MODERN SLAVERY STATEMENT
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 we work to strengthen our efforts to prevent, identify and address potential risks or instances of modern slavery within our organisation and with the suppliers of goods and service to us, in line with our values, policies and regulation.
Whitworths remains committed to ensure transparency within our organisation and our supply chain.
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.
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 2020 financial year ran from 29 December 2019 to 2 January 2021.
The site in Irthlingborough, where the head offices are based, consists of 4 manufacturing plants and 5 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 respond to short term changes in demand. Appropriate right to work checks are conducted throughout our labour base. We employ approximately 385 employees at our site in Irthlingborough.
Due to the nature of our products, we supply, we work with strategic supply partners globally.
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.
Our supply chains and due diligence
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.
Our approval of supply is risk based in three areas. Firstly, we focus by country, identifying those higher risk countries. We also risk assess against the raw material supply chains, such as Cashew Nuts, Hazelnuts, Coconut supply chains within the countries. Thirdly, we assess the suppliers from within these supply chains and countries. 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.
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 identify areas for improvement. How we work with our agency partners 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.
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.”
At Whitworths, Virtue, shapes the way we do business and forms the basis of our culture, our values and how we do business. As part of Virtue, the code guides our approach to human rights.
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. 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. 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 a Responsible Sourcing Policy which 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), Social
Accountability Policy, Responsible Recruitment, Children and Young Workers Policy, Grievance and Whistleblowing.
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 staff notice boards across our site. This Modern Slavery Statement is published on our website.
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 2021, we aim to continue to develop the skills and knowledge of key frontline colleagues across our business.
Progress On Our Performance To Date:
Identified risk within supply chain:
We have recognised a supply chain with significant risks is with cashews processed in Vietnam. Of particular concern is 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 so that we are only using suppliers that have direct control of the full process. 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 also partnered with a customer, and one of our suppliers to participate in a trial of direct engagement with workers to discover more about working conditions.
As we receive audit reports, and the results of the direct worker engagement we are working with suppliers to address any issues of concern that are raised through these processes.
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:
• Employee Voice: various mechanisms are in place to ensure that any potential issues are raised, including Employee Forum with representation from all areas of our business. A publicised Whistleblowing Policy/confidential help line and our informal Raise a Hand. We are committed to regularly promoting mechanisms to hear our employee’s voice. Since inception, no concerns have been raised in relation to modern slavery and/or human trafficking.
• 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.
• 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.
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 2 January 2021.