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Modern Slavery & Human Trafficking Statement

Introduction

This statement sets out e-foods actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and it’s supply chains. This statement relates to actions and activities during the financial year 2017/2018

As part of the Procurement sector, the e-foods recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

E-foods is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensure that its supply chains are free from slavery and human trafficking.

Organisation Structure and Supply Chains

This statement covers the activities of e-foods.

  • The principle activity of e-foods is that of organising the local supply and distribution of fresh produce, dairy, bakery, meat, dried and frozen goods to organisations with multiple outlets, who require flexible delivery with standardised pricing. In so doing we rationalise our customers’ invoicing, supplying one invoice for their whole estate and paying the supply base on their behalf.

  • Our activities are currently taken up within the UK

The following is the process by which e-foods assesses whether particular activities are high risk in relation to slavery or human trafficking:

We complete a review of this policy and statement against our activities to establish the approach we have taken follows best practice by:

  • Assessing and interpreting any recent or emerging case law and best practice;

  • Benchmarking our activities against statements and actions plans undertaken by similar organisations.

  • Undertaking a second risk assessment using professional, legal, risk, procurement and regulation teams to determine our risk exposure.

Where do we consider there to be a risk?

The principle categories which are considered to carry a risk are our suppliers whom we encourage to operate to the same ethical standards we employ ourselves.

Our Policies

e-foods operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent human trafficking in its operations:

  • Whistleblowing Policy: e-foods encourages all its workers, customers and other business partners to report to e-foods’ management team any concerns related to the direct activities of the company or its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. e-foods whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

  • Employee Code of Conduct: e-foods code of conduct makes clear to employees the actions and behaviour expected of them when representing the company. e-foods strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.

  • Supplier Code of Conduct: e-foods is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. e-foods works with suppliers to ensure that they meet the standards of the code. Serious violations of e-foods supplier code of conduct could lead to the termination of the business relationship.

  • Recruitment and Selection Policy: Employment agencies aren’t normally used, however if the situation should arise then e-foods will only use reputable employment agencies to source labour and will always verify the practices of any new agency it is using before accepting workers from that agency.

Training

e-foods intend to provide further training to our contracts teams especially procurement to ensure a high level of understanding of the risks of modern slavery and human trafficking within our supply chains.

As well as training staff, e-foods has raised the awareness of modern slavery issues by the circulation of emails to staff.

These emails explain to staff;

  • The basic principles of the Modern Slavery Act 2015;

  • What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and

  • What external help is available for example the Modern Slavery Helpline

Board Member Approval

This statement was approved on 07.12.2018 by e-foods board of directors who will review and update the Modern Slavery Statement annually.