Modern Slavery Statement

Introduction

Whitworths Ltd is committed to driving out acts of modern day slavery from within our business and supply chains. We acknowledge our responsibility under the Modern Slavery Act 2015 (Act) and work to ensure transparency within our organisation and with suppliers of goods and service to us.

We will not associate with any business that is knowingly in breach of the Act and its expectations or which we know is engaged in slavery or human trafficking.

Organisation’s structure

We are a privately-owned business that mixes, packs, processes and transports dried fruit, nuts, seeds, beans and pulses to our customers.  Our supply chain includes relationships with external business for the sourcing of products and several of these suppliers are based outside of the United Kingdom. Our 2018 financial year ran from 31 December 2017 to 29 December 2018.

The site in Irthlingborough, where the head offices are based, consists of 5 manufacturing plants and 5 warehouses over a 22 acre property. Our labour base consists of permanent employees supplemented with local Agency workers to enable flexibility and respond to short term changes in demand.

Due to the nature of our products we supply, we work with strategic supply partners globally.

Our Directors and Senior Management take the responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training etc) and investment in an effort to ensure that slavery and human trafficking is not taking place within the organisation and to obtain confirmation that it is not taking place in its supply chain.

Our supply chains and due diligence

We are audited by our customers against their individual Codes of Practice. Ethical Standards are part of the audit scope, it is a requirement that we are ethically compliant as this forms part of our own approval as suppliers.

We are also third party audited by accreditation bodies and ethical standards are also part of the audit scopes.

We are part of SEDEX and we are audited on a regular basis against the Ethical Trading Initiative base code.

Internally, audits are carried out against customer and accreditation bodies’ codes of practice and standards.

All our raw material, packaging and indirect supply suppliers go through an approval process prior to commencement of supply, which can and will include self-assessment questionnaires and audits, designed to establish a risk rate and the relevant control measures to monitor supply.

As approval of supply is risk based, where a supplier is deemed to be of a higher risk, procedures are in place to closely monitor this by auditing the relevant suppliers. Audit frequency is also established according to the risk rating, the higher the risk the higher the frequency.

We have established regular meetings with our Labour Providers and will develop the agenda to ensure a continued focus on Modern Slavery to identify and assess areas of risk and identify areas for improvement

We incorporate peer learning e.g. through the Ethical Supplier Exchange to help us to continuously improve our approach

Our commitment and policies

We will not support or deal with any business knowingly involved in slavery or human trafficking.

We are committed to ensuring that there is no modern-day slavery and / or human trafficking in any part of our business and to doing all we can to ensure that this is also true of our suppliers and associates.

Our policy reflects our commitment to acting morally, ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure, as far as we can, that slavery and / or human trafficking is not taking place anywhere in our supply chain. A copy of our policy is available on request from HR@whitworths.co.uk

We will ensure compliance with the Act within our company but also expect our suppliers to ensure their own suppliers are also ethically aware and compliant and are SEDEX registered.

We will encourage our suppliers with a total turnover in excess £36 million to also release a modern slavery statement of their own and publish in their relevant websites where applicable.

As part of our due diligence processes into slavery and human trafficking, we abide by the ETI (Ethical Trading Industry) Base Code and have SEDEX Membership. SEDEX conduct an external ethical audit of our business on a regular basis and we have a supply approval process incorporating a review of controls undertaken by our suppliers which includes produce sourced from territories outside the UK and EU which are potentially more at risk of slavery and human trafficking issues.  The level of management control will be continually monitored. We also carry out a self assessment of risk.

We have internal policies in place which support this statement including Whitworths Supplier Ethical Code (which is sent to all our future suppliers at supplier approval stage), Social Accountability Policy, Recruitment, Grievance and Whistleblowing.

Our policies are accessible at all times on the intranet and/or by making a request to the HR Team. Some of our policies can be found attached to staff notice boards across our site. This Modern Slavery Statement is published on our website.

Training

The business Directors and Senior Managers take responsibility for and are committed in the implementation of this policy and will invest in training and resources as required.

We have modified our Induction to include Modern Slavery, the delivery being relevant to the audience. This has been shared with our Labour Providers.

Measuring effectiveness

This policy has been reviewed and the actions referred to put in place for our 2019 financial year to ensure that we continue to deliver on our commitment.

We will continue to explore ways to measure the effectiveness of our approach. For the 2019 year, these will be comprised of both inputs and outputs, as follows

  • Employee Voice: various mechanisms are in place to ensure that any potential issues are raised, including Employee Forum and a publicised Whistleblowing Policy/confidential help line
  • Mechanisms to identify risks and issue – regular use of the SEDEX Self Assessment Questionnaire and follow up
  • Employee awareness key performance indicators – through our annual Engagement Survey, completed by permanent and agency staff
  • Recruitment includes questions to identify potential issues – key performance indicators
  • Annual review of policy and publicise within 6 months of the financial year end

This statement has been approved by our Management Board and will be reviewed annually

and published within 6 months of the financial year end. This statement is made pursuant to

section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human

trafficking statement for the financial year ending 29 December 2018.

Signed on behalf of the Management Board by Mark Fairweather, CEO

27 March 2019