Modern Slavery Act

Fresh-Pak Chilled Foods — Modern Slavery & Human Trafficking Statement 30 March 2021

1. Definition

Modern Slavery is the term used within the UK and is defined within the Modern Slavery Act 2015. These crimes include holding a person in a position of slavery, servitude, forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon after.

Human trafficking can be defined as “the recruitment, transportation, transfer, harbouring or receipt of persons, by means of threat or use of force or other forms of coercion; of abduction, fraud, deception, the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation”.

2. Introduction

Modern Slavery is an unacceptable crime that deprives a person’s dignity for another person’s gain. It is recognised that this is a real problem for millions of people around the world, including in many developed countries. Every company is at risk of being directly or indirectly involved in this crime through its own operations and supply chain.

Fresh-Pak Chilled Foods Ltd has a zero-tolerance approach to modern slavery and is committed to preventing such acts within our organisation and supply chain. We have taken steps to tackle modern slavery and these are outlined in our statement.

Fresh-Pak Chilled Foods Ltd will not knowingly use suppliers or labour providers that exploit job applicants/workers and will report any allegations to the relevant authorities.

3. Organisational structure and supply chains

Fresh-Pak Chilled Foods Ltd is the producer of sandwich fillings, hard boiled/poached eggs and dips. Based in Barnsley, South Yorkshire, we supply grocery multiples, high street retailers, food service outlets, food manufacturers and other commercial customers nationwide.

Fresh-Pak Chilled Foods Ltd 1st tier suppliers are located throughout the UK and Europe.

• UK
• Ireland
• Germany
• Spain
• Netherlands

Raw materials are sourced through these 1st tier suppliers are procured from the following countries of origin:

4. Supplier questionnaire

All existing suppliers have completed a paper-based questionnaire and where applicable have supplied details of SEDEX membership.

5. Supplier due diligence

Fresh-Pak Chilled Foods Ltd conducts due diligence on all new suppliers. This involves either reviewing audit results for 2nd tier suppliers or auditing the premises of 1st tier suppliers. This includes:

• Health & Safety Standards
• Food Safety Standards
• Labour Standards (ETI base code)
• Requiring improvement for any substandard practices

6. Training

Fresh-Pak Chilled Foods Ltd has incorporated Modern Slavery training into its induction programme and conducted training for all current employees. All 3^rd party agency workers are required to undergo modern slavery training prior to commencing work.

7. Awareness

Fresh-Pak Chilled Foods Ltd has raised the awareness of modern slavery by putting up posters, which explain how to spot the signs of modern lavery and details of how to report cases of suspected or actual modern slavery. New recruits are requested to complete a Stronger Together questionnaire.

8. Relevant Policies

Fresh-Pak Chilled Foods Ltd operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent modern slavery and human trafficking in its operations:

• Whistleblowing policy: Fresh-Pak Chilled Foods Ltd has a documented policy for reporting any concerns related to the direct activities, or the supply chains of the organisation. This includes concerns relating to modern slavery. The whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Employee Code of Conduct: Fresh-Pak Chilled Foods Ltd makes it clear to employees the actions and behaviour expected of them when representing the organisation, through this code. Fresh-Pak Chilled Foods Ltd strives to maintain the highest standards of employee conduct and ethical behaviour.
• Recruitment/Agency workers: Fresh-Pak Chilled Foods Ltd uses only specified, reputable employment agencies. Any new agency is audited and verified prior to commencement. Recruitment agencies are audited twice yearly by the HR Department, part of the audit process is to conduct worker address checks.

9. Responsibility

Overall responsibility for Fresh-Pak Chilled Foods Ltd labour exploitation initiatives lies with the board of directors.

Specific areas of responsibility are outlined below:

10. Performance Indicators

The organisation has set the following performance indicators for the years 2020/21.

• Assess supplier questionnaires on ethical compliance
• Target 100% supplier relationship on SEDEX
• Assess compliance of supply chain with ETI base code
• Identify high risk suppliers/sources and conduct risk assessments
• Formulate an action plan based on risk assessment findings

This statement has been approved by the organisation’s Chief Executive.

Mr S Evans

Chief Executive — Fresh-Pak Chilled Foods Ltd