Slavery and Human Trafficking Statement


Introduction

The Modern Slavery Act 2015 (“the Act”) came into effect on 29th October 2015. This statement, as required under the Act, sets out the steps Donald Russell Limited, is taking to reduce the risk of slavery and human trafficking taking place in its supply chains or in any part of its business.

Modern slavery is a crime and a violation of fundamental human rights. It 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.

We have a zero tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships; and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

Our Business

Donald Russell produces and sources gourmet meat and food products. These are then sold through our “Direct to Consumer” business, through our hotel and restaurant trade business in the UK, and exported to wholesalers and retailers abroad in both frozen and fresh formats.

We build long-term partnerships with customers and suppliers alike.

Donald Russell had a turnover of £35million and employed 251 employees in 2016.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking

We operate several internal policies and procedures to ensure that we are conducting business in an ethical and transparent manner.

We have introduced an Anti-Slavery and Human Trafficking Policy setting out our stance on modern slavery and explaining what employees should do should they identify instances of modern slavery.

We have also introduced a Whistleblowing Policy to ensure that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisal.

Donald Russell have in place an Ethics Policy which sets out how we conduct ourselves as an organisation, and how we behave when dealing with customers and suppliers. This sets out that adherence to Human Rights issues is a key consideration when considering a business partner.

As part of our recruitment process we conduct Eligibility To Work in the UK checks for all employees to safeguard against Human Trafficking or individuals being forced to work against their will.

Supplier adherence to our values and ethics

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with our values and ethics. To this end we have the following measures in place:

    • We obtain confirmation from our key or high risk suppliers that they have policies and procedures in place around slavery and human trafficking and obtain copies of statements where available.

  • We have systems in place to encourage the reporting of concerns and the protection of whistleblowers.

Training

To ensure a high level of understanding of the risks of slavery and human trafficking in our supply chains and our business, we provide training to those staff involved in procurement and/or with responsibility for our supply chain management.

Our effectiveness in combating slavery and human trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

For the year ended 31st December 2016 we have received confirmation from 65 suppliers of their compliance with anti-slavery and human trafficking laws.

If we discover a violation of our Anti-Slavery Policy we will respond in a manner proportionate to the nature and extent of the violation. Serious violations will require immediate and decisive action and may result in the termination of the business relationship.

For less serious violations, we will allow the supplier reasonable time to develop and implement a plan for remediation. We will treat termination as a last resort as it is unlikely to resolve the underlying issue and it may be detrimental to those people who rely on the work to survive.

Further Steps

Following a review of the effectiveness of the steps we have taken in 2016 to ensure that there is no slavery or human trafficking in our supply chains, we intend to take the following further steps to combat slavery and human trafficking during 2017:

Supplier Code of Conduct Policy:
Consider the introduction of a supplier code of conduct policy to supplement and strengthen the existing declarations made by our suppliers.

Board Confirmation

This statement was approved by the Board of Donald Russell Limited

Tazio Gagliardi, Managing Director

Tazio Gagliardi
Managing Director
26th April 2017