Modern Slavery Statement

Tax Strategy Report 2021

Defined Benefit Pension Scheme:

Statement of Investment Principles (“SIP”) Report

Implementation Report 2021

Privacy Notice 2021

Gender Pay Gap Report



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 policy and expectations of ourselves and our 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 throughout our supply chain.

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.

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.

Colleague Training and Responsibilities

Our policy is available for all Colleagues and is expected to be read and understood by all Colleagues within the Board, Executive, Commercial and Operational Teams, who have responsibility for any aspect of our supply chain.

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. Colleagues are required to avoid any activity that might lead to, or suggest, a breach of this policy. Colleagues must notify a member of the Board or Executive Team 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 such a conflict. All colleagues 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 colleague who breaches this policy will face 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 a small business as such we can identify any evidence of this quickly and deal with it in a timely manner.

We trade with a wide range of different producers, suppliers and carriers, many outside the UK.

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

Supplier Contracts

We are committed to not using unethical suppliers and through the use of our Supplier Approval Questionnaire we continue to ensure that we are following our high standards when working with Suppliers and to ensure that their standards meet ours.

We are committed to producing 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. EH Booths Code of Practice 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 Human Trafficking and Slavery 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 Human Trafficking and Slavery.

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 and we challenge if required to ensure the highest level of standards are maintained.

We remain committed to risk assessing all Booths Brand suppliers and through the use of our audit processes can show a full list of those that have been assessed and those that are required to undergo an audit. We 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.

At one of our manufacturing sites, for the fourth year running we continue to be proud members of SEDEX, a global membership organisation to support us in managing our performance on labour rights, health & safety, the environment and business ethics.

Recommendations for the continued development of our policies, detailed in our 2020 report included; the re-categorisation of suppliers within Booths Branded products to identify higher risk suppliers easier and to create three severity levels for ethical based risks within the supply chain. This commitment has been fulfilled and will continue to be reviewed.

In addition a risk rating system has been created which covers all aspects of food safety, quality and ethical trading. All of our suppliers, producers and trading partners are now being audited through this new process.

Covid 19

Due to the 2020 pandemic, it has been necessary to complete a number of audits remotely, this will be reviewed in due course and visits will commence as soon as it is safe to do so.

Future Plans and Targets

Modern Slavery training opportunities continue to be evaluated with a view to having a number of colleagues across our Trading, Manufacturing, Booths Brand and Technical Teams who are fully trained and able to maintain our high standards.

Our intention for 2021 is to increase external business to business relationships by extending Booths’ multi-channel offer. In achieving this we will thoroughly assess every opportunity, ensuring we maintain high ethical standards with regard to this statement.