Our Purchasing team sources from over 600 different suppliers. The majority of our raw materials are sourced from suppliers based in the UK. In many cases, we have long term strategic partnerships in place to help build effective, fair and transparent supply chains.

Our policies on slavery and human trafficking

We have the following policies in place that underpin our commitment which we periodically review and update:-

• Policy on Reporting of Incidents (Whistleblowing Policy)
• Equality, Diversity and Inclusion Policy
• Recruitment and Selection Policy
• Young Persons at Work Policy
• Human Rights Policy

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we monitor ethical standards across the business on a regular basis both internally and via external third-party audits. We are a member of the Supplier Ethical Data Exchange (‘SEDEX’) and sites complete a self-assessment questionnaire and undergo unannounced SEDEX members Ethical Trade Audits at the required frequency.

Our Technical Conditions of Supply require our raw material and packaging suppliers to complete our Ethical Questionnaire (based on the ETI Base Code) and register with SEDEX, making their ethical data visible to us and enabling us to drive ethical standards within our supply chain. Currently, circa 83% of suppliers are linked to us via SEDEX which represents an increase versus prior year. Where suppliers are not currently linked or registered on SEDEX, we continue to work with them to bring them into the scheme, progressively building SEDEX membership across our supply base.

Whistleblowing Policy

We provide an independent, external reporting hotline, which is free, anonymous and confidential, whereby colleagues can raise concerns. This operates alongside the internal company grievance procedures. The contact details for the hotline are displayed in prominent areas throughout our sites and are communicated as part of both the onboarding process and via internal communication mechanisms. The nature of the calls received by the external reporting hotline are monitored and concerns investigated where appropriate. Calls are also reviewed by the Operating Board.

We have a governance process for handling modern slavery and human trafficking challenges within our operations.Modern Slavery is listed on our Corporate Risk Register which is discussed and monitored at the Group Operating Board. Compliance with the relevant legislation and guidance is reviewed by the Technical and People functions. 

Supplier adherence

We have zero tolerance of slavery and human trafficking. If issues are discovered in our supply chain, immediate and proportionate action will be taken to address the issue.

We highlight agency labour as a part of our business operation which may have a risk of slavery and human trafficking occurring. All employment agencies with whom Finsbury Food Group have contracts to supply temporary workers must demonstrate that all temporary workers supplied are eligible to work in the UK, understand our Health & Safety and Food Safety practices and requirements, and their contractual documents. We work with these agencies to audit and monitor their compliance as well as share best practice for worker welfare and approaches for addressing modern slavery or labour exploitation risks. We are also working to reduce our agency labour usage across the business.

Our supply chain’s security and integrity is a crucial component of the business model. Robust supplier approval and traceability systems ensure that our products are responsibly sourced from suppliers whose values align with our own. We monitor, assess and mitigate wherever possible the potential risk areas in our supply chains.

Training

To ensure understanding of the risks of modern slavery and human trafficking and to prevent its occurrence, we provide our colleagues with training.

People Team colleagues are required to conduct checks on “Right to Work” compliance and maintain competency in management of the SEDEX system, booking ethical audits and closing out non-conformances.

Information on hidden labour exploitation is included in our induction training and colleagues in selected roles are required to complete further training to enable them to identify and address hidden labour exploitation.

All members of the People Team, plus senior leaders across the Technical, Manufacturing, Payroll & Reward, Health, Safety & Environment and Supply Chain Teams are required to complete the Stronger Together workshop ‘Tackling Modern Slavery in UK Businesses’. All Purchasing Team colleagues receive ethical trading training via CIPS.

The resources provided by the Stronger Together campaign are available throughout the business. We run an annual campaign in support of Anti-Slavery Day to raise awareness of human trafficking and modern slavery.

Our effectiveness in combating slavery and human trafficking

We track progress through a number of metrics to demonstrate the effectiveness of our plans.

• Independent Ethical Audit – all Finsbury Food Group Limited entities have an up-to-date ethical audit and have closed out any non-conformances within agreed timescales
• Supplier SEDEX Registration – raw material and packaging suppliers are SEDEX registered
• Training – colleagues have completed the relevant Modern Slavery training
• Communication – delivery of the planned communication

Further steps

Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps:

• extend the number of roles that are required to complete the Stronger Together workshop
• further develop guidance for line managers, auditors and People Team members
• leverage the new HRIS to further reduce risk
• build a review of arrangements for combating slavery and human trafficking into the tendering process for new agency labour providers
• work with service contract suppliers to ensure high ethical standards and practices are adhered to
• further standardise our approach across the group, including the integration of acquisitions

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 30/06/24. It was approved by the board in August 2024.