Whyte & Mackay Ltd prohibits the offering, giving, solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever in the world they are situated and whether they are a public official or body or private person or company.
This Policy applies to any act of any individual employee, agent or other person or body acting on the Company's behalf whereby the aim is to gain any commercial, contractual or regulatory advantage for the Company in a way that is improper or unethical in respect of the relevant countries’ laws or those of the UK, or if the objective of the act is to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
This Policy applies to all permanent and temporary employees of the Company (including any of its intermediaries, subsidiaries or associated companies).
It also applies to any individual or corporate entity associated with the Company or who performs functions in relation to, or for and on behalf of, the Company (“associated persons”).
All employees and associated persons are expected to adhere to the principles set out in this Policy.
Failure to comply with the policy will result in disciplinary proceedings against employees, and potentially could result in legal action against the employee(s) and / or associated persons.
We respect the right of adults to choose whether or not to consume alcohol as an acceptable and enjoyable way to celebrate and relax. We believe that, when consumed in moderation, alcohol can be part of a balanced lifestyle.
We recognise, however, that the misuse of alcohol can cause serious problems for individuals, communities, and society at large. We are supporters of the Portman Group and Drinkaware Trust. We seek to provide consumers with the information they need to make an informed choice about drinking or not drinking, and, if they do drink, to drink responsibly.
ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT
The following statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Whyte and Mackay Group Limited’s slavery and human trafficking statement for the financial year ending 31 December 2017.
Whyte and Mackay Group Limited, a company registered in Scotland (SC221954), is a global spirits company producing and distributing some of the most highly-awarded and respected whisky and spirit brands. We are the fifth largest Scotch whisky manufacturer in the world, with products distributed in over 50 countries.
Whyte and Mackay operates in the heart of Glasgow where we have been for over 170 years. The company employs over 480 people across the world, and owns 5 distilleries and a state of the art bottling plant.
Whyte and Mackay is a wholly owned subsidiary of Emperador UK Limited which in turn is wholly owned by Philippines based Emperador Inc.
The Chief Executive Officer and Executive Team are responsible for ensuring the statement is up to date and accurately reflects the Company’s actions and initiatives to tackle slavery and human trafficking.
HR are responsible for introducing policies and reviewing the process by which they are adopted.
All employees are encouraged to report any concerns they may have and management are required to act upon them with appropriate urgency.
Whyte and Mackay is committed to ensuring there is no modern slavery or human trafficking within its supply chains or in any part of its business. We strive to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place within any of our supply chains.
Whyte and Mackay will not knowingly support or deal with any business or organisation involved in slavery or human trafficking. We have undertaken a risk assessment of our global supply chains, identifying where they extend into sectors and territories that are higher risk in terms of the potential presence of slavery and human trafficking. As part of our on-going due diligence we continually seek to identify any possible risks in these areas and take appropriate corrective action.
When recruiting we adopt good practice approaches to identification and reference checking and as standard we require our agency providers to do likewise.
We ensure that the requirements of the Modern Slavery Act 2015 are reflected within our policies and procedures. We operate the following compliance policies: Preventing Hidden Labour Exploitation, Whistleblowing, Anti- Corruption & Bribery Policy, Bullying and Harassment.
Training and Awareness
A key part of Whyte and Mackay’s modern slavery and human trafficking risk mitigation strategy is to promote a high level of understanding and awareness of the risks through training and employee communication.
We provide training to senior management and members of our Supply Chain, Procurement and HR Teams, to ensure they understand the risks and on how to report any concerns. We support the Stronger Together UK initiative and intend to use the materials related to this to further promote awareness across all our employees.
Whyte and Mackay does not have designated key performance indicators against slavery and human trafficking. However we will continue to monitor the effectiveness of our compliance regime and take necessary steps to strengthen it as appropriate.
Whyte and Mackay’s approach to tax
Whyte and Mackay’s approach to conducting its tax affairs and dealing with tax risk is approved by our Treasury, Risk and Capital Committee. It applies to Whyte and Mackay Limited and the entities listed below for the financial year ended 31 December 2018 and its publication is regarded as complying with our duty under paragraph 19(2) Schedule 19 to the Finance Act 2016 for that year.
Entities in the UK tax group include:
- Emperador Holding (GB) Limited
- Emperador UK Limited
- Whyte and Mackay Group Limited
- Whyte and Mackay Limited
- Whyte and Mackay Warehousing Limited
Our approach to tax is aligned to that of our ultimate parent company Alliance Global Group, Inc.
Our business activities generate a substantial amount and variety of taxes, including but not limited to, corporation tax, employment taxes, and indirect taxes such as excise duty and VAT.
Whyte and Mackay is committed to complying with tax laws in a responsible manner and to having an open and constructive relationship with tax authorities.
Our approach to tax is underlined by the following principles:
We engage in efficient tax planning that supports our business and reflects commercial and economic activity.
We adhere to relevant tax laws and we seek to minimise the risk of uncertainty and disputes.
Whyte and Mackay will use incentives and reliefs to optimise tax costs of conducting its business activities, but will not use them for purposes which are knowingly contradictory to the intent of the legislation.
Relationship with HMRC
Whyte and Mackay is committed to the principles of openness and transparency in its approach to dealing with HMRC. All dealings are conducted in a collaborative, courteous and timely manner. The aim would be to strive for early agreement on uncertain matters to achieve clarity.
Tax is part of the Finance Function of our Group and is the ultimate responsibility of our Chief Financial Officer.
Our approach to tax and tax status is reviewed regularly by our Treasury, Risk and Capital Committee chaired by our Chief Executive Officer. Tax issues are assessed on a case by case basis by our CFO obtaining external advice where necessary. There are clear management responsibilities, backed up by regular monitoring and review including internal audit programs.
Day to day tax matters are delegated to the Head of Financial Control and a team of in-house professionals who hold a combination of tax and accounting qualifications and experience.
Tax risk management
We manage tax risks in such a way as to ensure that key risk areas are monitored and material risks minimised.
Diligent professional care and judgement is always employed to assess tax risks in order to arrive at well-reasoned conclusions on how tax risks should be managed. Where there is uncertainty as to the application or interpretation of tax law, appropriate advice, evidencing the facts, risks and conclusions may be taken from third party advisors to support the decision making process.
GENDER PAY REPORT
At Whyte & Mackay we aim to attract and retain broad and diverse talent and have an inclusive culture which we live through our vision and our values. We are confident men and women are paid the same for equivalent roles at all our sites.
The gender pay gap is the difference between the hourly pay of women versus men, calculated as an average across the workforce as a whole. The report shows that we have a gender pay gap in the UK and this gap is largely due to two factors:
We have fewer women in the most senior positions including the Executive Team. As senior roles pay more than more junior roles, the fewer the number of women who hold senior roles in a company, the greater is the average gender pay gap. This is more pronounced in our manufacturing sites where the majority of senior roles are held by men. This reflects the demographics of the broader manufacturing industry: low turnover/high continuous service; and a high number of technical and shift based roles which attract a premium.
Variable pay also influenced our overall pay gap. All our employees participate in a bonus if the Company meets its targets. However, the management incentive plan, paid to senior roles where the majority are currently men, contributes to the reported gap on bonus.
What are we doing about it?
We are reviewing our leadership development programmes to ensure they support all our employees and we will actively provide our line managers with guidance on making decisions that are free from unconscious gender bias.
We will constantly review our approach to recruitment and reward, including variable pay, to ensure again that they are free from unconscious gender bias.
We are committed to building an inclusive working environment to accelerate the growth and success of our business and recognise the value of different perspectives and experiences which are key to our continued success.
We take a line of our female employees and position them from lowest hourly rate to the highest hourly rate. We do the same for the male employees. We then take the middle female in the line and the middle male in the line and compare their actual hourly rate and actual bonus payments.
This shows our female hourly rate was 20.77% lower than the male hourly rate and the female bonus pay was 36.32% lower than the male bonus payment.
We take the same line of female and male employees but this time we add up all the hourly rates and bonus payments for each and then divide by the number in the line to get the average or mean.
This shows our female hourly rate was 24.96% lower than the male hourly rate and the female bonus payment was 64.15% lower than the male bonus payment: 92.02% of our female employees and 92.51% of men received a bonus payment.
We now add up the number of female employees and male employees at each level of the organisation. To do this we make a list of all our employees’ hourly rate from highest to lowest. We then divide into 4 equal groups and count how many female employees and male employees are in each group.
This shows the top 25% hourly rates in the Company is made up of 71.3% men and 28.7% women. The next 25% is made up of 77.12% men and 22.88% women. The third 25% is made up of 67.8% men and 32.2% women with the last 25% made up of 46.09% men and 53.91% women.
Global HR Director
4 April 2018