INTRODUCTION FROM THE BOARD OF DIRECTORS
We are committed to improving our practices to combat slavery and human trafficking. F. Duerr & Sons Ltd takes it obligations under the Modern Slavery Act 2015 very seriously and has a robust working practice to comply with its obligations. This policy document sets out those practices and gives insight into the supply chain and business processes of the company. This statement relates to the actions and activities during the financial year 1st April 2018 to 31st March 2019.
ORGANISATIONS STRUCTURE AND SUPPLY CHAINS
Established in 1881, F. Duerr & Sons Ltd is the oldest family owned Jam maker in England, supporting around 250 staff in the Manchester area. With truly global reach, F. Duerr & Sons Ltd has become one of the largest independent manufacturers of Conserves, Jams, Marmalades and Peanut Butter in the UK. We are members of the Ethical Trading Initiative (ETI).
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We internally review our supply chain to evaluate human trafficking risks and slavery risks and we conduct supplier self-assessments and audits which review all aspects of the supply chain including safety, human trafficking, child labour and other legal requirements.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. We act ethically and with integrity in all our business relationships and implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within our supply chain.
In keeping with our commitment to act with integrity in all our business dealings, many of our existing policies are relevant to ensure there is no slavery or human trafficking in any part of our business or supply chain.
Our relevant policies include:
- Standards of Conduct Policy;
- Ethical Trading Policy;
- The Prevention of Hidden Labour Exploitation Policy;
- Health & Safety Policy
- Supplier Approval Policy;
In our Ethical Trading Policy, the relevant sections cover ‘Discrimination and Harassment’, ‘Human Rights’ and ‘Responsible Procurement and Supplier Partnerships’.
Our Standard of Conduct policy sets out the behaviours we expect from employees in their dealings with colleagues, customers, consumers and suppliers. All employees and suppliers are expected to act with integrity in accordance with the standards of behaviour set out in the Standard of Conduct Policy.
We provide guidance and training at Induction to support employee understanding of expected behaviour, particularly in respect of their business decisions and code of conduct. We encourage employees to raise concerns as outlined in Ethical Trading Policy. We support and promote the Stronger Together Campaign, both internally and externally through our labour supply chains.
We believe in the business benefits brought about by diversity and equal opportunity. We therefore support collective bargaining for our own employees and through our supplier standards.
We actively support employee engagement, representation, dialogue and the ability of an employee to raise potential concerns. Freedom of association and the right to collective bargaining is a core labour standard. We apply our employment practices in line with local legislation.
RISK ASSESSMENT AND DUE DILIGENCE
The risk of slavery and human trafficking within our own organisation is substantially avoided and mitigated as a result of strict policies and procedures as well as the oversight built into our business operations and the knowledge and skills of our staff.
We consider that the greatest risk of slavery and human trafficking is in our supply chain where we undertake procurement activities and where operations and managerial oversight are out of our direct control. In addition to the training and awareness provided by our Standards of Conduct and Ethical Trading policies, we also have supplier standards and specific supplier programmes.
F. Duerr & Sons Ltd undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. The organisations due diligence and reviews include:
- Mapping the supply chain broadly to assess particular products or geographical risks;
- Evaluating the modern slavery and human trafficking risks for each new supplier through supplier self-assessment processes and audit as required;
- Conducting supplier audits;
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, indicating the termination of the business relationships.
TRAINING AND AWARENESS
We provide guidance and training to support employees understanding of the expected behaviour, particularly in respect of their business decisions and the Standard of Conduct. Training on such is demonstrated in our Induction Program for all new employees and an ongoing awareness created by workplace posters and information in relation to the Stronger Together Campaign.
BOARD OF DIRECTORS APPROVAL
This statement has been approved by the organisations Managing Director who will review and update it annually and will ensure the F. Duerr & Sons Ltd board compliance is followed.
1st April 2018