Introduction
Puffin Produce Ltd welcomes the requirements of Section 54 (1) of the UK Modern Slavery Act 2015. This statement supports our commitment to operate free from any kind of modern slavery in a part of our business and supply chain by understanding our risks and taking all reasonable steps to comply with the provisions of the Act.
Organisation
Puffin Produce Limited, is a food manufacturer operating from our main site in Haverfordwest. The company processes and packs fresh produce and flowers for delivery into supermarkets and the wholesale markets. Labour used within the organisation is sourced from within the UK labour market and via agencies recruiting overseas workers via the Seasonal Agricultural Workers Scheme (SAWS) and those individuals who have settled or pre-settle status.
Supply Chains
The company’s main business is derived from the purchase and resale of fresh produce from growers within the UK, predominately within Wales, who are regulated by UK legislation with regard to employment law, health and Safety legislation, Working Time Regulations and Human Rights legislation. In addition to this all of our growers are required to be members of SEDEX and comply with the standards outlined by the ETI base code. In some circumstances we may purchase equipment and products from outside the UK but these suppliers are all based within the EU.
Policies
The Company has the following policies which further define its stance on modern slavery:
• Modern Slavery Policy
• Human Rights Policy
• Younger worker and Child labour Policy
• Whistleblowing Policy
Potential Risk
Modern slavery is a serious crime being committed across the UK in which victims are exploited for someone else’s gain. It can take many forms including trafficking of people, forced labour, sexual exploitation and servitude. Because of its hidden nature, it is often hard to identify. We consider the predominant risks for our business to be human trafficking and labour exploitation due, in the main, to our supply of labour via agencies from countries where protection against breaches of human rights maybe limited.
However, the company considers its exposure to be relatively limited as it has taken steps to ensure that labour is only sourced through reputable agencies and worker recruitment practises and welfare is monitored directly with individuals.
Due diligence
The company takes a number of steps to reduce the risk and impact of modern slavery.
• We are members of SEDEX and undergo third-party ethical audits on a regular basis.
• We only source labour from GLAA registered labour providers and audit them prior to engagement.
• Workers supplied via agencies complete a worker recruitment interview to ensure that no exploitation has occurred during the recruitment process or during the assignment period.
• Our grower declaration requires all growers to be members of Sedex, agree to adhere to the ETI base code and only use GLAA registered labour providers.
• All staff are provided with Modern Slavery training during induction so that they are aware of modern slavery indicators and steps to take if they believe people are being exploited.
• Key members of staff are required to attend third party modern slavery training to provide a higher level of understanding of the risks of modern slavery and human trafficking in the UK supply chain.
• Right to work checks are completed for all colleagues on commencement of employment.
• A confidential whistleblowing hotline is in place for colleagues to anonymously report any breaches of our policies, safe working practises and legislation. All colleagues are informed of the hotline during induction.
Key Performance indicators
The business has set key performance indicators to measure its effectiveness in ensure that the risks of modern slavery are reduced as much as possible within the business and the supply chain.
- Employees trained on modern slavery during the year
- Agency staff worker recruitment interviews undertaken during this period
- Labour provider audits undertaken in the year
- Instances of suspected/proven modern slavery reported in the year
This statement is supported by the Board and has been approved and signed by the Chief Executive Officer. It will be reviewed annually each year.
Huw Thomas
CEO
