Slavery and Human Trafficking Statement
Financial Year ending August 2018
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 refers to the financial year ending August 2018. It 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.
Speedboat Hold Co is the holding company for the following businesses/legal entities:-
- Speedboat LNCO Limited
- Speedboat Midco Limited
- Speedboat AcquisitionCo
- BPG EquityCo Limited
- BPG Midco Limited
- BPG Acquisitions Limited
- Brand Partnership Group Limited
- Brand Partnership (Holdings) Limited
- Symington’s Limited
- Telford 2 Limited
- William Rodgers Holdings Limited
- William Rodgers (Foods) Limited
- La Rochelle Foods Limited
- Victoria Foods Limited
- Symington’s (Holdings) Limited
- Symington’s Australia PTY Limited (Registered in Australia)
The above companies listed encompass all businesses which are in existence under Speedboat Hold Co, however Symingtons is the only trading entity which produces food products within the UK. Our food manufacturing business Symington’s is a branded and own label ambient food manufacturer with over 700 employees cross 5 sites in the UK and an annual turnover of around £120m.
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 UTZ 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 will 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.
Over the last 12 months we have completed 45 technical audits which contain elements of ethical auditing, along with Sedex audits at each of our sites.
As part of our commitment to identify and mitigate slavery and human trafficking risks during our financial year to August 2018 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;
- Selected relevant colleagues to attended external training with “Stronger Together” for current and future cascading within the business;
- 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.
As part of our ongoing commitment in the coming year we will:-
- Continue to roll our Stronger Together by ensuring that all key members of our HR and procurement teams attend the training
- Continue to train all Symington’s colleagues on our anti bribery policy;
- Continue to only work with one labour provider in regards to our operational labour supply, and will audit them a minimum of twice per year;
- Continue to ensure that only suitably trained managers book agency workers;
- We will implement director-level bi-monthly meetings with our agency provider to ensure that we share best practice and continue to build on our effective working relationship;
- Continue to complete intermittent GLA checks on our agency partner;
- We will ensure that all sites have up to date SEDEX audits in place;
- We will ensure that ethical sourcing remains a critical strategic focus, and will step up our commitment to ensuring sustainability and recyclability.
In doing the above we have set ourselves the following KPI’s which will be reviewed at the end of the financial year:-
- Increased number of technical audits within our supplier base versus previous year (specifically suppliers of agency labour)
- 90% of HR team to have undertaken the Stronger Together training workshops
- 100% of all new starters to have undertaken Stronger Together briefings
- All sites to be “green” Sedex rated throughout the year
- We will target one part of the business to trial a culture engagement survey before rolling out more broadly across the business
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 2018.
I confirm that the information and data reporting is accurate, and can confirm that this statement is approved by the Board.
Chief Executive Officer