Modern slavery act

It continues to be a priority for the Finsbury Food Group to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and supply chain. We are committed to constantly reviewing and improving our practices to combat slavery and human trafficking.

Organisation’s structure

The Finsbury Food Group is a leading speciality bakery manufacturer serving both the major multiple retailers and foodservice channel. Our purpose is to achieve baking brilliance that makes every day special. The Group has approximately 3,500 colleagues across our operations in the UK, which include 8 manufacturing sites and 1 distribution centre with an annual turnover of circa £400 million.

Our business

This statement covers the following Finsbury Food Group Limited entities:

  • Memory Lane Cakes Limited
  • Lightbody of Hamilton Limited
  • Johnstone’s Food Service Limited
  • Fletchers Bakeries Limited
  • Nicholas and Harris Limited
  • Ultrapharm Limited
  • Lees of Scotland Limited

Our supply chains

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 to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We periodically review and update our policies.

  • Policy on Reporting of Incidents (Whistleblowing Policy)
  • Equality, Diversity and Inclusion Policy
  • Dignity at Work 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.

It is in our Technical Conditions of Supply that our suppliers complete our Ethical Questionnaire (based on the ETI Base Code) and register with SEDEX, making their Ethical data visible to us, enabling us to drive ethical standards within our supply chain. Currently, circa 73% of suppliers are linked to us via SEDEX. Where suppliers are not currently linked or registered on SEDEX, we are continuing to work with them to bring them into the scheme, progressively building SEDEX membership across our supply base.

We also have in place systems to:

  • Identify and assess potential risk areas in our supply chains.
  • Monitor potential risk areas in our supply chains.
  • Protect whistle blowers.

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 Audit Committee.

We have a clear governance process for handling modern slavery and human trafficking challenges both within our operations and our supply chains. Modern Slavery is listed on the Risk Register which is reported to the Audit Committee. Compliance with the relevant legislation and guidance is reviewed by the Technical and HR functions. 

Supplier adherence

We have zero tolerance of slavery and human trafficking. To ensure all those in our supply chain and contractors comply we have in place a rigorous supply chain compliance programme.

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 the potential risk areas in our supply chains and have robust systems in place to deal with such risks.


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

HR teams in Finsbury Food Group are provided with the knowledge and resources required to conduct checks on “Right to Work” compliance. HR colleagues also 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, including ‘Stronger Together’ materials, 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 HR Team, plus senior leaders across the Technical, Operations, Payroll Health, Safety & Environment and Supply Chain Teams are required to complete the Stronger Together workshop ‘Tackling Modern Slavery in UK Businesses’. All members of the Purchasing Team attend 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 in October 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 to ensure that slavery and human trafficking is not occurring in our business or supply chains.

  • Independent Ethical Audit –
    • All Finsbury Food Group Limited entities have an up-to-date ethical audit
    • All Finsbury Food Group Limited entities have closed out any non-conformances from ethical audits 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 campaign(s)

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 to combat slavery and human trafficking:

  • extend the number of roles that are required to undertake the Stronger Together workshop
  • drive actions to mitigate risk via a cross functional team
  • 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 30/06/23. It was approved by the board in July 2023.

John Duffy
Chief Executive Officer

Finsbury Food Group Limited
Date: July 2023

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