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Weetabix Limited - Slavery and Human Trafficking Statement
This statement is made by Weetabix Limited (Weetabix). It is a statement made in accordance with section 54 of the Modern Slavery Act 2015 (the MSA) and covers the financial year from 1 January 2016 to 31 December 2016 (the Financial Year).
Weetabix is a company which strives to do things in the right way and as a business we recognise our responsibility to be aware of the risks of modern slavery and human trafficking within our own organisation and supply chain.
Our Northamptonshire mills currently export to over 80 countries around the world. We employ around 1,800 staff members internationally, with the majority based within the UK, undertaking a range of roles including marketing, sales, manufacturing, finance, IT, HR, strategy and export. We also have employees undertaking sales and marketing roles based in North America, Canada, Spain, UAE, China, Ireland and Germany.
We use agency labour in our UK manufacturing areas, which is sourced through a reputable recruitment agency. We also have third party suppliers on site which provide contractors. We outsource certain services where specific expertise may be required and a number of non-key activities, such as engineer support, site maintenance and logistics are also outsourced.
All of the wheat for our big Weetabix biscuits is harvested less than 50 miles from our Burton Latimer mill by our Grower Group, which is formed of around 160 farmers dedicated to best practice and responsible production.
Within our direct supply chain, there are 83 different raw materials and co-managed vendor parties, and 44 packaging vendor parties. Our indirect supply chain currently consists of 720 active suppliers.
We have carried out a review of our direct supply chain and have concluded that the risks of modern slavery and human trafficking are low. However, we acknowledge that we must remain vigilant to the risks and ensure that our vendors understand and play their part in ensuring that modern slavery and human trafficking does not take place in our organisation or supply chains.
To find out more about what we do, please go to https://www.weetabixfoodcompany.co.uk/
3. Relevant Policies and Contracts
To further our organisation’s commitment to combating slavery and trafficking, we are taking steps to implement the following new policies, which set out our zero tolerance approach to modern slavery both within our own operations and our supply chain:
1. We have in place a Responsible Sourcing Policy which applies to all our operations and those in our supply chain. We are amending our Responsible Sourcing Policy to make specific reference to our zero-tolerance stance on modern slavery.
2. We have prepared and will be including in the future appropriate guidance to our employees through the introduction of our internal Anti-Slavery Policy, which applies to all those working for us or on our behalf.
3. We are reviewing the steps we will take when engaging with new vendors, contractors and business partners to ensure that they are aware of and will adhere to our Responsible Sourcing Policy and to assess the likelihood of slavery or trafficking existing in those organisations and what measures are already in place to combat those risks.
4. We have reviewed our existing policies and are making amendments to recognise our obligations under the Act including our Whistleblowing Policy.
5. We have introduced Anti-Slavery Clauses to our supplier contracts.
4. Risk assessment processes
We have considered the risk of modern slavery in our own operations and we have concluded that, on the basis that we are a UK employer subject to UK employment protections and practices and already have well developed checks and balances within our business, we have a low risk of modern slavery occurring in our own operations.
Our suppliers which fall into the following categories are strongly encouraged to commit and adhere to the Weetabix Standards, which include a requirement to abide by the Ethical Trading Initiative base code and to be a member of Sedex:-
• Suppliers of Ingredients to Weetabix.
• Suppliers of Packaging Materials to Weetabix.
• Those involved in the co-manufacturing, co-packing and licensed manufacture of Weetabix Brands.
We have considered the risk of modern slavery occurring in our use of external labour via employment agencies and our direct suppliers. Given the organisations that we work with and the existing checks and balances that we apply in these areas we have concluded that the risks of modern slavery are low in this area.
We have concluded that we would benefit from a higher degree of oversight in relation to our indirect suppliers and contractors where the modern slavery risk is deemed higher and this is an area of focus that we have identified going forward.
5. Due diligence processes
In order to prevent slavery and trafficking in our business and supply chains, we are taking steps to update and improve our supplier due diligence process, particularly in the case of our indirect suppliers and those suppliers not subject to the Weetabix Standards. This includes integrating and acting upon the findings of our risk assessment processes described above and taking action to embed zero tolerance of modern slavery and trafficking. We intend to take the following steps in relation to our supply chain:-
• Amending the “Weetabix Standards” to make specific reference to our zerotolerance stance on modern slavery.
• Reviewing those in our supply chain not subject to the Weetabix Standards, with a view to engaging with those suppliers where modern slavery risks are deemed higher, in order to:
o set out our zero tolerance approach to modern slavery;
o require them to confirm that they will adhere to the principles set out in our Responsible Sourcing Policy;
We will use the responses from our suppliers to judge future actions and assess what further due diligence or other steps are required.
To raise awareness of slavery and trafficking and of our policies and procedures we are developing an approach to training key staff members in this area.
We are also preparing a general staff communication setting out our zero tolerance approach to modern slavery and introducing our Anti-Slavery Policy.
7. Measuring effectiveness – performance indicators
In order to monitor the effectiveness of the steps we have taken and are intending to take to stop slavery and trafficking taking place in our business and supply chains, we intend to use the following performance indicators for the year ahead:
• We intend that key members of staff will receive relevant training, as referenced above.
• We will have issued our Anti-Slavery and Human Trafficking Policy to our workforce through a communication setting out our stance in relation to modern slavery.
• We will establish a process to gain a better oversight of our indirect supply chain and consider how best to risk assess, carry out due diligence and communicate with these suppliers in relation to MSA issues. We will consider whether it is appropriate to raise specific questions in relation to slavery and trafficking with these suppliers.
• As a minimum and focussing initially on those suppliers we deem to be higher risk, we will send out, to those suppliers not subject to the Weetabix Standards, correspondence:
o setting out our zero tolerance approach to modern slavery;
o require them to confirm that they will adhere to the principles set out in our Responsible Sourcing Policy.
• As we develop our risk assessment and due diligence processes, we will assess and consider the appropriateness of developing further measures, where we assess that there may be a heightened risk of slavery and trafficking within those organisations. We will take appropriate measures to encourage and persuade them to adopt their own measures to minimise the risks of slavery and trafficking within their own organisations and the supply chain beyond.
As referenced in this statement, we will monitor the need for further action to be taken and other key performance indicators to be implemented as we continue our risk assessment and due diligence activities and get responses from our key suppliers.
This statement has been approved by the organisation’s board of directors who will review and update it annually.
Signed on behalf of the Board of Directors by Sally Abbott