Modern Slavery Policy
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Wealmoor Ltd during 2018/19 financial year, to prevent modern slavery and human trafficking in its business and supply chains.
Slavery, servitude, forced labour and human trafficking (Modern Slavery) has no place in our business, supply chain or on our planet.
Described by some as the single greatest human rights issue of our generation, modern slavery is a global problem on the rise that is transcending borders, economies and industries.
We believe in long term, ethical, collaborative, sustainable end to end responsible relationships with all of our growers, customers and colleagues. Our purpose at Wealmoor differentiates us from any other UK organisation in the fresh produce industry.
We take our duty to respect and promote human rights extremely seriously and have a zero tolerance approach to Modern Slavery of any kind within our operations or local and global supply value chains. We are committed to being a loved, trusted and respected family business by treating people fairly both in our business and local and global supply value chains.
This responsibility is that of our collective workforce; employees in our business and supply value chains are expected to report any concern, however small, and management are expected to promptly act on these.
Ultimately, we recognise that the abolition of Modern Slavery will require a collaborative effort between all parties involved and we aim to lead the way in respecting and promoting human rights and labour practices throughout our business and supply value chains.
This statement refers to the financial year ending 1st April 2019.
Our business and supply chains
Wealmoor is a family owned business, established over 45 years ago, with strong heritage for sustainably sourcing quality exotic fruits, speciality vegetables and other fresh ingredients.
We have built a reputation as an innovative world-class food business that produces, sources, markets and delivers fresh produce into the UK and international markets. Our heritage and values have endured and remain critical to maintaining strategic competitive advantage.
Wealmoor’s activities globally focus on ethical and sustainable farming practises that ensure quality produce that positively impacts the communities and environment surrounding its operations. Wealmoor carefully selects and aligns itself with growers and suppliers across five continents, who share the enduring values that Wealmoor still champions to this very day.
Wealmoor is one the UK’s leading fresh produce suppliers and has an annual turnover of £160 million. Wealmoor has 1,000 UK based employees across two sites (Greater London and Stratford upon Avon) and is top 2% employer in the UK.
We are hugely mindful about the impact we can and do have on the people impacted by our partnerships and work across our global supply chain. Especially as a worker for our grower or supplier partners tends to have multiple dependents, therefore, the beneficiaries of our business extend way beyond the immediate worker. We conservatively estimate that our business positively impacts the lives of over 300,000 people worldwide.
We choose like-minded suppliers who are conscious of the foot print they leave and the impact they have on our planet and societies. In 2018/19 financial year, we worked with 135 suppliers from 37 countries around the world.
Wealmoor is proud of its diverse supply base and we have established and built upon relationships with suppliers in North and South America, the Indian subcontinent, Africa, Asia, Europe and the UK.
Policies in relation to modern slavery
Wealmoor is fully engaged in supporting and upholding human rights and our internal policies, procedures and practices help us safeguard against Modern Slavery; forced labour and human trafficking of any kind in our business and operations.
All of our internal policies and procedures are available to all employees via our staff intranet, HR department and further communicated during formal induction and employee training.
Any agency provider that we use will be registered with the Gangmaster Licencing Authority (GLA). We will also carry out regular checks on employees employed through a GLA registered labour provider, using an agreed audit format. Any serious noncompliance will result in immediate termination of association and we will also report any such noncompliance to the GLA.
Recruitment and labour providers’ modern slavery policy is reviewed and discussed at audit to ensure fairness, all agency staff are inducted with our processes before starting work
Supervisors and staff responsible for recruitment are aware of the modern slavery policy and are aware of risk factors and have been trained to recognise these risk factors. Employees involved in recruitment are trained to be vigilant of large numbers of workers being introduced by individuals and to monitor that individuals are in control of their own bank accounts and identification when requested for checks.
All candidates at interview are made aware that there is no recruitment fee that is ever charged to the individual either directly or via an agency or another individual, also no deductions are made for any part of the recruitment process or for any PPE which is provided free of charge.
Recruitment and labour providers’ modern slavery policy is reviewed and discussed at audit to ensure fairness, all agency staff are inducted with our processes before starting work.
All staff will be trained at induction upon the outline requirements of the law and the Ethical Trading Initiative (ETI) code. Staff will be told the process to report any actual or perceived noncompliance including by anonymous means if preferred. Reports or concerns raised in good faith are encouraged by Wealmoor and no detrimental treatment will be tolerated.
A company handbook compiled by our own qualified staff and supported by legal expertise is available to all staff and details all of our policies including reporting and expected consequential actions.
Separate anti-bribery, complaints and grievance policies are published, updated and available to all employees. These policies can also be found in the employee handbook which is available on the staff intranet, on request from a member of HR and is displayed in communal areas. Employees are instructed at induction in to the content and scope of the policies; a copy of the handbook is given to employees at induction and a large print copy is available in communal areas for reference.
Customer compliance helpline numbers regarding staff, Health and Safety (H&S) and general issues are displayed on helpline posters displayed in communal areas.
HR compliance ensures that any shared bank accounts will be investigated to ensure this a proper and legitimate reason for them. The HR team will also consider the number of employees living at single address to make sure this is sustainable and not over crowded. Security is aware to monitor vehicles carrying a large number of employees to work. Supervisors and managers are aware of employee demeanour and condition.
Stronger Together literature including multi language leaflets, posters and helpline numbers are in communal areas, canteens and toilets to give help, guidance and information on modern slavery and exploitation and its many forms. Stronger Together literature with advice on renting houses and what is expected on legitimate landlords as well as advice on banking is available in communal areas.
Due diligence and audits of supply chain
The greatest risk of and exposure of Modern Slavery to Wealmoor lies in our global and complex supply chains where over 135 suppliers from 37 countries are involved. As the UK’s leading ethical fresh produce organisation Wealmoor upholds its duty to ensure that our business and our partners in our supply chain uphold ethical and sustainable sourcing practices. This responsibility means that we do everything we can to ensure all the people working in our supply chain are able to fully exercise their human rights.
To make this happen, we have purposefully undertaken significant activity in 2018/19 to minimise the risk of Modern Slavery amongst our suppliers (suppliers with whom we deal directly).
We realise that in order to tackle the issue of Modern Slavery we must take a collaborative approach. We are also fully aware of the limitations of our own expertise and where necessary or prudent we always employ the services of objective, independent experts.
We have identified through risk assessment the following essential controls for our suppliers to minimise the risk of Modern Slavery:
All new suppliers approved by our retail customers, factories and sites who want to work with Wealmoor are subject to comprehensive due diligence checks in the form of the Wealmoor Technical Supplier Approval Pack (WTSAP or the ‘Pack’).
The Pack covers a number of areas relating to human rights and ethical standards such as food safety and ethical compliance. All suppliers must be registered on the Supplier Ethical Data Exchange (SEDEX) database as “B” members. “B” indicates that they are purely a direct supplier to Wealmoor.
Wealmoor demands that all of its Tier 1 registered suppliers on the database show 100% completion of the Self-Assessment Questionnaire (SAQ) which provides a supplier risk-rating of either “low”, “medium” or “high”.
Wealmoor will regularly monitor the SEDEX supplier SAQ results to ensure low or medium risk status is maintained. Any supplier that shows a high risk rating will be supported to reduce their rating to an acceptable level. Any supplier that is unwilling or unable to work with us to reduce their risk rating will be warned and if necessary delisted.
However, due to our commitment to develop farming practices and empower local communities in developing countries, Wealmoor continues to help suppliers in under-privileged regions to lower their risk rating.
Suppliers must also formally commit to adhere and abide by the Ethical Trading Initiative (ETI) Base Code, which is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice.
Furthermore, Wealmoor works closely with our customers and uses various tools and methods to identify supplier that will require a SMETA. If a SMETA is required, then this will be communicated accordingly. The type of audit will be stated by Wealmoor and will follow either a 2nd or 3rdparty audit protocol, which will only ever be conducted by trained and certified auditors.
Impact and monitoring
Modern Slavery is largely a hidden tragedy; therefore, it’s extremely difficult to affirm the absolute success of Wealmoor’s risk mitigation and interventions, especially in its supply chain.
Like many organisations with ethical and sustainable genes, we are constantly looking for ways to improve the effectiveness of our actions and reviewing the most valuable means of reporting their success.
While publishing our Modern Slavery statement, Wealmoor is in the process of creating an internal committee which will meet with the purpose of upholding ethical standards within the business, its operations and supply chain. Furthermore, the committee will discuss the outcomes of ethical audits while monitoring and reviewing our effectiveness at mitigating modern slavery. The committee will contain some members of Wealmoor’s senior management team and will ensure the executive board of the organisation receives regular updates on key ethical issues, including Modern Slavery.
Wealmoor is committed to not only monitor Modern Slavery activity within its business, operation and supply chain but also to developing measures that can be reported clearly in the next Modern Slavery Statement.
Training and capacity building
Eradicating an issue as complex and challenging as Modern Slavery cannot rest on the shoulders of the few but must be the responsibility of the many. To this end, Wealmoor will be focussed on raising awareness of Modern Slavery across the business, its operations and supply chains.
All colleagues joining Wealmoor receive information on the expected code of conduct and ethical standards, which include information on ETI, Modern Slavery and who to contact in the event they suspect slavery or human trafficking. Some colleagues in Compliance and Risk, Technical and HR will receive further training which will include Stronger Together workshop sessions.
All members of the Wealmoor HR team that are involved in the recruitment process have undergone Stronger Together face-to-face training.
All line managers involved in the recruitment process will have to complete mandatory Stronger Together e-learning training and will have to attend internal Modern Slavery and Human Trafficking training session delivered by HR.
As we take the issue of Modern Slavery so seriously, Wealmoor will run a number of open training sessions which can be attended by all colleagues from across the business. The training sessions will cover all aspects of Modern Slavery and will provide colleagues with information on how to spot the signs and how to report any suspicious activity. These steps will build on the aforementioned activities discussed in Policies in relation to Modern Slavery section.
Modern Slavery contravenes Wealmoor’s values, beliefs and mission. While the above outlines how we intend to tackle the issue of Modern Slavery and human trafficking we realise there is always more that can be done.
In fact, we want to be a role model for other organisations in the way we face this unwanted criminal activity and we want to be known as an organisation that has truly positive impact on local communities and the environment whether in our business, operations or supply value chain.
Executive Chair, Wealmoor Ltd