WHITWORTHS LTD: MODERN SLAVERY STATEMENT SEPTEMBER 2022

INTRODUCTION

Whitworth’s Ltd acknowledges our responsibility under the Modern Slavery Act 2015 (Act), and we work to strengthen our efforts to identify, prevent, mitigate, and address potential risks or instances of modern slavery and human trafficking within our organisation and with the suppliers of goods and services to us, in line with our values, policies and regulations. We are committed to improving our practices to combat modern-day slavery and human trafficking from within our business and supply chains.

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 dried fruit, nuts, seeds, beans, pulses and cereals 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 2021 financial year ran from. 03/01/21 to 01/01/22.

The site in Irthlingborough, where the head offices are based, consists of 3 manufacturing plants (Fruit processing plant, Cereal processing, and Nut processing) 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 flexibility and response to short term changes in demand. Appropriate right to work checks are conducted throughout our labour base. We employ approximately 337 permanent employees at our site in Irthlingborough.

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

OUR COMMITMENT AND POLICIES

“At Whitworths we believe in doing the right thing in the right way. Building a sustainable business is in the long-term interests of our stakeholders, including customers, investors, suppliers, our people and all the consumers that choose our food, and we recognise and take seriously the significant trust they place in us.”

Our culture, the way we do things around here, reflects our brand values and reflects on our brand. Virtue, our Ethical Trading Policy, brings together under one umbrella our commitments as a socially responsible business, specifically in relation to: –

• How we do business
• Social Accountability
• Colleagues’ rights (Human Rights)
• Our commitment to the ETI Base Code
• Modern Slavery and Human Trafficking

Other Policies

• Responsible Sourcing
• Young Workers
• Agency Policy
• Working together, working differently

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 Ethical Trading Policy, outlines responsibilities for key ethical areas across our board.

The standards outlined include the ethical trading initiative base code and are in accordance with HRDD, and 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. 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 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.

Our Responsible Sourcing Policy, owned by our Procurement Director, applies to all our operations and those in our supply chain and outlines our stance on human rights due diligence and modern slavery, developed in conjunction with Procurement, HR and our Technical team.

We also have several internal policies in place which support our stance on modern slavery, including Whitworths Supplier Ethical Code (which is sent to all our future suppliers at supplier approval stage), Responsible Recruitment, Children and Young Workers Policy, Grievance Policy and Whistleblowing Policy. Our Ethical Trading Policy outlines our stance on social accountability, anti-harassment and bullying, anti-corruption and bribery.

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

Our Directors and Senior Management take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training etc) and investment in an effort to ensure that modern 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

RAISING AWARENESS AND 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. To raise awareness of slavery and trafficking, and of our policies and procedures, we have an established Induction programme to include Modern Slavery, the delivery being relevant to the audience. This has been shared with our Labour Providers.

In 2022, we aim to continue to develop the skills and knowledge of key frontline colleagues across our business.

MEASURING EFFECTIVENESS

This policy has been reviewed and the actions referred to put in place for our 2021 financial year to ensure that we continue to deliver on our commitment.

We continue to measure our performance based on several indictors, but specifically:

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

We will continue to explore ways to measure the effectiveness of our approach. For the 2021 year, these will be comprised of both inputs and outputs, as follows:

• We place value on our employee voice communications ensuring all employees whether directly employed or via our agencies have opportunity to raise concerns confidentially, through various mechanisms we have in place.
• Extending the Employee Forum membership to ensure as many teams across our business are represented.
• Continue to raise awareness of our Whistleblowing line which goes direct to our CEO and HRD, through poster publication, email promotion and messages on payslips. Whistleblowing is included in our induction.
In 2021, no concerns were raised.
• Mechanisms to identify risks and issue – regular use of the SEDEX Self-Assessment Questionnaire and follow up, key learnings from our customer audits.
• Employee awareness key performance indicators – through an employee survey. In 2021, we will implement this in conjunction with one of our key customers.
• Recruitment and induction process; includes questions to identify potential issues; modern slavery
statements on all applications with key telephone numbers to call; inclusion within induction; bank account and home address checks – key performance indicators.
• Ensuring all employees have easy access to all relevant policies
• Annual review of policy and publicise within 6 months of the financial year end.
• Extend Modern Slavery training through to a further management tier within our business.

OUR SUPPLY CHAINS AND DUE DILIGENCE

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 suppliers in high-risk countries to be SMETA audited on an 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, refusing to work with factories that outsource certain process steps, refusing to source some products from countries that are deemed to present an unmanageable risk, and to use Direct Worker Communication to better understand workers experience of our suppliers. 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 active members 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.

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.

Our Labour Providers, with whom we have established regular meetings with, have a continued focus on modern slavery and we work with them to continue to identify and assess areas of risk and areas for improvement. How we work with our agency partners, our expectations and how we audit them is detailed in our Use of Agency Policy.

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 recognised that supply of cashew nuts carries a specific level of risk, due to the nature of the product, structural issues with the industry, and over time a lack of care in sourcing. Of particular concern has been the widespread practice of outsourcing many of the more dangerous and labour-intensive processes to third parties, meaning our control over standards in these areas in the past has been greatly diminished.

Over the past 18 months we have been working to reset our supply base. The first decision (taken some years ago) was to concentrate our sourcing and management on suppliers in Vietnam. We have introduced sourcing plans to ensure we only use suppliers that have direct control of the full process. We have ensured we only use supply sites where the two steps that lead to most risk to workers, and potential for poor treatment of workers (cutting the cashew seed and peeling the kernels) is mechanised and the use of manual labour during these steps is minimised. We have then requested that all sites we use undergo regular SMETA audits and that the reports of these audits are shared with us. We have partnered with a service provider and one of our key suppliers to conduct a pilot of using direct worker engagement to better understand working conditions and are now planning to roll this out across all our cashew nut suppliers. We will be conducting a visit to suppliers within the next six months to review progress and to plan our next steps.

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 2 January 2021.

SIGNED ON BEHALF OF THE MANAGEMENT BOARD BY MARK FAIRWEATHER, CEO

September 2022