Modern Slavery

1.    Introduction

This statement sets out our organisations actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business and its supply chains. This statement relates to actions and activities during the financial year 1 April to 31 March.

As part of Animal by products industry and food supply chain, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

2.    Organisational structure and supply chains

The organisation is part of the Animal By-Product (ABP) industry. We specialise in the process of ABP by producing product into meals, oils and petfood ingredients, which are then exported on a global scale. Our products are utilised in a range of industries from cosmetics, biofuels, pet food, oleo chemical, agricultural and power industry.

The organisation currently operates in the following countries:

• United Kingdom
• South Africa

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

• Quality Manager and Sales Manager will complete an Onboarding process for all new

suppliers, that is known as our ’Code of Conduct’ which is reviewed by Senior Management. As part of our on-boarding process we request to see the companies policies that detail their own Modern slavery practises.

High-risk activities

The following activities are considered to be at high risk of slavery or human trafficking:

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows;

• Policies: Group HR Manager Statutory requirements for the policy understanding the remit for the statutory Once the policies have been put in place then we implement this throughout the organisation.
• Risk assessments: The process and broad organisational responsibility for human rights and modern slavery risk analysis is carried out by Senior Management and the HR Manager.
• Investigations/due diligence: Senior Manager and the HR Manager are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
• Training: An annual module is required to be completed on Modern Slavery as described in the Training section of this policy.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations :

• Whistleblowing policy The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can raise these with Senior Management or HR.
• Supplier/Procurement code of conduct The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship
• Recruitment/Agency workers policy The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. All agencies will go through an on- boarding process to ensure they meet the required standards with the Group HR

3. Due Diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

• evaluating the modern slavery and human trafficking risks of each new supplier;
• conducting supplier audits or assessments through the organisation’s own staff and third- party auditor (Sedex), which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through Sedex audit and requiring them to implement action plans.
• using Sedex, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

4.    Performance indicators

The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is:

• requiring senior managers and HR managers to have completed training on modern slavery annually;
• improving our system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain; and
• reviewing our existing supply chain, whereby the organisation evaluates all existing

5.    Training

The organisation requires all staff within the organisation to complete training on modern slavery.

The organisation’s modern slavery training covers:

• our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• what steps the organisation should take if suppliers or contractors do not implement anti- slavery policies in high-risk scenarios, including their removal from the organisation’s supply

6.    Awareness-raising programme

As well as training staff, the organisation has raised awareness of modern slavery issues by also putting up posters across the organisation’s premises and circulating a series of emails to staff.

The emails explain to staff:

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• what external help is available, for example through the Modern Slavery

7.    Version