Slavery and Human Trafficking Statement

MODERN SLAVERY ACT 2015

SLAVERY AND HUMAN TRAFFICKING STATEMENT

This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It sets out the steps that Vestey Holdings Limited and its subsidiaries have taken during the year ending 31 December 2021, and continue to take, to prevent modern slavery and human trafficking in its business and supply chain. See Appendix A for the UK subsidiary companies covered by this statement.

INTRODUCTION

We know that Modern Slavery is a growing and global issue, and that no sector or industry can be considered immune or untainted.  Vestey has a zero-tolerance approach to any form of modern slavery.  We are committed to acting in an ethical manner, with integrity and transparency in all business dealings. We are committed to creating effective systems and having controls in place to safeguard against any form of slavery taking place within the business or our supply chain.

 

We accept that we all have a responsibility to be alert to the risks, however small, in our business and the wider supply chain. Staff are expected to report concerns and managers are expected to act on them and take appropriate actions.

 

This statement sets out our actions to understand all potential Modern Slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking within our business and our supply chains.

OUR BUSINESS & SUPPLY CHAINS

Vestey specialises in the sourcing, processing and distribution of chilled, ambient and frozen products in the meat, fish, seafood, dairy, fruit, vegetables, specialist meal, and fine foods categories. The Group also has two pension advisory businesses.

 

Our headquarters are in Coulsdon, United Kingdom and we operate in various countries around the world and have offices in the UK, France, Denmark, Belgium, Lithuania, Spain, Poland, Dubai, Oman, the Philippines, the USA and China. We build long-term partnerships with suppliers and customers alike, and supply products for retail, foodservice, wholesale, hotels and restaurants, governments and manufacturing customers as well as directly to consumers.

 

Vestey had a global turnover in 2021 of £496m and has over 1,047 employees worldwide. In last 12 months there have been no major changes to our business or operational structures which affect our Modern Slavery compliance.

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.

 

Vestey operate a number of policies at individual subsidiary company level, such as: Procurement, Corporate Social responsibility (CSR), Ethics, Anti-Bribery, Corporate Gift, Environmental and Health and Safety policies. These are all are signed off at company director level.

 

The CSR Policy states that we will not tolerate or condone abuse of Human Rights or Modern Slavery within any part of our business or supply chain, and will take seriously any allegations that Human Rights are not properly respected. All reports will be investigated, and appropriate remedial action will be taken.

 

We have strengthened our standard supplier contractual terms, this sets out the standards required of our suppliers and adds extra due diligence to ensure compliance to the Modern Slavery Act.

 

We maintain rigid supplier approval programs to validate that all our suppliers and service providers meet our criteria before they can be classed as ‘Approved’. Specifically, third party certification and risk based Vestey audits are fundamental in ensuring products conform to local legislation, whilst also assessing our suppliers’ suitability.



In accordance with our recruitment policy, 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.

 

Vestey Holdings and its subsidiaries have introduced a whistleblowing policy. This ensures all employees know they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

 

Every company adheres to the Group’s 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.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

Vestey have strong technical and procurement teams in each Group company supporting all aspects of our business. Our trained technical auditors are highly qualified with many years’ experience, and conduct risk based second party audits, as required.

 

We understand that our biggest exposure to Modern Slavery is in our product supply chains, and therefore we are focusing our effort here. All our suppliers are subject to pre-approval and this is, amongst other things, will help to identify any modern slavery practices. If issues are identified, appropriate investigative and remedial actions will be taken.

 

Audits are conducted with many suppliers and include the verification of modern slavery.  Suppliers are required to: 

 

  • Participate in audits;
  • Provide employees with good working conditions, fair treatment and reasonable rates of pay; and
  • Respect workers’ Human Rights and comply fully with all applicable laws.

 

In person audit visits were again restricted in 2021 due to COVID, however these are expected to resume where appropriate in 2022. 

 

All of which is designed to ensure that: 

 

  • All work is voluntary, and not done under any threat of penalties or sanctions;
  • Workers have not paid any deposits for work, and employers have not kept original copies of identity documents; and
  • Workers are free to leave work at any time, with all salary that is owed paid.

 

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that: 

 

  • they comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force but not limited to the Modern Slavery Act 2015;
  • and maintain throughout the term of this agreement their own policies and procedures to ensure compliance;
  • they will not engage in any activity, practice or conduct that would constitute an offence under sections 1, 2 or 4, of the Modern Slavery Act 2015 if such activity, practice or conduct were carried out in the UK; and
  • they will ensure that each of their subcontractors and suppliers shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015.

TRAINING

To ensure a level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide appropriate instructions to our commercial, technical and procurement teams.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We aim to frequently assess our Anti-Slavery policy to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.


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

There were no instances of slavery or human trafficking reported in 2021.

 

We will continue to review the effectiveness of the steps we have taken in prior years and to ensure that there is no slavery or human trafficking in our supply chains we will carry on with the following steps to combat slavery and human trafficking in 2022:

 

  • Continue to review best practice modern slavery and other related policies that are in place in individual subsidiary companies to ensure that they are up to date and continue to be introduced into all Group companies
  • Continue to formally seek confirmation from suppliers that they are following anti-slavery and human trafficking laws
  • Continue to raise awareness internally of the issues surrounding Modern Slavery and provide appropriate instructions to all employees.

This statement was approved by the Board of Vestey Holdings Limited.

Signed

 

George Vestey Signature

George Vestey
Chief Executive Officer

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