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Modern Slavery & Human Trafficking Statement

2022

Modern Slavery & Human Trafficking Statement

2022

Introduction

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s modern slavery and human trafficking statement.

 

A E Rodda and Son Ltd is fully committed to preventing slavery and human trafficking in our business activities and we proactively work to ensure there is no slavery or human trafficking in our own business and supply chains.

 

Our mission statement is ‘caring enough to do the right thing’. We commit to our customers, consumers, and staff that we will always treat people in our business and supply chain fairly. This means we will continually review and improve our policies, practices, and procedures in order to fulfil this commitment.

 

Organisational Structure and Supply Chain

 

This statement covers the business activities of A E Rodda and Son Ltd, Group and Partnership. We are a manufacturer of dairy products including Cornish clotted cream, bottled milk and butter. The Company operates from one site in the U.K only, specifically at The Creamery, Scorrier, Redruth TR16 5BU. Our supply chain includes the sourcing of raw materials for the manufacturing of our products and for packaging.

  • Potentially High- Risk Activities

The following activities are considered to be at risk of modern slavery or human trafficking:

 

  • Suppliers of raw material into the business – our supplier and service provider contracts include strong obligations on compliance with modern slavery legislation
  • Recruitment of agency workers through recruitment agencies if used, agency staff have been rarely used since 2020.
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Responsibilities

Responsibility for the Company’s anti-slavery policy is as follows:

 

  • Policy review and development: the Head of People Engagement is responsible for creating and reviewing this policy.
  • Due diligence: the Executive team and Head of People Engagement are responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.
  • Recruitment agency audits: The Head of People Engagement is responsible for ensuring that recruitment agencies are audited every 6 months to ensure compliance with the Company’s Modern Slavery and Ethical Trading policies.
  • Employees: have a duty to be alert to risks and to report their concerns.
  • Management: have a duty to act on concerns as a matter of urgency.
 

Developing Capability

 

  1. Managers with responsibility for developing and operating company procedures relevant to this issue in the business attend training on setting standards and tackling hidden labour exploitation
  2. The Company carefully checks and monitors labour providers and ensures that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent leaders/individuals
  3. The Company ensures that all Managers responsible for directly recruiting workers are aware of issues around possible third party labour exploitation and signs to look for.
  4. The Company provides information on tackling “Hidden Labour Exploitation” to our employees through training and visual communications
  5. The Company encourages workers to ‘whistle blow’ or report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports promptly
  6. During initial induction, the Company positively encourages employees and agency workers to report any exploitation which may be occurring within their communities by informing them of the ways in which exploitation can be reported
  7. The Company requires labour providers and organisations in the labour supply chain to adopt policies and procedures consistent with fair treatment of workers
  8. The Company conducts audits of our labour providers to ensure that there is no exploitation within the labour supply chain and in the case of farms requires Red Tractor certification.
  9. The Company regularly surveys our employees and in surveys and 1-1’s management specifically asks for feedback on safety and fairness.
  10. The Company embraces being audited to ensure fair practises and procedures and utilise resources and best practice learning from our customers.

Associated Policies

 

  • Whistleblowing Policy: the Company encourages all workers, to report any labour and slavery concerns in its direct activities or its supply chain activity
  • Community (Corporate Social Responsibility Policy: the Company’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities
  • Ethical Policy: the Company aims to ensure fair labour standards though out the company and its supply chain, and that all working practices are in accordance with current UK legislation and Ethical Trading standards. The company has signed up to the Sedex Ethical Trading Initiative, is audited by Sedex and conducts regular Sedex SAQ self- assessments.

 

Due Diligence Process

The Company undertakes due diligence when taking on new suppliers and  reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners and suppliers.

 

We have zero tolerance to slavery and human trafficking, and we expect all those in our supply chain and contractors to comply with our values.

 

Performance Indicators

 

The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains:

  • whistleblowing concerns
  • supplier audit data
  • labour monitoring via HR/Payroll systems
  • results from agency and ethical audits.
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This Modern Slavery and Human Trafficking Statement will be updated when necessary and reviewed a minimum of every two years. The Board of Directors endorses this policy statement and is fully committed to its implementation.

 

This Modern Slavery and Human Trafficking Statement has been approved and authorised by:

 

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Date: 1 April 2022