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 and Greece as well as UK-based sites. We have traded for over 10 years with over 20% of our 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 based 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 and during 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. This outlines 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, 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. Informed decisions are then made and support provided to our supply base. We are launching our revised ethical approval process for all suppliers in 2021, with a target in collating and reviewing supplier information followed by any corrective actions. We will continue to partner with our suppliers by helping sites develop and learn through correcting any non-conformances raised. This will be based upon using SEDEX’s Radar platform.
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
- Freedom of association and the right to collective bargaining are respected
- No discrimination is practiced
- No harsh or inhumane treatment is tolerated
- Regular employment is provided
- Working hours are not excessive
- Living wages are paid
We take a risk-based approach in managing ethical compliance within our supply base. All suppliers are risk assessed and their commitments made towards our ethical trading requirements form part of our assessment. We encourage all direct suppliers to register with SEDEX and achieve 100% SAQ completion. Alternatively where this is not possible, we may also allow suppliers to complete our Supplier Ethical Questionnaire or evidence compliance to the 9 points of the ETI Base Code. We use the https://www.transparency.org/ website to further enhance our risk-based approach and are currently working on utilising SEDEX’s RADAR platform to further enhance our supply chain mapping.
Within 2021, we aim to further improve and build upon our current process by implementing an 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; however acknowledge that additional work can be done in respect to further down our 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
By 2022 we will incorporate the SEDEX Radar tool to trend supplier audit non-conformances and identify common issues arising from a similar region or food category. This will help build on our awareness of current product and supply chain risks. Should critical SMETA non-conformances be raised, we will approach our MDS partners to agree achievable and proportionate corrective actions.
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 will follow up with suppliers with significant non-conformances remotely.
E.g. August 2020, when a supplier SMETA audit identified 15 separate new non-conformances, (several 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 managers 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 and we are continuing to work with them to ensure the remaining 5 are actioned.
We have stringent measures in place for vetting the ethical integrity of proposed suppliers. Unless they are a SEDEX member, 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 KPIs on anti-Modern-Day Slavery and report annually.
We have established a relationship on SEDEX with all our direct suppliers who are members to enable us to monitor their ongoing ethical audit scoring. We will continue to work with the SEDEX platform to enhance our monitoring programme and supplier approval process.
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 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, in 2021 we will provide relevant training for our new commercial trading teams, based upon the ‘Guide to Buying Responsibly’ publication, created by the Ethical Trading Initiative and International Labour Organisations.
At the end of 2020, we consulted with 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 Modern-Day Slavery statement awareness and action points detailed within this document.
We had planned to shadow a SMETA audit on one of our UK based suppliers during 2020, however this has been postponed due to the pandemic.
We are reviewing our current external partners and are looking to join FNET (https://foodnetworkforethicaltrade.com/) to obtain more industry specific ethical training and detailed risk assessments based on regions.
We will undertake additional anti-modern-day slavery training in 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 June 2021 to June 2022 and has been approved by the Directors and Board of Caterers Choice Ltd and Fruitypot Ltd.
Managing Director – Caterers Choice Ltd
Managing Director – Fruitypot Ltd