Whitworths LTD: Modern Slavery Statement September 2025

INTRODUCTION

Whitworths Ltd remains fully committed to preventing modern slavery and human trafficking in our operations and across our global supply chains. We continue to evolve our approach, aligning with the UK Modern Slavery Act 2015 and emerging best practices in Human Rights Due Diligence (HRDD).

In 2024, we strengthened our capability and governance through targeted training, improved reporting access, and deeper supply chain risk analysis. We recognise the heightened risk in food manufacturing—especially where global sourcing and a high proportion of migrant and agency labour intersect. This statement sets out our updated approach to identifying, preventing, and responding to modern slavery risks.

This statement is made pursuant to section 54(1) of the Act and covers the financial year ending 31 December 2024.

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

Whitworths are a privately-owned business that mixes, packs, processes and coats, dried fruit, nuts, seeds, beans, pulses, and cereals for 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 2024 financial year ran from Monday 01/01/24 to Tuesday 31/12/24.

The site in Irthlingborough, where the head offices are based, consists of 5 manufacturing plants (Fruit processing plant, Cereal processing, Nut processing, Peanut and Coating), the site also houses a Heat Treatment and separate Mixing area, and 7 warehouses over a 22-acre property.  Our labour base consists of permanent employees supplemented with local agency workers, sourced through reputable recruitment agencies, which enable the business flexibility and the ability to respond to short term changes in demand.  All appropriate right to work checks are conducted throughout our labour base.  We employ approximately 430 permanent employees at our site in Irthlingborough.

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

OUR POLICIES AND COMMITMENTS COMMITMENT

We continue to embed ethical practices through our integrated policy framework, Virtue which

outlines standards reflecting 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

• Virtue (Ethical Trading Policy) – covers human rights, modern slavery, social accountability, and responsible sourcing.
• Responsible Sourcing Policy – issued to all suppliers
• Whistleblowing and Grievance Policy
• Use of Agency Policy – sets expectations and audit requirements.
• Recruitment and Induction Policies – include RTW checks and bank/address validation.

We encourage an open and honest culture in our business supported by the appropriate policies, which are regularly communicated, starting at our new hire induction, and using various methods, including email correspondence, posters across site and messaging on pay slips.

We will ensure compliance with the Act within our company but also, we expect our suppliers to share our commitment to ethical and responsible business practices and to comply with all applicable laws and regulations, including those relating to modern slavery and human trafficking. We may take action against suppliers who fail to meet our standards.  We continue to encourage our suppliers with a total turnover in excess £36 million to also release a modern slavery statement of their own and publish on their relevant websites where applicable.

We are regularly audited using the SMETA methodology which covers SEDEX’s 4 pillars of labour, health and safety, environment, and business ethics.  We share this information on the SEDEX platform with our customers.  Ethical audits of this nature will cover ‘worker voice interviews’ held with no management or supervision interaction to ensure openness and honesty.

We have a robust 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 request all suppliers are members of SEDEX and link with us on the platform, in the case of suppliers based in “high risk” countries this is a condition of supply.

Our policies are always accessible on the intranet and on our shared drives, or by making a request to the HR Team.  They are shared with employees as they join our business.  Some of our policies can be found attached to employee communication boards across our site. This Modern Slavery Statement is published on our website.

GOVERNANCE AND RESPONSIBILITIES

Responsibility for our Modern Slavery agenda sits with our Management Board, led by the CEO. Day-to-day implementation is managed by the HR Director, Procurement Director, Head of Technical, and the Supply Chain Technical Controller.

HUMAN RIGHTS DUE DILIGENCE

Our HRDD approach includes:

• Country, commodity, and supplier-level risk assessments.
• Mandatory SEDEX membership and SMETA audits for all high-risk suppliers.
• Review of audit outcomes, including corrective actions and remediation.
• Audit refusal or delisting where risk is unmanageable.
• Annual risk reassessment, guided by ETI Base Code and customer standards.

TRAINING AND AWARENESS

We will continue to expand our training and resources, as required, to raise awareness of slavery and trafficking, and of our policies and procedures.  We have an established Induction programme which raises awareness of 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 have been put in place and executed within our 2024 financial year ensuring that we have continued to deliver on our commitments.

• We continued to promote the Whistleblowing telephone and email communication mechanisms, which go direct to our CEO and HRD, through poster publication, email promotion and messages on payslips. Whistleblowing is included in our induction.  In 2024, no concerns were raised in relation to Modern Slavery.
• In 2024, we ran our annual engagement survey, which is externally hosted. Ongoing action plans will span 2024 and into 2025.
• Our Worker Voice Forum, known as the Employee Forum, was extended as we recruited more representatives to ensure all functions had a voice. Awareness training was provided to all members.
• Modern Slavery Awareness presentations were distributed across site for all workers, and these included confidential help lines.
• We continued the regular use of the SEDEX Self-Assessment Questionnaires to identify risks and issues and followed up all key learnings from our customer audits.
• We continued to drive good practice recruitment and induction process, raising awareness, and providing access lines should a colleague be aware of exploitation, or if they themselves were being exploited.
• Further data checks have been added in, and the regularity increased post induction, involving address checks, bank account details, key telephone numbers and next of kin.
• Our annual policy review has been completed. A revised statement due to be published within 6 months of the financial year end.

Our performance continues to be measured via the following mechanisms

• Third party ethical audits undertaken at our site in Irthlingborough.
• Colleague and Suppliers who have undertaken modern slavery awareness training.
• Reported incidences of modern slavery in our supply chains.
• Improvement actions undertaken in our supply chain.

OUR SUPPLY CHAINS AND DUE DILLIGENCE 

All our raw material, packaging and indirect suppliers go through an approval process prior to commencement of supply.  In addition to questionnaires and audits, we require all our suppliers to register with SEDEX, and share information on their human rights, environmental, and business ethics policies and practices.  We use this information to stratify the risk associated with the supplier, and to manage the supply relationship appropriately.

Our approval of supplIers is risk based and focuses on three areas.  Firstly, we focus on country, identifying higher risk countries.  We also risk assess specific raw material supply chains, identifying those where particular concerns exist, such as those for Cashew Nuts, Hazelnuts, and Coconut. Thirdly, we assess the individual suppliers within these supply chains and countries.  We request all high-risk suppliers to be SMETA audited on a bi-annual basis.

We use a number of tools to mitigate risk, and to ensure modern slavery is not practiced.  This may include setting specific criteria for sites we work with and declining to work with factories that outsource certain process steps.  Where we deem a country or region of origin to present an unmanageable risk, we will not source from that country or region.   In 2024 we instigated checks on the controlling interests of suppliers in high risk countries. We use Direct Worker Communication to better understand workers experience of our suppliers, taking good practice from the SMETA audit ethos.  Audit frequency is also established according to the risk rating, the higher the risk the higher the frequency.

Whitworths approach to due diligence within our supply chain is guided by our Responsible Sourcing Policy.  A copy of which is issued to all prospective suppliers as part of a Supplier Introduction Pack and ways of working with our business.  Whilst we are mindful of the limitations of audits, our audit programme is a critical enabler in the discovery and management of modern slavery risks throughout our supply chain.

We are an active Buyer/ Supplier member of SEDEX (Supplier Ethical Data Exchange) and continue to use their system and tools to map our supply chains, assess key areas of risk and monitor improvement activity across our supply chain.  We review all SMETA audits carried out at our suppliers’ sites, and ensure corrective actions, and where appropriate remediations are carried out.  Suppliers with critical non-compliances are reviewed, and their progress towards full compliance supported.  Delisting is retained as a last resort option for suppliers who fail to resolve critical non-compliances.

As a supplier to our customers, we are audited against their individual Codes of Practice, of which ethical standards form part of the audit scope.  It is a requirement that we be ethically compliant to gain approval as a supplier.  We are also third party audited by accreditation bodies and ethical standards are part of these audit scopes.  Internally, audits are carried out against customer and accreditation bodies’ codes of practice and standards as a means of continuous improvement.

In 2024, having undergone an extensive labour provider review, we partnered with a new Labour Provider.  Our Labour Provider is a member of SEDEX and is audited under SMETA, sharing results with our site.  We work with their compliance team when conducting unannounced audits.  A reset of meetings, including regular operational meetings, staff engagement and welfare and quarterly business review mechanisms are in place.  With their GLAA membership and enhanced checks, they have a strong focus on modern slavery, and we work with them to continue to identify and assess areas of risk and areas for improvement.  Our Use of Agency Policy has been revised to outline expectations.

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

PROGRESS ON OUR PERFORMANCE TO DATE

We have identified a number of products, and origins where there is a higher risk of practices that can lead to forced or indentured labour.  These include Cashew Nuts, Tropical Dried Fruit, Brazil Nuts, and Coconut.  We have also identified a number of countries with higher risks due to a high level of migrant labour.

We have made further progress in simplifying our supply chains, concentrating on those supply chains where growing is globally dispersed, but processing and packing is concentrated in a few countries.  This is enabling us to ensure they are more transparent and working with suppliers to improve their performance in management of labour standards.

With such an extensive and complex supply chain, working with our suppliers, continually assessing and reassessing, ensuring appropriate controls in place will continue to be our focus.

NEXT STEPS FOR 2025

In line with UK Governments reforms to the Modern Slavery Act, we intend in 2025 to

1. Increase our investor, customer and internal scrutiny
2. Further focus on Human Rights Due Diligence outlining how we assess, prevent and respond to potential risks.
3. Expand our training and awareness programme
4. Ensure greater transparency of training metrics, along with future targets

1. Deepen supply chain mapping for high-risk categories
2. Expand employee voice channels and insights

7. Strengthen our response capability for suspected or confirmed exploitation
8. Forge greater links to victim support services
9. Review worker remediation practices
10. Include new channels for whistleblowing routes

MODERN SLAVERY STATEMENT

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 Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2024.

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

September 2025