Modern slavery
and Human Trafficking Policy

Policy Statement

This Modern Slavery and Human Trafficking Policy (“Policy”) documents our steadfast commitment to eliminating and preventing all forms of modern slavery, including human trafficking, forced or compulsory labour, and child labour, in our operations and supply chains. We are a fresh fruit and vegetables supplier operating within the United Kingdom and sourcing produce, workforce, and services both domestically and from overseas partners.

We recognize that modern slavery is a heinous violation of fundamental human rights. Therefore, we adopt a zero-tolerance approach to any such practices. Our organization holds itself to the highest ethical standards and expects the same from all partners, suppliers, contractors, and individuals who carry out work in our name.

This Policy is informed by relevant UK legislation, including the Modern Slavery Act 2015 and updated statutory guidance, and is consistent with recognized international standards such as the UN Guiding Principles on Business and Human Rights, OECD Guidelines for Responsible Business Conduct, and International Labour Organization conventions.

We are committed to ensuring that our approach to tackling modern slavery is transparent, effective, and subject to continuous improvement. By regularly reviewing and updating our procedures, we seek to remain at the forefront of ethical sourcing and responsible labour practices within the fresh produce industry.

Scope

This Policy applies to:

• All employees, directors, officers, and casual staff working for or on behalf of our organization in any capacity, including permanent, temporary, or seasonal staff.
• All contractors, subcontractors, suppliers, growers, distributors, agencies, consultants, and any other third parties engaged in the provision of goods or services to our company.
• Each person or entity within the scope of this Policy is expected to act in accordance with its content and spirit. Any violation, actual or suspected, will be investigated and, where appropriate, addressed with decisive measures, as outlined in Section 9 (Breach Consequences).
• This Policy covers all sites our organization operates or contracts with:
  • Farms that supply fresh fruits and vegetables.
  • Packing facilities, warehouses, and distribution centres.
  • Offices and administrative locations.
  • Subsidiaries and joint venture partners in which we have direct or indirect involvement.

The Policy applies regardless of the country in which the business activities take place. In jurisdictions where local laws may be less stringent, we will still adhere to these fundamental principles to prevent modern slavery and human trafficking.

Definitions

Modern Slavery

• Slavery: A situation where one person exercises ownership rights over another or exerts a level of control so that the victim loses his or her freedom.
• Servitude: The obligation to provide services imposed by coercion, where a victim cannot change their condition.
• Forced or Compulsory Labor: Any employment or work that is required under threat of any penalty if the person has not offered himself or herself voluntarily.
• Human Trafficking: The arrangement or facilitation of an individual’s travel or recruitment for the purposes of exploitation. This applies irrespective of whether the victim consents to travel.

Child Labor and Exploitation of Children

• Any labour involving persons under the age of 18 that is inconsistent with relevant national laws or international standards, or that is harmful to the child’s health, safety, or development.
• Children are considered victims of trafficking whether or not coercive means have been used.

Worker

• Refers to permanent employees; contracted, agency, and migrant workers; interns; apprentices; volunteers; or any other individual performing tasks directly or indirectly for our organization.

High-Risk Suppliers

• Any individual or organization that operates in jurisdictions with weaker regulatory oversight, employs low-skilled or seasonal labour, subcontracts frequently, or demonstrates any red flags—such as inability to prove compliance with labour standards or use of unscrupulous recruitment agencies.

Responsabilities

Senior Leadership Team

• Bear overall responsibility for ensuring the effective operation of this Policy.
• Provide sufficient resources for policy implementation, monitoring, and improvement of anti-slavery procedures.
• Ensure that an annual Modern Slavery Statement—that reflects the organization’s risks and mitigation strategies—is approved and published when legally required.

Compliance Officer or Designated Manager

• Oversee day-to-day operational execution of the Policy.
• Establish and maintain processes for risk assessment, due diligence, and incident reporting.
• Develop and facilitate training and awareness programs, ensuring that content is kept up to date in light of emerging risks and legislative changes.
• Coordinate with suppliers, auditors, NGOs, and relevant sector bodies to stay current on recognized best practice in reducing modern slavery risks.

Department Managers and Supervisors

• Communicate this Policy’s requirements to all staff under their supervision.
• Remain vigilant for warning signs of modern slavery, such as suspicious changes in worker behaviour, shared addresses or bank accounts, or unexplained deductions from wages.
• Immediately report concerns to the Compliance Officer or Designated Manager.
• Incorporate modern slavery due diligence measures in relevant contracts and
  operational processes.

Employees and Other Personnel

• Familiarize themselves with the contents of this Policy and remain alert to signs of exploitation or forced labour.
• Use the reporting mechanisms described in Section 8 if they have knowledge or suspicion of any breach of this Policy within the business or our supply chain.
• Cooperate fully with all internal and external investigations related to compliance with this Policy.

Risk Assessment and Due Diligence

Identification of Risks

• Our company recognizes that, in the fresh fruit and vegetables sector, certain factors elevate the risk of modern slavery, including:
  • Seasonal nature of agricultural work, often involving migrant labour.
  • Use of third-party labour contractors and recruiters.
  • Complex, tiered global supply chains for produce.
  • Potential for exploitation of vulnerable populations, such as refugee or undocumented workers.
• We carry out periodic reviews of risk exposure at multiple stages: growing, harvesting, packing, distribution, and associated support services in our supply chain.

Due Diligence Framework

• Tiered Supplier Mapping: We strive to map and document all suppliers in our direct (Tier 1) and, where feasible, indirect (Tier 2 and beyond) supply chains. This is supplemented by targeted risk-based approaches for higher-risk tiers.
• Supplier Onboarding: All potential new suppliers undergo an evaluation that may include:
  • Completion of self-assessment questionnaires and modern slavery declarations.
  • Documented evidence of adherence to labour standards and relevant certifications (e.g., GLA licenses for labour providers or membership in recognized fair labour associations).
  • Independent background checks, focusing on labour practices and repute.
• Contractual Clauses: Contracts with our service suppliers and the Code of Conduct that governs growers and good wholesalers include clauses that prohibit modern slavery and obligate them to cooperate with audits, training and investigations.
• Ongoing Monitoring and Audits:
  • We conduct scheduled and, where warranted, unannounced audits on high-risk suppliers. Audits may involve interviews with workers, onsite visits, verification of pay records, and inspection of living conditions.
  • We use both internal auditors and, when necessary, independent external auditors with specialized expertise in labour rights.
  • We pay special attention to red-flag indicators:
• Wage payments not made directly to workers.
• Employment contracts used by agencies or subcontractors not translated into the workers’ primary language.
• Fees charged to workers for recruitment.
• Unusual or excessive deductions in wages.
• Workers consistently accompanied or monitored by ‘representatives’ not authorized by management.
• Corrective Action Plans (CAPs):
  • Where an audit or investigation reveals non-compliances, we develop action plans that clearly set out remediation timelines and follow-up procedures.
  •  If a supplier demonstrates an unwillingness to implement corrective measures or breaches the Policy to a severe extent, we may suspend or terminate the contractual relationship.

Recruitment and Employment Practices

Fair Recruitment

• All recruitment activities, whether direct or via agencies, adhere to the principle that no worker should pay for a job. We require that labour providers do not charge recruitment fees to job seekers.
• Prior to engagement, our own hiring teams conduct right-to-work checks, confirm identity, and ensure that no personal documents are withheld.
• Where external agencies are used to recruit overseas or migrant workers:
  • We engage only reputable agencies that can demonstrate compliance with labour standards, often through licensing schemes such as the Gangmasters & Labour Abuse Authority (GLAA).
  • We require agencies to disclose any sub-agent relationships and keep accurate data on the identity of sub-agents.
  • We ensure workers are fully informed, in a language they understand, about contract terms, pay rates, and living conditions.

Worker Contracts and Conditions

• Every worker receives a written contract in a language they understand, specifying:
  • Roles, responsibilities, and hours of work.
  • Rate of pay and grievance procedures.
  • Overtime policies, including pay rates, and confirmation that overtime is voluntary.
• We strictly prohibit any retention of identity documents, financial deposits, or similarly coercive practices.
• No worker is forced to work beyond their agreed hours, and they are free to terminate
  employment after serving relevant notice without penalty.

Wages and Payroll

• We comply with all applicable national minimum or living wage legislation. Where possible, and to the extent feasible, we aspire to pay a living wage that exceeds statutory minimum thresholds.
• We ensure that wages are paid directly, into accounts bearing the workers’ own names, and that any deductions are lawful, transparent, and agreed upon with full consent.

Working Hours, Holidays, and Leave

• We respect statutory requirements around maximum weekly working hours, breaks, and rest periods, particularly in harvest and peak seasons.
• Workers are entitled to paid leave, consistent with legal minimums, and must have the right to take leave or sick days without fear of losing their job or facing intimidation.

Training and Awareness

Mandatory Training

• All employees, including new starters and seasonal staff, receive training on this Policy as part of their induction. Training addresses the following areas:
  • Definitions of modern slavery and human trafficking.
  • Signs and indicators of forced or bonded labour.
  • Our internal reporting mechanisms and whistleblowing procedures.
  • Consequences for individuals and the company if modern slavery is discovered.
• We conduct refresher sessions at appropriate intervals or when changes in legislation or prevailing risks warrant updated guidance.

Specialized Training

• Human Resources and Buying teams receive more in-depth sessions, focusing on:
  • Identifying high-risk suppliers during the selection process.
  • Carrying out compliance audits and addressing red flags.
  • Conducting thorough background checks on labour agencies and staff recruiters.
• Onsite farm managers and quality control supervisors receive specialized training to detect irregularities in living and working conditions for seasonal and migrant workers. They are taught how to discretely interview workers and escalate concerns promptly.

Measuring Training Effectiveness

• We monitor training participation rates, staff feedback surveys, and incident reports to gauge awareness.
• Training materials are updated as new lessons are learned through internal investigations or as new best practices emerge in the broader industry.

Reporting Mechanisms

Confidential Reporting Channels

• We maintain a confidential hotline or web portal (where feasible) accessible to employees, workers, suppliers, and any business partner. These channels allow anonymous reporting of suspected violations of this Policy or related concerns.
• We deploy multiple languages on the hotline or web portal to ensure accessibility for migrant workers.

Whistleblowing Protections

• We unequivocally prohibit retaliation against anyone who reports genuine concerns in good faith under this Policy. Any act of retaliation will be treated as misconduct and subject to disciplinary action.
• Managers who receive any tip-off or concern must forward it to the Compliance Officer promptly.

Investigation Protocol

• Any concern raised is taken seriously and investigated swiftly by internal teams or, where necessary, by external professionals.
• Investigations follow fair procedures and maintain confidentiality, limiting disclosure of information only to those who need to know for the resolution of the matter.
• Where the concern is substantiated, appropriate remediation measures are implemented, including supporting potential victims and reviewing or sanctioning the supplier(s) involved.

Reporting Back

• The Compliance Officer or designated investigator aims to provide feedback to the whistleblower (if contact details are available) regarding the outcome of the investigation or remedial steps taken, subject to any legal constraints.

Breach Consequences

Internal Staff

• Any employee found complicit in modern slavery or human trafficking—either by neglecting their responsibility to follow this Policy or by enabling such practices—faces disciplinary action, up to and including termination of employment.
• Managers or supervisors who fail to report or act upon known indicators of forced labour may be subject to disciplinary measures, given the severity of the matter.

Suppliers, Contractors, and Partners 

• We reserve the right to suspend or terminate relationships with any supplier, subcontractor, or business partner that is found, after due investigation, to be engaging in or tacitly allowing modern slavery practices.
• Depending on the seriousness of the violation, we may notify authorities or collaborate with other legal channels.
• Where feasible and appropriate, we may work with a supplier to develop a Corrective Action Plan and only consider terminating the relationship if the supplier refuses or fails to take remedial steps within agreed timelines.

Legal and Regulatory Ramifications

• We understand that modern slavery is a criminal offense in the UK and will cooperate fully with law enforcement agencies if instances of such practices are discovered in our supply chain or operations.
• Non-compliance can lead to significant reputational damage, legal action, and potential fines. We are committed to doing everything possible to avoid these outcomes by adhering to best practices in supply chain management.

Continuous Improvement and Review

Annual Review and Modern Slavery Statement

• Senior Leadership Team formally reviews this Policy on an annual basis, taking into account any legislative changes, emerging risks, or feedback from stakeholders.
• If our annual turnover meets or exceeds statutory thresholds, we will publish a Modern Slavery Statement within six months of our financial year-end, detailing the steps we have taken to detect and prevent modern slavery in our operations and supply chains.
• This Policy will evolve through updates that reflect new best practices, developments in UK employment standards, and lessons learned from our audits, investigations, and collaborations with external stakeholders.

Goals, Targets, and Key Performance Indicators

• We set measurable targets each year, such as:
  • Completing audits at a defined number of high-risk suppliers.
  • Reducing the incidence of identified non-compliances.
  • Scaling up training reach, ensuring 100% of staff and relevant suppliers are trained.
• Key performance indicators track progress against these targets, which are monitored by the Compliance Officer and reviewed by senior leadership.
• Data from monitoring and evaluation feeds into updated training programs, improved audit methodologies, and refined contract clauses.

Stakeholder Engagement

• We maintain constructive dialogue with industry associations, NGOs, worker representatives, and regulatory bodies to remain current with evolving standards of modern slavery prevention.
• We seek feedback from employees and suppliers on the effectiveness of our anti-slavery measures to foster continuous improvement.
• Where relevant, we collaborate with other food industry stakeholders on sector-wide initiatives aimed at eradicating forced labour, illegal recruitment fees, and worker exploitation.

Remediation and Lessons Learned

• Should an instance of modern slavery be confirmed, we enact a Remediation Plan tailored to the specific situation, putting the welfare of victims at the forefront.
• We use root-cause analysis to identify areas of system failure or oversight and then strengthen corresponding policies, processes, or training tools.
• Where possible, we share non-sensitive insights and best practices across our wider supply chain and relevant industry platforms, aiming to reduce future risks collectively.

Record-Keeping and Documentation

• Comprehensive records of risk assessments, supplier audits, training sessions, and internal investigations are securely stored and maintained for a period that meets or exceeds statutory requirements.
• Records are periodically reviewed to detect emerging trends, measure the effectiveness of initiatives, and plan targeted improvements to eliminate potential vulnerabilities.

Conclusion and Effective Date

This Policy takes effect immediately upon approval by our Senior Leadership Team. It demonstrates our unwavering determination to protect the dignity and rights of every individual involved in our supply chains and business operations. By adhering to the principles set out in this document, each employee, supplier, and stakeholder plays an essential role in helping to prevent modern slavery and uphold the highest standards of ethical conduct in the fresh fruit and vegetables industry.