Modern Slavery and Human Trafficking Statement Reviewed August 2020 Version 2
Modern Slavery and Human Trafficking Statement
Introduction
The Company is required, pursuant to the Modern Slavery Act 2015, to make and publish a statement about the steps we are taking to ensure that slavery and human trafficking is not taking place in any part of our own business and in any part of our supply chains.
Modern Slavery takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Our approach and expectations of suppliers, producers and trading partners is that we have a zero-tolerance approach to any such activity.
We are committed to acting ethically and with integrity in all our business dealings and relationships and it is of fundamental importance that there is no slavery or human trafficking taking place in our own business. We will continually take steps to ensure that this is so, both in our recruitment policies and our on-going reviews.
We expect the same high standards from all of our suppliers, producers to the extent we are able, we include specific prohibitions in our contracts against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.
We expect that they will in turn hold their own suppliers to the same high standards.
Organisational Structure and Supply Chains
This statement covers the activities of Lailas Fine Foods Limited Registered at 91 Moor Park Avenue, Bispham, Blackpool FY2 0LZ, otherwise known as the organisation within this statement
The registered business manufactures chilled and frozen ready meals to the Retail and Service sectors within the UK and Europe.
Due to the nature of its manufacturing process raw materials are sourced worldwide through nominated UK suppliers.
Supply chains are assessed to determine which ones are potentially a high risk of modern slavery to those of a lower risk. Supply chains are viewed in the terms of the of the risk that people in the supply chain could be enslaved not the risk to the business.
We will have an audit spreadsheet to show a full list of those that have been assessed and those that are required to undergo an audit. When we receive information, we, as far as possible, cross-check it with independent sources and analyse the effect of that information on the risk posed by the proposed arrangement. We also identify trigger points that will lead to a review of the trading arrangement, such as changes in key personnel within a trading partner or radical changes to their pattern of business. Modern Slavery and Human Trafficking Statement Reviewed August 2020 Version 2
Responsibility
Responsibility for the organisations anti-slavery initiatives is as follows;
Policies: The formulation and review of this policy is the responsibility of the Board of Directors of the organisation. This policy and the process in which it was developed will be reviewed annually.
Risk Assessments: A team compiled of Technical/Quality Manager/ Compliance Manager/HR Manager will be responsible for modern slavery risk analysis.
Investigations/Due Diligence: H/S and Compliance Manager will be responsible for conducting investigations where allegations of suspected slavery and human trafficking are identified. The Technical Team including Compliance and Quality will ensure suppliers provide evidence of ethical and social initiatives submitted by suppliers.
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 employees, 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 organisations whistleblowing procedure is designed to make it easy for workers to make disclosures, without the fear of reprisal or suffering a detriment. The organisations employees, customers or others who have concerns can complete our confidential disclosure form.
Employee Code of Conduct: The organisations code makes clear to employees the actions and behaviours expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating outside of its manufacturing base and managing its supply chain.
Supplier Code of Conduct: The organisation is committed to ensuring that its suppliers are required 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 the use of their labour. The organisation works with suppliers to ensure they meet the standards of the code and improve their employees working conditions. However serious violations of the supplier’s code of conduct will lead to the termination of the business relationship. Suppliers are required to complete a Social and Ethical Questionnaire which highlights the organisations commitment and also the supplier’s commitment to the prevention of slavery and human trafficking.
Recruitment and Agency Workers: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency before accepting workers form that agency. All providers are Active Checked with the Gangmasters Licensing Agency and the organisation carries out its own auditing of agency providers including workers questionnaires. Modern Slavery and Human Trafficking Statement Reviewed August 2020 Version 2
Due Diligence
The organisation undertakes due diligence when considering new suppliers and regular reviews its existing suppliers. The organisations due diligence and reviews include;
- Mapping of the organisations supply chain, broadly to assess particular raw product or geographical risks of modern slavery and human trafficking.
- Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping
- Conducting supplier audits and questionnaires
- Participating in initiatives focused on human rights in general such as Stronger Together and the Ethical Trading Initiative Base Code (SEDEX)
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan including termination of the business relationship if overall evidence of improvements has not been met.
Performance Indicators
The organisation has reviewed its Key Performance Indicators in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation is:
- Requiring all Senior Managers, Department Managers and HR professionals to have completed training on Modern Slavery
- Developing and maintaining a system for supply chain verification in place since February 2013, whereby the organisation evaluates potential suppliers before they enter the supply chain
- Continually reviewing its existing supply chains
Training
This policy will be available for all colleagues and will be expected to be read and understood by all colleagues within the Board and the Commercial Team, who have responsibility for supply chains.
The organisation requires all Senior Managers, Department Managers and HR professionals to complete training on modern slavery. The organisations modern slavery training covers the following:
- How to assess the risk of slavery and human trafficking in relation to varies aspects of the business, including the 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, GLA and the “stronger together” initiative.
Modern Slavery and Human Trafficking Statement Reviewed August 2020 Version 2
Raising Awareness within the Organisation
We are members of Stronger Together. As well as training staff, the organisation has raised awareness of modern slavery issues by putting up information posters around the organisation premises. The posters explain to employees;
- 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
- What external help is available to employees for example through the Modern Slavery Helpline.
Board Approval
This statement has been approved by the organisation Board of Directors who will review and update it annually.