Slavery and human trafficking remains a hidden blight and is a growing concern in both industrialised and developing economies. Caterers Choice and Fruitypot take their responsibilities under the Modern Slavery Act 2015 very seriously and operate a zero-tolerance approach to forced labour and slavery of any kind within the organisation and global supply chain. Every colleague has a responsibility to be alert to the risks and report concerns. Management are expected to act upon them.
Business, Supply chains, Structure
Caterers Choice Ltd & Fruitypot Ltd are Yorkshire-based leading importers of canned goods and ambient products, operating from one central office located in West Yorkshire. Established in 1988 by the current Chairman, Fruitypot later followed in 2007 and was established as a separate business in 2016.
The majority of our trade is in skipjack tuna, however products range from tomatoes, dried pasta, beans, pulses, flavoured jellies, fruit, through to dry bread mixes. The distribution of these goods is carried out by an approved third-party haulier; supplying our customers based throughout the UK and Northern Ireland, supplying food service, manufacturing and retail sectors with own and supplier branded goods, as well as private retail.
The business has strategic long-standing relationships with global suppliers, ranging from Thailand, Indonesia, and China, through to Turkey, Greece as well as UK-based sites. We have traded for over 10 years with over 20% of suppliers and 5 years for 45% of our supply base. We believe that building and maintaining a high level of trust with our suppliers, as well as our customers, is crucial in continuing an honest and transparent working supply chain. Caterers Choice and Fruitypot Ltd encourage best practice regarding anti-modern slavery and are committed in supporting all suppliers who share the same values for fairness and human rights.
The business is comprised of 28 colleagues across both companies, with everyone situated at the one Yorkshire-based site. The business is committed in understanding the importance of continuous reflection and improvement on ethical, social and environmental concerns within our supply chain. These are discussed at Director meetings on a bi-annual frequency, as well as monthly technical meetings. With full support from the Managing Directors and Co-Directors, dedicated Category Technical Managers hold the responsibility for guiding and directing the business on anti-slavery initiatives, reviewing the status and aiming for continuous improvement on our ethical and social objectives.
Anti-Slavery and human trafficking policies
Our Ethical & Social Trading Policy is a core element of our commitment in responsible sourcing, which details our commitment in supporting and adhering to the Ethical Trade Initiative (ETI) as an agent & broker, cascading our expectations through to our suppliers. We work with External partners, including Slave Free Alliance, Hope for Justice and Global Tuna Alliance who continuously support our development and understanding of the risks relating to our supply chain and business operations. Working with these partners’, we have developed our own understanding and progress in developing policies, procedures and internal training.
We acknowledge that due to the number of our products and suppliers and their related country of origin; the risks associated can vary and therefore supply chain mapping is key in ensuring as much detail is captured as possible. By evaluating individual suppliers, their product and origin related ethical and social risks, we collate and review a significant amount of information, enabling informed decisions to be made and support provided within our supply base. The business aims to initiate a revised ethical approval process for all current and new suppliers in Q1 of 2021, with a target in collating and reviewing supplier information by Q2, followed by any corrective actions. We appreciate the importance of working with suppliers and helping sites develop and learn through correcting non-conformances.
Identification of risks, steps taken to prevent and manage risks
Our Ethical Trading Policy is a core element of our commitment to responsible sourcing and we require senior management in all organisations to take full accountability for ethical compliance. Suppliers within our global supply chain must work towards meeting the following requirements as a minimum:
- Employment is freely chosen
- Child labour is not used
- Working conditions are safe and hygienic
- Wages meet national legal or industry benchmark standards (as a minimum)
- No discrimination is practiced
- No harsh or inhumane treatment is tolerated
- Regular employment is provided
We take a risk-based approach in managing our ethical compliance within the supplier base. All suppliers either complete a Supplier Ethical Questionnaire or supply company documentation covering the key elements of the Supplier Ethical Questionnaire to confirm they are supportive of our stance on ethical trading. As part of this they are required to indicate if they are compliant to the ETI Base Code. We encourage our direct Suppliers to register with SEDEX. All suppliers are risk assessed and their stance on ethical trading is a part of this risk assessment. We use the https://www.transparency.org/ website to further enhance our risk based approach.
During 2021, we aim to further improve and build upon our current process by implementing our updated supplier ethical risk assessment questionnaire for tier one suppliers; continuing a risk-based approach, this will include an additional ‘weighting’ for each question, to provide further emphasis on the severity of the individual requirements. The additional information will enable closer scrutiny and therefore better risk assessment and consequent prioritisation of next steps. Alongside our updated ethical approval process, we aim to continue using external portals such as Sedex to provide visibility of individual sites through their SAQ and ethical audit reports (i.e. SMETA.) We have made positive progress so far with specific suppliers whom we have supported by helping staff learn and understand the short and long-term corrective actions required on certain non-conformances. Not only has this helped the site develop, but also strengthened the relationship from both sides in acknowledging the benefit of transparency and open communication when it comes to continuous improvement.
We have a good understanding of our suppliers, but further work is required further down the supply chain. For example; having greater understanding where multiple crop growers feed into co-operatives who may also supply through agents, associations, and contract packers. The greater the complexity of a supply chain, the more opportunity for modern-day slavery acts to hide. We will continue to utilise Sedex to help us monitor the supply base.
Due diligence processes
To manage and ensure the robustness of our systems and processes, we review non-conformances raised on the back of our suppliers SMETA audits. Going forwards, we will track SMETA non-conformances in greater detail, and conduct trend analysis to identify common issues arising from the same suppliers or from a similar region or food category.
The Covid 19 pandemic has adversely affected our ability to visit our supplier base and conduct face-to-face discussions around ethical issues such as modern-day slavery. As soon as it is safe to travel we will resume supplier visits. In the interim, we follow up with suppliers with significant non-conformances remotely.
E.g. August 2020, when a supplier SMETA audit identified 15 separate new non-conformances, a number of which were classed as major. We put together a matrix of the non-conformances to aid a focused videocall with members of senior management from the supplier and their agents. Senior trading manager at Caterers Choice also joined, to provide commercial backing. At this meeting we confirmed proposed actions and deadlines for completion. The supplier has now made good progress, closing out 10 of the 15 non-conformances. We are continue to work with them to ensure the remaining 5 are actioned.
In 2021, we will complete a Human Rights Impact Assessment (HRIA) with our relevant partner. This will enable us to manage and mitigate any priority risks that come out of the assessment.
Where critical SMETA non-conformances are raised, we will approach our MDS advisory group partners to confirm whether corrective actions are proportionate or seek advice where necessary.
We have stringent measures in place for vetting the ethical integrity of proposed suppliers. Unless they are a Sedex member/they comply with the ETI Base code and local legislation on employment law/ have undertaken a 3rd party ethical audit, etc. they will not be approved.
Effectiveness in ensuring slavery and human trafficking is not happening
As part of our continuous improvement we will publish a set of KPIs on anti-Modern-Day Slavery and report annually against them once established.
We have established a relationship on Sedex with all our direct suppliers who are members, to enable us to monitor their ongoing ethical audits scoring. In HY1 we will work with Sedex to develop a monitoring programme for our suppliers using their system.
Training and capacity building
Whilst the responsibility to monitor compliance on modern slavery requirement sits with members of the technical team, we recognise that the duty to prevent modern slavery within our supply chain requires companywide participation, particularly with our commercial and trading team whose actions, as identified above, can have a direct impact on labour in the supply chain.
With this in mind, we will provide relevant training for our commercial trading teams (based upon the ‘Guide to buying responsibly’ publication, created by the Ethical Trading Initiative and International Labour Organisations).
This year, we consulted with a Slave-Free Alliance on how we can improve our methods and procedures for monitoring and preventing modern slavery. As a result, we have strengthened our Anti-Modern-Day Slavery statement.
We had planned to shadow a SMETA audit on one of our UK based suppliers during 2020, this has been postponed due to the pandemic.
We are currently reviewing our current external partners and are looking to join FNET (https://foodnetworkforethicaltrade.com/) to obtain more industry specific ethical training and more detailed risk assessments based on regions.
We will undertake additional anti modern slavery training in Q1 2021. This will be completed through the Stronger Together initiative who provide training targeted towards: –
- Further understanding of the risks of modern slavery
- Forced labour and hidden labour exploitation
- How to recognise the signs that someone may be exploited
- How to respond to exploitation and take preventative action to minimise the risk of it further.
Approval of Modern Slavery Statement
This statement covers period 22/12/2020 to 22/12/2021 and has been approved by the Directors and board of Caterers Choice Ltd and Fruitypot Ltd, at the board meeting on 22/12/2020.