Modern slavery act

Finsbury Food Group commits to adopting a proactive approach to tackling hidden labour exploitation. Hidden labour exploitation is exploitation of job applicants or workers by third party individuals or gangs other than the employer or labour provider, including rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for workfinding services and work-related exploitation such as forced use of accommodation. It is understood that it is often well hidden by the perpetrators


This policy applies to all sites in the UK that form part of Finsbury Food Group.


The Group Human Resources Director has overall responsibility for this policy. Company Directors, Site Leaders and HR Team members have specific responsibilities for various aspects of this policy.

Policy Commitments

Finsbury Food Group shall:

  1. Designate appropriate managers to receive relevant training in relation to this policy and to have responsibility for developing and operating company procedures relevant to this issue.
  2. Accept that job finding fees are a business cost, and will not allow these to be paid by job applicants. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
  3. Ensure that all staff responsible for directly recruiting workers are aware of issues around third party labour exploitation and signs to look for and have signed appropriate Compliance Principles.
  4. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
  5. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and police.
  6. Provide information on tackling “Hidden Labour Exploitation” to our workforce through a variety of formats such as workplace posters, induction training, employee handbooks etc.
  7. Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
  8. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities.
  9. Require labour providers and other organisations in the supply chain to adopt policies and procedures consistent with the above.

Approved by the Board of Finsbury Food Group Plc on 22 April 2021.

John Duffy
Chief Executive Officer

This statement is made by, and has been approved by the boards of, the following members
of the Finsbury Food Group: Finsbury Food Group Plc; Fletchers Bakeries Ltd; Lightbody of Hamilton Ltd; Memory Lane Cakes Ltd; Nicholas & Harris Ltd; Ultrapharm Limited and Johnstone’s Food Service Limited.

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