Modern Slavery Act Statement

MODERN SLAVERY ACT

A review of 2021

Introduction

The UK Modern Slavery Act 2015 (the ‘Act’) requires businesses to state the actions they have taken during the financial year to ensure modern slavery is not taking place in their operations and supply chains. We are fully committed to playing our part in eradicating modern slavery through our operating subsidiary businesses. We firmly advocate for transparency and collaboration to eliminate the risks of modern slavery. This statement sets out the steps taken by Symington’s Limited to prevent modern slavery and human trafficking in our own operations and supply chains.

We are committed to making best endeavours to ensure that there is no modern slavery, human trafficking or forced labour within our own business or indeed our supply chain. We are committed to continuously review and improve business practices to combat slavery, human trafficking and forced labour. Our value of “doing the right thing” extends to everything that we do, and that includes ensuring that our operations and supply chain are free of slavery and human trafficking

Our Business

Our parent company is Newlat Food SpA, a family-run business, based in North Italy. It’s one of Italy’s leading producers of milk, milk products, pasta, baked goods, baby food and gluten-free and protein free products, from multiple sites across Italy and Germany. Acquiring Symington’s in 2021 was a strategic move for Newlat in their exciting growth plans for the UK, America and Canada. There are many synergies between our businesses which make us a great fit for our products and distribution across the world and we are very proud to be part of the Newlat family.

Our position on Modern Slavery and Human Trafficking

This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems to ensure slavery and human trafficking is not taking place within either our own business or within our supply chain.

Due Diligence process for Slavery and Human Trafficking

We are committed to developing sustainable and strategic partnerships with our key suppliers. This is demonstrated through long term supply contracts, which drive mutual benefits and value.

Our aim is to source materials certified to meet recognised environmental and ethical standards, such as cocoa horizons or the rainforest alliance for all chocolate and cocoa products, sustainable palm oil from producers that meet the Roundtable for Sustainable Palm Oil (RSPO). We value the integrity of our materials and hold supply chain maps for all high-risk ingredients; the support of our supply base is essential in this. Across our packaging supply base we are actively championing more environmentally friendly and sustainable solutions.

The majority of our procurement activities are within Europe although we do use some suppliers from outside this area. We use a risk-based approach to audit “high” and “medium” risk suppliers, carrying out technical / SMETA audits. We prioritise our highest risk suppliers and ensure that suitable rigorous diligence is demonstrated in this regard.

All suppliers are put through a systematic, documented verification process which is designed to objectively obtain and evaluate evidence, to determine whether the supplier conforms to the required labour standards. Packaging and ingredient suppliers who are deemed to be medium and high-risk suppliers (determined by reference to the supplier Sedex risk rating, geographic sourcing region and nature of the product supplied), will have a greater level of due diligence actions undertaken regularly throughout any period of supply. All individuals performing these checks within Symington’s are suitably trained in the relevant internal procedures that govern the approval process.

Our labour providers are GLA registered, and we have an automatic alert via the GLA website to notify us of any change in status. Our supplier of industrial labour is required to undertake 6-monthly audits which include elements of ethical practices, and they are required to meet our expected standards in order to continue to supply labour to us. The audit includes the elements of the ETI base code and encourages continual improvement to the highest standards. As part of these audits, we conduct worker interviews with random group of colleagues equally distributed across each of our sites, this enables us to support and verify the audit findings.

Despite the challenges as a result of the pandemic, we have continued to complete technical audits (using a mixture of virtual and on-site assessments) which contain elements of ethical auditing. Our Sedex SAQ’s for each sites are continually updated, three of our sites were audited in 2021.

As part of our commitment to identify and mitigate slavery and human trafficking risks we have:-

Complied with ethical standards across the business via external third party validation;
Followed supplier approval system requiring suppliers to submit information regarding their ethical standards, Health and Safety, environmental management and people processes against which they are risk assessed and suppliers are reviewed in line with their risk rating;
Continued to train all Symington’s colleagues on our anti-bribery policy when they join the company;
Ensured all managers across the group have now attended external training with Stronger Together. Provide all sites with multi language workplace posters displayed in communal areas to raise and maintain awareness and encourage reporting should there be any evidence or suspicion of either forced labour or human trafficking within the business or supply chain;
Continued to partner with a fully committed agency that are registered with the Gangmasters Licensing Agency (GLA) and signed up to the stronger together program;
Completed intermittent GLA active checks on our agency partner and have registered for immediate updates if there are any changes to their status; and
Identified suitably trained managers to book agency workers to ensure that the selection of workers is fair, transparent and non-discriminatory.
Reviewed the audit process we use for our labour suppliers to ensure it covers expectations of the highest ethical standards.
Ensured that any new labour providers we engage with are audited prior to engagement
Regular meetings take place with Mach (labour provider) to ensure that they remain 100% compliant with UK Labour Laws and all workers it supplies are free from treatment that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses as well as monitoring working hours and training requirements.

As part of our ongoing commitment in the coming year we will:-

Continue to roll out stronger together training on an annual basis to ensure new colleagues have the relevant training and to keep knowledge up to date. Implement refresher e-learning training modules. Roll out more in-depth management training across all of our sites. This will include anti-bribery training on boarding training. Return to face-to-face audits after the pandemic and continue to ensure these are carried out a minimum of twice per year Continue to ensure that only suitably trained managers book agency workers;
Continue to complete intermittent GLA checks on our agency partner;
We will ensure that all sites have up to date SEDEX audits in place with ethical champions across all work locations;
We will ensure that ethical sourcing remains a critical strategic focus and will step up our commitment to ensuring sustainability and recyclability. Place specific focus on developing and launching equality and diversity initiatives

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s Slavery and Human Trafficking Statement for the financial year ending December 2021

I confirm that the information and data reporting is accurate and can confirm that this statement is approved by the Board.

Christian Boulter
Chief Executive Officer

October 2022