Modern Slavery Statement

Definition

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 hiring systems and policies and our on-going reviews.

We expect the same high standards from all of our suppliers, producers and trading partners, and 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.

Company Expectations

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 can take various forms, including 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. Needless to say, we have a zero-tolerance approach to any such activity and we are committed to acting ethically and with integrity in all our business dealings and relationships.

Employee Training and Responsibilities

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 prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. Employees must notify a member of the Board as soon as possible if they believe or suspect, or have concerns, that a conflict with this policy has occurred, or may occur in the future, even if they are unsure about whether a particular act, or any treatment of workers or their working conditions, might constitute it. They are encouraged to raise concerns about any issue or suspicion of modern slavery or human trafficking in any part of our business or supply chain.

Consequences of Non-Compliance

Any employee who breaches this policy faces disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

We are confident that, in our own business, there is no slavery or human trafficking taking place. Our internal systems, controls and hiring policies are sufficiently strong and robust to ensure this. We are also a small enough business that any evidence of this would be quickly spotted and dealt with. We do, of course, trade with a wide range of different producers, suppliers and carriers, most outside the UK.

We always try and ensure that all of these are reputable and carry on business to the same high standard as we do ourselves. We actively encourage them to do so. Our relationships, particularly with producers, often go back many, many years. We are in regular contact with them.

Supplier Contracts

We will produce suitable contract provisions, which we are intending, to the extent we are able, to include in all our contracts with producers, suppliers and contractors. These require the other party to ensure that no slavery or human trafficking is taking place in its business. EHB Code of Practice (COP) for the Supply of products will include an ethical clause, requesting that suppliers must adhere to local and national legislation with respect to terms and conditions of employment, and an appropriate HTS clause Assessment and audits.

We have a programme of regular contact with our suppliers, producers and trading partners and it is part of that programme to informally check, as far as possible, that they are similarly committed to good practices in relation to their the workforce and contractors, including reference to HTS.

In addition, our most significant suppliers, producers and trading partners are independently assessed to identify the degree of risk in trading with each of them and more formal audits are conducted as appropriate (a long-established and trusted partner probably needs fewer checks and less frequent reviews than a new or proposed partner).

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.

Also, as part of our Slavery and Human Trafficking Policy, all our staff will be encouraged to be aware of the possibility of slavery and human trafficking taking place and must notify one of the Board as soon as possible if they believe or suspect, or have concerns, that slavery or human trafficking might be taking place in any part of our supply chain, even if they are unsure about whether a particular act, or any treatment of workers or their working conditions, might constitute it. Any such concerns will be investigated. We believe this policy is appropriate for the Company.

Future Plans and Targets

We have recently completed a review of our policies and procedures relating to Modern Slavery in conjunction with Lancaster University Management School (LUMS). This report has set out several recommendations for the continued development of our policies, which include:

  1. Re-Categorisation of suppliers within Booths Branded products to identify higher risk suppliers easier.
  2. Create three severity levels for ethical based risks within the supply chain.

Any recommendations from this report carried forward will aim to be delivered by April 2018.