Modern Slavery 2019/2020

2nd July 2020 Posted in Corporate Social Responsibility

Modern Slavery Statement


This statement applies to Troy Foods Ltd and Troy Foods (Salads) Ltd (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year October 2019 to September 2020.

Organisational Structure

The Organisation’s group of company’s consists of Troy Foods Ltd and Troy Foods (Salads) Ltd.
Troy Foods Ltd operates out of 3 sites; Veg Processing, Retail Veg and the Distribution Hub.
Troy Foods (Salads) Ltd operates out of 2 sites; Salads Manufacturing and the Distribution Hub.

The Distribution Hub is the company Head Office and all sites are based within the United Kingdom.

Troy Foods and Troy Foods (Salads) are family owned businesses with the Chairman and Group MD maintaining ultimate responsibility for both businesses. Each business then has an MD and Senior Management Team that are responsible for the running of the business.

The main activity carried out by Troy Foods Ltd is the processing of vegetables and the manufacture of retail vegetables. There is the shared use of a transport fleet.
The main activity carried out by Troy Foods (Salads) Ltd is the manufacture of dressed salads and food to go products and the shared use of a transport fleet.

Demand across both businesses fluctuates seasonally with a core of all year round products.

The labour supplied to the Organisation in pursuance of its operation is carried out solely in the UK, in our Yorkshire based manufacturing sites.


The Organisation considers that modern slavery encompasses:

• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• being dehumanised, treated as a commodity or being bought or sold as property
• being physically constrained or to have restriction placed on freedom of movement


The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

Supply Chains

In order to fulfil its activities, the main supply chains of the Organisation include those related to the growing of fresh produce which is supplied within the UK and from international suppliers.

A mixture of direct and indirect contracts and spot purchasing. Most are long term contracts that have been established over many years.

Potential Exposure

The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in the temporary labour pool due to the transient nature of this workforce.

In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.


The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

• All supplier contracts include termination clauses in the event that the supplier ie, or is suspected to be involved in modern slavery
• Temporary labour providers are audited regularly and include human trafficking questionnaires as part of their registration process
• Stronger Together training has been completed by members of the HR department and an awareness is given to all employees at induction
• Action plans are in place to provide wider training to the management and supervisory teams
• A zero-tolerance policy would be taken to any reports of Modern Slavery

Key Performance Indicators

The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains;

• Reporting of the instances of flags or complaints made through the confidential reporting mechanism we have in place


The Organisation’s policies and procedures are currently under review. However, the following policies will be in place to further define its stance on modern slavery;

• Recruitment & Selection Policy
• Whistleblowing Policy
• Ethical Sourcing Policy
• Business Ethics Policy

Slavery Compliance Officer

All concerns regarding modern slavery should be addressed to the Head of HR, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval: 02 July 2020

Signed: Andrew Murphy
Job Title: Technical Director
Date: 02 July 2020