and purchasing staff (focused on supply chain risks)
  • HR personnel (focused on recruitment and employment practices)
  • All staff (general awareness)

Training Frequency:

  • Initial training for all new employees
  • Annual refresher training for all staff
  • Specific training when policies or procedures are updated

Supplier Engagement and Capacity Building

We engage with our suppliers to raise awareness and build capacity:

  • Share our modern slavery expectations and requirements
  • Provide guidance on conducting risk assessments
  • Offer support in developing appropriate policies and procedures
  • Encourage suppliers to cascade requirements through their own supply chains

Measuring Effectiveness

We assess the effectiveness of our approach to preventing modern slavery through:

Key Performance Indicators

1. Supplier Compliance:

  • Percentage of key suppliers with modern slavery policies in place
  • Percentage of suppliers who have completed our due diligence questionnaire
  • Number of supplier contracts including modern slavery clauses

2. Training and Awareness:

  • Percentage of staff who have completed modern slavery training
  • Number of training sessions delivered annually
  • Staff awareness levels (assessed through surveys or discussions)

3. Risk Management:

  • Number of supply chain risk assessments completed
  • Number of high-risk suppliers identified and engaged
  • Progress in addressing identified risks

4. Reporting and Response:

  • Number of concerns raised through reporting mechanisms
  • Response time to reported concerns
  • Number of investigations conducted and outcomes

Continuous Improvement

We are committed to continuously improving our approach to preventing modern slavery:

2024/2025 Achievements:

  • Developed and published our first comprehensive modern slavery statement
  • Conducted initial supply chain risk assessment
  • Implemented supplier due diligence questionnaire
  • Provided modern slavery awareness training to all staff
  • Included modern slavery clauses in new supplier contracts

2025/2026 Priorities:

  • Expand supplier engagement programme to include capacity building
  • Conduct deeper due diligence on identified higher-risk suppliers
  • Enhance our grievance mechanisms to ensure accessibility
  • Develop more detailed KPIs to track effectiveness
  • Engage with industry initiatives to share best practices

Governance and Accountability

Board Responsibility

The Board of Directors has overall responsibility for ensuring this statement complies with our legal and ethical obligations. The Board:

  • Reviews and approves this statement annually
  • Oversees the implementation of our modern slavery policies
  • Ensures adequate resources are allocated to prevent modern slavery
  • Receives regular reports on modern slavery risks and actions

Management Responsibility

Day-to-day responsibility for implementing our modern slavery policies rests with our senior management team, who:

  • Conduct risk assessments and due diligence
  • Engage with suppliers on modern slavery issues
  • Deliver training and raise awareness
  • Monitor compliance and effectiveness
  • Report to the Board on progress and challenges

Stakeholder Engagement

We recognise that tackling modern slavery requires collaboration. We engage with:

  • Suppliers: To understand their practices and support improvement
  • Industry Bodies: To share best practices and learn from others
  • Professional Advisors: For expert guidance on complex issues
  • Government Agencies: To stay informed of regulatory requirements and guidance

Our Commitment

PremCom is committed to:

  • Zero Tolerance: Maintaining a zero-tolerance approach to modern slavery and human trafficking
  • Continuous Improvement: Regularly reviewing and enhancing our policies and practices
  • Transparency: Being open about our approach, challenges, and progress
  • Collaboration: Working with suppliers, industry peers, and stakeholders to drive positive change
  • Accountability: Taking responsibility for our operations and supply chains

We recognise that preventing modern slavery is an ongoing journey requiring sustained effort, vigilance, and adaptation. We are committed to playing our part in eradicating this crime from our industry and supply chains.

Statement Approval

This statement has been approved by the Board of Directors of PremCom UK Ltd and will be reviewed and updated annually.

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Contact Information

For questions about this statement or to report concerns related to modern slavery, please contact:

PremCom UK Ltd

1b Centurion Business Park Sturrock Way Peterborough PE3 8YF

Phone: +44 1733 340400

Email: sales@premcom.co.uk

Website: https://premcom.co.uk

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