Slavery & Human Trafficking

Introduction

This statement sets out Jon Thorners 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 its supply chains. This statement relates to actions and activities undertaken during the financial year 1st April 2020 to 31st March 2021 and to activities that are planned for this period.

As part of the food storage and distribution industry, the organisation recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking.

Our organisation is absolutely committed to preventing modern slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from modern slavery and human trafficking.

Ethical Trading Initiative Base Code

Jon Thorners respects and adheres to internationally recognised human rights principles and in particular the Ethical Trading Initiative Base Code. This code contains the following nine clauses which are founded on the conventions of the International Labour Organisation and are an internationally recognised code of labour practice:

– Employment is freely chosen
– Freedom of association and the right to collective bargaining are respected
– Working conditions are safe and hygienic
– Child labour shall not be used
– Living wages are paid
– Working hours are not excessive
– No discrimination is practiced
– Regular employment is provided
– No harsh or inhumane treatment is allowed

Jon Thorners is committed to ensuring that all its dealings with suppliers are conducted in line with such ethical and responsible trading requirements.

Due Diligence on New Suppliers

We require our new suppliers to go through a detailed process before approval to supply is granted. Suppliers are expected to update the information provided on an annual basis for further review and approval by the technical team. This annual review process ensures that our due diligence remains up to date and relevant.

Our supplier SAQ includes questions on compliance with the Modern Slavery Act. The new supplier process allows us to determine which suppliers are most at risk for responsible sourcing challenges and, for those that are high risk suppliers, we will prioritise a site audit. Following a site audit, we will notify the supplier of any remedial action required. We will only continue to trade with those suppliers who fully comply with our Slavery and Human Trafficking Policy Statement and our Ethical and Sustainable Sourcing Policy Statement, or those who are taking verifiable steps towards compliance.

Organisational structure and supply chains

This statement covers the activities of Jon Thorner’s

• Jon Thorners produces, stores and distributes frozen, chilled and ambient goods. We supply the South-West of the UK. Products are supplied from a range of UK supply bases.

Countries of operation and supply

The organisation currently operates in the following countries:

• United Kingdom

High-risk activities

The following activities are considered at high risk of slavery or human trafficking:

• Fruit & veg picking on farms
• Food processing
• High risk foods from emerging economies include – crustacea, corn, palm oil, poultry, rice, sesame, wheat, sugar, coffee, cocoa beans, nuts & tea

Responsibility

Responsibility for the organisation’s anti-slavery initiatives are as follows:

• Policies: The Managing Director is accountable for overseeing all Jon Thorner’s policies in relation to its own workforce.
• Risk assessments: The Managing Director is accountable for overseeing the auditing of all packaging, product and ingredient suppliers to Jon Thorners
• Investigations/due diligence: During the financial year 2019/2020 there were no known breaches or suspected instances of slavery and human trafficking with respect to Jon Thorners
• Training: The Managing Director is accountable for ensuring that Modern Slavery
Awareness Training in the organisation is delivered accordingly.

Relevant policies

The organisation operates the following policies that links its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Jon Thorners Recruitment Policy – We ensure that all new employees provide proof of their identification and right to work in the UK. This involves physical checks of employee’s passports or birth certificates.
• Provision for Agency Workers Policy – Jon Thorners uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due diligence

The organisation aims to undertake due diligence when considering taking on new suppliers, and to regularly review its existing suppliers.

Jon Thorners will:

• Ensure supplier approval questionnaires are sent to all suppliers with questions referring to slavery and human trafficking

Training

We recognise that to achieve the successful implementation of any anti-slavery and anti-human trafficking policy, it is vital to train and raise awareness with those employees who have the potential to deal with our suppliers on a regular basis. The organisation will require all staff working in Procurement, Technical and HR to complete training on modern slavery.

The organisation’s modern slavery training covers:

• Our business’s purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
• How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
• How to identify the signs of slavery and human trafficking;
• What initial steps should be taken if slavery or human trafficking is suspected;
• How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• What external help is available, for example through the Modern Slavery Helpline, Gangmasters etc.
• Licensing Authority and “Stronger together” initiative;
• What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• What steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Awareness-raising programme

As well as training staff, the organisation raised awareness of modern slavery issues by putting up posters across our premises. The posters explained 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 through the Modern Slavery Helpline.

Steps to be Taken in the Future

We see the implementation, measurement and raising of awareness and standards across the business and supplier base as being an ongoing project. We will continue to draw on industry best practice and evolve our supply chain in the best way possible to ensure that we are continually assessing the effectiveness of preventing slavery and human trafficking.
Implementation plans include:
– Review and amend contract terms and conditions with suppliers
– Complete risk assessment for all suppliers
– Carry out physical supplier audits
– Achieve visibility of second and third tiers of supply chain
– Develop ethical audit programme encompassing human rights, sourcing principles and supply chain transparency
– Develop best practice encompassing industry codes of conduct (CIPS) and audit standard (SEDXEX)

Board approval

This statement has been approved by Jon Thorner’s Managing Director, who will oversee its review annually.