Modern Slavery

6th February 2018 Posted in Corporate Social Responsibility

Troy Foods: The Slavery and Human Trafficking Act Statement (UK Modern slavery act 2015) statement

Troy Foods are committed to tackling Modern Slavery and undertake to update policies and procedures, training and engagement activities to reflect the risks identified from our risk mapping activities. We aim to take a broad view and encompass the broader human rights agenda such as worker protection, civil rights and community development.

Part 1: Structure and supply chains (responsibility – Departmental Managers)
• Main products/services/customers
Processing of vegetables and value added chilled and ambient food products for supply into retail, wholesale and industrial clients.
• Company structure and subsidiaries, including outside the UK
Two independent limited companies under Private family ownership, all based in Leeds.
• Structure of supply chains
A mixture of direct and indirect contracts and spot purchasing. Most are long term relationships established over a number of years trading.
• Location countries of company operations, manufacturing activities and sourcing
Product distribution and manufacturing is all within the UK. Most supply is from within UK/Europe with minimal from the rest of the world.
• Whether suppliers are engaged seasonally and the percentage of employees on temporary/seasonal contracts
All businesses trade all year round with seasonal spikes in demand. Uplift in skill requirements are met by agency personnel and those are the only employees affected by seasonality curves and demand. None of our suppliers are used on a season basis, other than where cropping cycles determine such.
• Internal procedures to ensure adequate procurement pricing, prompt payment and good planning
All suppliers are fairly treated and have comprehensive Ts and Cs. Contract pricing is usually by tender and subject to prevailing market conditions.

Part 2: Policies in relation to slavery and human trafficking (Responsibility – HR Manager)
Comprehensive policies exist or will be added in the following areas. These are under review to ensure they include the requirements of the MSA and our broader ambitions outlined in our headline statement above.

• Policies that concern business relationships i.e. supplier code of conduct
• Recruitment and induction policies
• Procurement policy
• Whistle-blowing procedures
• Migrant labour policies
• Child labour policy
• Child protection policy
• Gender policy
• Supplier code of conduct
• Employee code of conduct
• Policies concerning remedy and compensation for labour rights abuses
• Policies relating to staff training and increasing awareness of modern slavery
• Details of any mechanism by which standards or policies are enforced

Part 3: Risk assessment and management – due diligence processes (HR Manager and departmental Managers)
We undertake to complete by 01 Sept 2018 an assessment of our status within the requirements of the MSA 2015. These considerations will include, but not be limited to:
• An assessment of the risks linked to modern slavery as detailed in section three of Beyond Compliance (i.e. high-risk sectors, lack of regulation in source countries, complex employment arrangements, presence of vulnerable workers, absence of worker representation and rights)
• Details of due diligence and/or other risk management processes, including whether they cover human trafficking and any other labour issues dealt with in the company’s policies.
• Impact assessments undertaken, including evidence of, and findings from engagement with people potentially or affected by corporate operations.
• Actions planned, and actions taken (including how actions have been prioritised) to:
o embed respect for human rights and zero tolerance of modern slavery across the business;
o address any identified risks of modern slavery;
o monitor and evaluate measures in place;
o communicate and report on modern slavery

Part 4: Effective action to address modern slavery (Responsibility HR Manager and Departmental Managers)
During the process described in part 3 above, we confirm that we will:
• Disclose of any identified instances of modern slavery and results of corrective action plans
• From Company-level grievance mechanisms, report the number of complaints made through these mechanisms and complaint resolution.
• Remedy and compensation provided for labour rights abuses.
• Publish any performance indicators used, including detailing if and how business decisions are informed by performance indicators.

Part 5: Training on modern slavery and trafficking (Responsibility HR Manager)
On completion of these steps, we affirm to:
• Provide specific training sessions on modern slavery, including awareness-raising of the signs of modern slavery and information on how to raise complaints within the company.
• Train all relevant decision-makers within the company on risks, policies and standards related to modern slavery, human trafficking and forced labour.
• Identify which suppliers have received training and capacity-building due to the risks of their operations.
• Provide evidence that training has been provided to groups at risk, to make them aware of their rights.
• Define the frequency of training (i.e. annually) and evaluation of its effectiveness via feedback from participants

Signed and approved on the ___6th_____ day of ______February_______ 2018.

Andrew Murphy (Director)