MODERN SLAVERY ACT
A review of 2021
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 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 proteinfree 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, two of our sites were audited in 2020, our most recent one was carried out at our Bradford manufacturing site in November 2020.
As part of our commitment to identify and mitigate slavery and human trafficking risks we have:-
As part of our ongoing commitment in the coming year we will:-
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 August 2021
I confirm that the information and data reporting is accurate, and can confirm that this statement is approved by the Board.
Christian Boulter and Henry Breese
Joint Chief Executive Officer’s