Modern Slavery Statement
Modern Slavery and Human Trafficking Statement (FY18-19)
The Jordans & Ryvita Company, a division of ABF Grain Products,
Associated British Foods plc
As a professional and ethically responsible business and employer we recognise that we have a responsibility to take a robust approach to prevent modern slavery and human trafficking. This statement sets out The Jordans & Ryvita Company’s actions to understand all potential modern slavery risks related to our business and the steps we take to try to ensure that there is no slavery or human trafficking in our own business, or our supply chains. This statement relates to actions and activities during the Financial Year 14th September 2018 to 13th September 2019.
Organisational structure and supply chains
The Jordans & Ryvita Company (referred to as Jordans Dorset Ryvita or JDR) operates in the Food Manufacturing Industry. We currently operate in the following countries:
• UK – 1 Head Office and 4 Manufacturing sites
• Australia – 1 Sales Office
• Brazil – 1 Sales Office
• Canada – 1 Sales Office
• France – 1 Sales Office
• Germany – 1 Sales Office
JDR has a global supply chain and in some cases we purchase ingredients from extended supply chains, involving traders and brokers. We have taken steps to identify high risks in our supply chains and continue to monitor our risk assessments as required.
Sustainability is important to our business in all areas, from the ingredients we buy through to the products we make and how we make them. This business wide focus is manifested through the JDR “Good Food Commitment” which sets out our approach to Corporate Responsibility in relation to the nutritional qualities of the products we manufacture, the ingredients we purchase in order to make those products and the operational processes through which we manufacture those products. We continue to devote two of the four strategic pillars of our Good Food Commitment to responsible sourcing, namely International Supply Chains and UK Cereals (which are the single largest commodity that we purchase by volume.) The work of the Good Food Commitment is sponsored by the board and overseen by a panel of external experts through a Sustainability Governance Committee. In this way we are able to promote sound ethical and environmental standards across the business and capture the latest insights in Corporate Responsibility.
Our procurement policies and procedures incorporate the appropriate requirements in line with ILO standards; The ETI Base Code and the Modern Slavery Act, as specified within the latest version of the ABF Supplier Code of Conduct. Appropriate training has been conducted with the relevant managers to ensure these policies and processes are correctly implemented. Policies are reviewed annually and where necessary refresher training included for relevant colleagues. Last year we added an ethical audit policy to our procurement policy standards which is now undergoing review after its first year of implementation. This enables us to put greater emphasis on the ethical auditing of our supply chain, particularly in relation to modern slavery. We have communicated the latest version of The ABF Supplier Code of Conduct to all of our raw material suppliers and continue to include this as a provision of supplier approval for new suppliers.
To help us raise awareness and mitigate risk we have a policy titled Preventing Hidden Labour Exploitation in Our Business, this supports us during the recruitment and employment of permanent employees and temporary agency employees. The HR team has responsibility for this policy and it was drafted in accordance with guidance from ‘Stronger Together’.
Our People – Due Diligence
We recognise that our supply chains are not the only area where people may be at risk of Modern Slavery in the context of our business. As such, 6 monthly checks are undertaken within our own business operations to identify any areas of concern associated with shared addresses or bank accounts for employees. This year we amended our HR system to support us with this process, building in a message prompt, as we input new starter information, if their details match another employee. We also undertake 6 monthly reviews of our modern slavery commitments within the HR team.
When recruiting we follow good practice approaches to identification and our agency suppliers are fully licensed and comply with our Recruiter Compliance Principles. Specific questions have been introduced to our interview templates to encourage conversation about how the applicant heard about the role and whether any money has been exchanged in relation to the role. We recognise that temporary workers are a particular risk group in respect of modern slavery and we work closely with our existing suppliers to mitigate the risk of potential labour exploitation. To enable us to be even more effective, for the majority of our temporary worker requirements, we work with a single agency who works directly with temporary worker suppliers on our behalf (a neutral vending solution, Neuven). This third party works directly with our suppliers, applying thorough auditing and compliance standards which include a focus on ways to mitigate the risk of Modern Slavery. Where we hire temporary workers outside of this process we undertake regular audits of the provider ourselves. Two managers have raised concerns regarding agency workers in relation to modern slavery since working with Neuven and they have supported us in exploring these concerns demonstrating they, and the agencies they work with, are fully committed to working with us to prevent it. There was no modern slavery concern in either of these cases, but we were pleased that managers were being vigilant, and we were able to provide support to the individuals involved.
We have a Whistleblowing Policy which is communicated to all employees via noticeboards and posters. We encourage our people to report any concerns they may have either regarding circumstances that may give rise to an enhanced risk of slavery or human trafficking or to a specific situation which causes them concern. Our Whistleblowing Procedure is designed to make it easy for workers to make disclosures, without fear of retaliation, and we have had a confidential whistleblowing hotline in place since 2011, with posters displayed around our sites.
Training and Awareness
Using training material from Stronger Together, employees in our Procurement and HR teams have received tailored briefings on the signs and risks associated with Modern Slavery and Hidden Labour exploitation.
This year we have developed an online e-learning module in Modern Slavery and rolled this out across our buying team. This allows clear traceability of training records and ensures that all participants are receiving a high quality of training in a standardised format. In this way we are able to give our buyers the in depth understanding of Modern Slavery that we feel is important for their roles. We have the opportunity to roll this training out to other functions who have exposure to suppliers and supply chains.
As well as formal training, the buying team continue to be actively involved in the management of ethical trade in their categories- specifically modern slavery and labour risks. This year we have built on the foundations of our Ethical Auditing Programme and our buyers have taken a central role in its implementation through regular tracking sessions and engagement with suppliers to conduct audits. We will be continuing with this agenda during our next financial year using this year’s experiences to further improve our programme management. A number of our team members are trained on social systems auditing (SA8000 Lead Auditor training). These individuals do not operate as ethical auditors but are using that training to help them understand and assess the information provided by agencies/suppliers.
We have continued to develop our ethical programme in Turkey and through our team member in Istanbul we have significantly advanced our capabilities in the management of modern slavery in this key sourcing geography. In this way we have been able to get much closer to the activities of these supply chains with regular face to face visits during which we can support suppliers with the continuous improvement of their modern slavery risk management. We are also confident that this closer connection with our supply chains will support our buyers and the wider businesses with establishing a deeper understanding of these issues.
We continue to build awareness with our suppliers particularly around our ethical audit agenda and our suppliers have been critical to our programme. In particular we have notified and communicated with all suppliers who are assessed as high risk and we encourage their engagement with our audit programme. This year we focused time on our Turkish supply base and ran face to face training over 3 days with several groups of suppliers. This training received positive feedback and we are reviewing how we can learn from its success to continue to build knowledge and awareness with suppliers from other high-risk geographies. We have prepared ethical audit awareness materials for suppliers and also share common resources such as SEDEX guides with them.
We have increased awareness on the signs and risks associated with Modern Slavery across our Management, Head Office and Manufacturing populations. We conduct team briefs within manufacturing on an annual basis and have provided specific members of our population, such as those who manage large numbers of employees and our security and reception staff with more detailed briefing sessions. Refresher training takes place annually. We have included a section of this briefing session in the induction slides for all manufacturing sites to ensure that all new employees are made aware of the risks and what to do should they experience or witness anything of concern.
Our Supply Chains – Due diligence/Risk Assessment
The organisation undertakes due diligence when considering taking on new suppliers and regularly reviews existing suppliers. As part of our standard contractual terms we require all our suppliers to operate to our ‘Terms and Conditions of Purchase’, which includes a specific requirement to operate according to recognised ethical business standards. We have also revised our supplier approval process to increase the levels of rigour applied to MSA risk assessment. This has the additional benefit of driving greater awareness of the importance of this issue amongst our supplier community.
For our key suppliers who provide our manufacturing materials, we link to them on Sedex and carry out a review that consists of 3 stages of risk assessment plus remediation and reporting. Our risk assessment includes 1) a high level risk and materiality assessment to identify where inherent risk lies in relation to our brands, 2) supply chain mapping and 3) an ethical audit if required. We use a range of qualitative and quantitative data sources to conduct our risk assessments including but not exclusive to: Sedex, Verisk Maplecroft, BRC and 4 pillar SMETA audit data. A representative from each site has taken responsibility for updating SEDEX to improve the quality and detail of the information.
We continue to conduct high level risk assessments which assess our raw materials across a number of measures including country of origin and processing, the type of industry and the method of procurement. We also continue to map our high-risk supply chains, maintaining a focus on those geographies and products which pose the highest risk.
We have successfully built on the foundations of our work in Turkey working alongside processors and visiting farmers to collect information and build relationships. We also continue to support a cross industry initiative looking to combat labour malpractice in hazelnut supply chains. This is an initiative with the ILO and other business seeking to improve labour standards in this industry. We are also now joining a second cross industry activity looking at the management of seasonal labour practices across agricultural supply chains throughout Turkey.
We continue to review risk in our indirect supply chains, we monitor and review supply chain risk routinely and have extended our ethical audit agenda considerably this year. We value the input of suppliers in supporting us with this agenda and in addition to the Turkish projects mentioned above we have rolled our project in a Brazil nut supply chain which is now active. We maintain our relationships with external experts and consultants to assess the supply chain, identify remedial actions and reduce risk, and we maintain our commitment to identify those initiatives that will reduce any risk of it.
To support us in measuring whether the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain are successful we consider:
If any reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified within our business. To date two concerns have been received and investigated, neither were modern slavery concerns but we are pleased briefings are encouraging employees to raise any concerns.
If our people have been briefed to identify signs of Modern Slavery and how to report any concerns. Our manufacturing population, which represents 70% of our workforce, was provided with detailed training and now receive annual briefing and all new starters are briefed during induction. The majority of our UK head office-based employees have received either verbal or written briefing.
A commitment to complete an internal audit reviewing the efficacy of our processes and supply chain risk assessments. Audit has confirmed that our high priority suppliers have been identified and briefed on the requirements of our modern slavery commitments.
This statement has been approved by the organisation’s board of directors. The statement will be reviewed and updated annually.
Director’s name: Paul Murphy Date: 4th November 2019