Modern Slavery & Human Trafficking Statement

1.              Policy Statement

1.1               Modern Slavery is a crime and violation of  fundamental human rights. It can take various forms such as slavery, servitude, forced or compulsory labour and human trafficking. All of these, deprive people of their freedom, liberty security, wellbeing or health for personal or commercial gain.

1.2               We are committed to acting ethically and with integrity in all our business relationships and dealings and we have a zero-tolerance approach to modern slavery or any abuse of human rights. Our company mission statement is ‘caring enough to do the right thing’.

1.3               We are committed to ensuring transparency in our business and we are committed to preventing slavery and human trafficking in our business and in our supply chain.

1.4               We all have a responsibility to be alert to Human Rights risks. All staff are expected to report their concerns and management to act upon them promptly.

2.              About this policy

2.1               This policy is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement.

2.2               This policy covers the business activities of A E Rodda and Son Ltd and Group. We are a manufacturer of dairy products including Cornish clotted cream, bottled milk and butter. The Company operates from the U.K only, specifically at The Creamery, Scorrier, Redruth TR16 5BU.

2.3               The business supply chain includes the sourcing of raw materials for the manufacturing of our products and for product packaging.

3.              Who is responsible for this policy?

3.1               Employees are trained on the tell- tale signs of modern slavery and are expected to be vigilant of signs of human rights exploitation and to report any concerns immediately.

3.2               Managers responsibility is to act on any concerns promptly.

3.3               The Board of Directors reviews and endorses this policy statement and is fully committed to its implementation and to always operating ethically.

3.4               This Modern Slavery and Human Trafficking Statement has been approved and authorised by Managing Director, Mr Nicholas Rodda.

4.              Potentially high-risk activities

4.1               The following activities have  been identified as risks of modern slavery or human trafficking:

a)          suppliers of raw materials into the business;

b)          recruitment of agency workers through recruitment agencies or third parties.

5.              Responsibilities

5.1               Responsibility for the Company’s anti-slavery policy is as follows:

a)          Policies: the Head of People Engagement is responsible for creating and reviewing our policy. The process by which our policies are developed is to consider best practice and adapt these to the needs of the Company.

b)          Due diligence: the Executive team are responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

c)           Recruitment Agency Audits: the Head of People Engagement is responsible for ensuring that recruitment agencies if used, are audited to ensure compliance with the Company’s Ethical Trading Policy.

d)          Suppliers: it is the Planning and Procurement Manager responsibility to monitor the labour standards of new and existing suppliers.

6.              Training

6.1               To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company:

a)          requires all leaders to understanding the threat of modern slavery and  to be vigilant in spotting any signs of people exploitation in their teams;

b)          ensures that all managers responsible for directly recruiting workers are aware of issues around third-party labour exploitation and the signs to look for;

c)           provides training and information on tackling ‘Hidden Labour Exploitation’ to our workforce as a key part of induction training and with visual communications around the site;

d)          informs staff from day one of the ways in which exploitation can be reported.

7.              Operating Practises

a)          we have a zero tolerance approach to modern slavery  both in our business and in our supply chains. We inform staff from induction of the risk of modern slavery. We communicate our zero tolerance of modern slavery and people exploitation to our suppliers and business partners at the outset of our relationship with them and will terminate our relationship with them if appropriate, on an ongoing basis;

b)          the Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee;

c)           ensures that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent leaders/individuals;

d)          adopts a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and police;

e)           encourages workers to ‘whistle blow’ or report cases of hidden third-party labour exploitation, provide the means to do so and investigate and act on reports promptly;

f)            positively encourages and supports employees and agency workers to report exploitation which may be occurring within their communities;

g)           requires labour providers and companies in the labour supply chain to adopt policies and procedures consistent with the ETI base code and fair treatment of workers.

8.              Associated Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or in our supply chains. This statement affirms its intention to act ethically in all our business relationships. Our Company mission statement is ‘caring enough to do the right thing’ and we encourage all employees to act accordingly.

8.1               The following policies support us to identify modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

a)          Whistleblowing Policy – the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.

b)          Corporate Social Responsibility (CSR) Policy – The Company’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.

Ethical Policy – The Company aims to ensure universal labour standards thoughout the company and its supply chain, are in  accordance with current UK legislation & the Ethical Trading Initiative standards. We commit to communicating our ethical policy to our existing and potential customers. The company has signed up to the Ethical Trading Initiative base code, is audited by Sedex and conduct regular Sedex SAQ self- assessments.

9.              Due diligence process

9.1               The Company undertakes due diligence when considering taking on new suppliers and reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners. We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors comply with the ETI base code and with our values.

10.           Performance indicators

10.1           The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains:

a)          supplier reviews data;

b)          records of training on modern slavery;

c)           labour monitoring via HR and payroll systems;

d)          results of recruitment agency audits, if using agencies.