Modern slavery statement for financial year 2018/19
This statement is made pursuant to s.54 of the Modern Slavery Act 2015. It sets out the steps that Wessanen UK has, or will, be taking to reduce the risk of modern slavery or human trafficking within our business or supply chain.
The term modern slavery includes forced labour, child labour and human trafficking. Wessanen UK recognises that, in these three forms, modern slavery is a significant risk for businesses globally and we are committed to acting ethically and with integrity and transparency in all our business dealings in order to reduce this risk. We work with our suppliers to support and respect human rights and put effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chains.
Wessanen UK published its first Modern Slavery statement in 2017, and in the past year we have continued to work deepening our understanding of the key areas of risk and establishing sound policies for responding to those risks. We recognise that modern slavery is a criminal activity conducted for commercial purposes and that our response needs to evolve in line with what is a growing global risk. Our plans to do so in 2019 are referenced throughout this statement.
At Wessanen UK, we believe in producing great tasting, healthy food that is better for people and better for the planet. We focus on food and drinks that are healthier for people – organic, vegetarian, natural – and work hard to improve the nutritional balance of our products.
As well as championing healthy food, we care about the health of our employees and stakeholders, and the working and living conditions for farmers and producers. We want to protect our planet for current and future generations. We do this by producing the right food and by conducting our business in a sustainable way.
This approach guides how we develop, market and sell our brands (Clipper, Kallo, Mrs Crimble’s and Whole Earth) and our distribution of Almond Breeze on behalf of Blue Diamond. Our products are made in our own factories or by third party suppliers based in Europe. Our main product sectors include hot drinks, cereal cakes, peanut butter, breakfast cereals, cooking ingredients, gluten free products and almond drinks. Our products are sold in the UK and exported globally.
The Wessanen Group operates eight production facilities in five European countries producing mainly tea, dairy alternatives, breakfast cereals, sweet bars and biscuits, vegetarians spreads, coffee and cereal cakes.
The majority of our products are processed either in our own or in suppliers’ production facilities in countries in Europe where our risk assessment indicates the combination of countries and industries represent a lower risk of forced and child labour. Our supply chains, however, are global and we source raw materials from more 650 suppliers in more than 50 countries across Europe, Asia, Africa and North and South America.
Governance Structure and Strategy for Modern Slavery
The headquarters of the Wessanen Group and Benelux team are based in Amsterdam, the Netherlands. Our other country offices are located in Lyon and Bordeaux in France, Camberley in the UK, Bremen in Germany, Badia Polesine and Viadana in Italy and Madrid in Spain. Wessanen operate as a “family” of companies, with a joint strategy and set of key value, beliefs and shared objectives. The Executive Board, selected country General Managers and Functional Heads (Marketing, Operations and Human Resources) together form the European Leadership Team (ELT). The ELT drives the agenda of the business, including our sustainability initiatives and meets monthly to discuss results and planning.
Our Connecting to Nature sustainability strategy includes a commitment to “cooperate with our ecosystem”, build sustainable supply chains for key raw materials, and makes a commitment to increase our sale of Fairtrade certified products. All of these activities in conjunction with the Wessanen responsible sourcing programme include ethical initiatives, which cover modern slavery.
The management of the ethical initiatives is delivered through functional leaders who ultimately respond to the European Quality, CSR and R&D Director, who regularly reports back to the Wessanen ELT board.
Wessanen employ about 1,200 people across Europe and invest in their training and education to make them more engaged and knowledgeable about health and sustainable food. We see our staff as ambassadors to develop and champion our sustainability approach and organise regular community-related activities at all our sites to support this.
Policies and Contractual Controls
In the last twelve months, we have benchmarked our current policies, procedures and practices relating to modern slavery and ethical sourcing against best practice and identified gaps. Since our previous statement, we have revised and developed a number of internal and external policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Wessanen Supplier Code of Conduct: Revised version to be published in 2019 to meet best practice in ethical trade, including clearer provisions on forced labour and human trafficking.
- Internal Ethical Policy: To be published within Wessanen in 2019 to support all Wessanen colleagues working with suppliers who have responsibility for our ethical trade and modern slavery programme in line with international best practice. Our Ethical Operating Policy outlines our approach to ethical trade, including how we will implement and monitor our requirements from suppliers on modern slavery.
- Supplier Ethical Operating Policy: To be published in 2019 to mirror our Internal Ethical Operating Policy in line with international best practice. Our Supplier Ethical Operating Policy outlines our approach to ethical trade, including our requirements from suppliers on modern slavery.
- Recruitment Policy: Our recruitment policy, includes conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- Whistleblowing Policy: Our Whistleblowing Policy enables Wessanen employees to raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals. Any information is treated confidentially and promptly investigated
- Wessanen Company Code of Business Conduct: Our existing code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
Assessment of Modern Slavery Risk Within Our Supply Chain
In the last twelve months, we have started to develop our own detailed risk assessment of human rights, including forced labour and child labour, in our supply chains. This risk assessment has been conducted using publicly available, reputable information about country and product risks of forced labour and child labour and has been prioritised based on the key raw materials we buy.
Our ongoing work in 2018/19 on our risk assessment will be to:
- Identify which of our direct suppliers represent highest risk through SEDEX.
- Undertake appropriate due diligence to manage those risks.
- Building on the risk assessment we conducted on our key raw materials and carry out a more detailed research into the risks of forced labour and child labour in our high risk raw materials supply chains.
- Update our corporate ‘risk register’ to reflect modern slavery risks appropriately into our corporate risk register
Due Diligence and Assessment of Suppliers and Supply Chain
Wessanen UK operates a supplier policy and maintains an approved supplier list. A requirement to comply with our Supplier Code of Conduct, including our Modern Slavery Policy, forms part of our general purchase conditions and our manufacturing and supply agreements with all suppliers. They are required to confirm that they are working to reduce the risk of modern slavery and human trafficking in their businesses and supply chains and, where legally required to do so, to produce a Modern Slavery statement in line with the UK government’s guidance.
We conduct due diligence assessment on all suppliers before allowing them to become an approved supplier. This due diligence will, in future, include a requirement for direct suppliers to be registered on Sedex (the Supplier Ethical Data Exchange) and to have completed a Sedex self-assessment questionnaire (which includes questions on forced labour and child labour). Where possible we work with Fairtrade sources, in particular for tea, coffee and hot chocolate.
We recognise that the Fairtrade system does not guarantee that child labour and forced labour are not present in the supply chains of key raw materials and continue to work with the Fairtrade Foundation to support the evolution of their auditing protocols and transparency initiatives. However, we believe the process of engaging with Fairtrade and the empowerment and awareness-raising principles for workers and smallholders supports our goal of reducing the risk of modern slavery and human trafficking in our supply chains.
During 2018, we have also started to work on internal responsible sourcing initiatives to address a number of sustainability risks, including our COAT project which focuses on embedding ethical trade into our sourcing of cocoa and tea.
Modern Slavery Training
Our plans for 2019 include the development and delivery of training on modern slavery for senior managers at Wessanen UK and for all staff who work with suppliers and visit the supply chain. The training will ensure that staff understand forced labour and child labour, how to recognise the signs of both and what actions to take if they come across the signs on visits to suppliers. It will also cover an overview of assessing the risk of modern slavery in supply chains, support staff on the steps they should take to ensure suppliers have the capacity to manage modern slavery in their own supply chains and encourage staff to think about the link between procurement practices and reducing the risk of modern slavery.
Grievances and remedial action
Within our own business, we have a whistleblowing policy for Wessanen employees to raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals. Any information is treated confidentially and promptly investigated. We recognise the importance of locally developed grievance procedures and procedures for remedying human rights issues which are raised by workers or external third parties about Wessanen’s supply chains. Grievance procedures should follow the United Nations Guiding Principles “effectiveness criteria” for non–judicial grievance mechanisms.
We are aware that developing collaborations and partnerships will be critical to our ability to effectively tackle forced labour and human trafficking. At present, we work with Fairtrade to improve labour rights in our supply chains and we continue to do so in 2019.
Assessment of effectiveness (KPIS)
In 2019, we will use the following indicators to measure the progress we make implementing our modern slavery plan:
- Percentage of staff who are either in leading positions and/or engaged with suppliers trained to understand modern slavery and the steps they need to take when managing suppliers and visiting the supply chain to reduce the risk of forced labour and child labour.
- Percentage of suppliers (based on purchase turn over) providing information on forced labour and child labour via SEDEX.
- Number of suppliers in high risk supply chains, which have been assessed from an ethical perspective and the number of key raw material suppliers engaged in the development of sustainable supply chains.
A number of our next steps for 2019 have been highlighted in the report above. These include:
- The rollout of our Internal and Supplier Ethical Operating Procedures and revised Supplier Code of Conduct
- In depth risk assessments of our key raw materials
- Training of key staff and senior management on modern slavery risks
- The implementation and monitoring of key performance indicators to assess the effectiveness of our modern slavery approach.
This statement was approved by the Board of Wessanen UK on the 30th of November 2018 and is signed by Emma Vass, Wessanen’s Chief Executive Officer who is on the Board.