Modern Slavery and Human Trafficking Statement

Update January 2024

INTRODUCTION 

We continue to be proud of the steps we have taken to combat slavery and human trafficking and we are committed to continuously reviewing and improving our practices and policies to combat slavery and human trafficking. 

ORGANISATION’S STRUCTURE 

We are a manufacturer of sweet biscuit products in the food sector. Our ultimate parent company is Amber REI Holdings Limited. We have 631 employees and operate in the United Kingdom. Our business is based in Uttoxeter, Staffordshire. 

OUR SUPPLY CHAINS 

Elkes Biscuits sources ingredients from around the world, including Honduras, Columbia, Costa Rica, Brazil, Papua New Guinea, Malaysia, Solomon Islands, Ireland, UK, Europe, China, Guadeloupe, Dubai, Madagascar, South Korea, Cameroon, Gabon, Sao Tome, Ghana, Nigeria, Thailand and Vietnam. 

RESPONSIBILITY FOR ANTI-SLAVOURY INITIATIVES 

The relevant leaders of the HR, Technical, Procurement and Operations functions are responsible for the implementation, development and on-going maintenance of the policy within their respective business units whilst also working together to ensure there is a coordinated approach to tackling this issue. 

HUMAN TRAFFICKING 

We remain committed to minimising the risk of modern slavery or human trafficking in our supply chains or in any part of our business. Our Responsible Recruitment Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. 

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING 

We have in place systems to: 

  • Identify and assess potential risk areas in our supply chains; 
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains; 
  • Protect whistle blowers 
  • Ensure our colleagues and managers are all aware of the threat of modern slavery and human trafficking within our recruitment processes 

SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS 

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values and ethics, we have in place a supply chain compliance programme. This consists of ensuring our suppliers are registered with SEDEX and are connected Elkes Biscuits. 

TRAINING & COMMUNICATION 

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our HR and Procurement teams. 

All managers and existing personnel have visibility of Modern Day Slavery issues using materials supplied by Stronger Together. All new personnel are also briefed during induction and posters and other materials are displayed across the business. 

The flyers/posters/videos/training explain: 

  • the basic principles of the Modern Slavery Act 2015; 
  • how employers can identify and prevent slavery and human trafficking. 
  • what employees can do to flag up 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. 

RISK ASSESSMENT AND DUE DILIGENCE 

Elkes Biscuits is an AB member of SEDEX (Supplier Ethical Data Exchange) a not for profit membership organisation dedicated to driving improvements in responsible and ethical business practices in global supply chains. 

Three forms of formal risk assessment are used by the business on operations and supply chains: 

  • SEDEX ethical risk assessments of every site; 
  • SEDEX ethical risk assessment of every supplier, which is currently still being rolled out across the supply base; 

The main source of risk internally is identified as temporary agency labour supply. This risk has been mitigated by bringing a Recruitment Officer into the business with the aim of ultimately removing our use of agency labour. 

External labour providers have been identified as areas of higher risk and we look to mitigate these risks by: 

  • Recruiting directly where possible; 
  • Undertaking structured induction and training processes; 
  • Undertaking questionnaires / interviews with agency personnel; 
  • Carrying out tender process for the selection of external recruitment agencies; 
  • Carrying out a robust level of audit and approval of all external agencies which includes:
    • Agency labour provider audits; 
    • Agency accommodation audits, if an agency were to provide accommodation. 
  • Ensuring that Service Level Agreements are in place with all external agencies. 
  • Watching and checking vehicles dropping off workers and checking car parks for minibuses 

We attend events where there is an opportunity to discuss the risks of Modern Slavery with our peers, the GLAA, Non-Governmental Organisations (‘NGOs’) and other relevant stakeholders. This helps to expand our knowledge and highlight countries, product types or services that may be considered to have a higher risk of Modern Slavery. The knowledge and experience that we have obtained will help us identify the risks and issues, assess the level of importance and develop appropriate remedies. We will continue to collaborate and improve our understanding as time goes on. 

FURTHER STEPS 

We will continue in 2024 to build on the progress we have made. A new internal / BPO meeting programme is being established to broaden the scope of those that are involved. 

We will continue to improve communication on this topic with our supply chain and welcome opportunities to collaborate to identify risks or solve problems that we cannot tackle alone. We will face common issues and by working together, not only with suppliers but also with other UK companies, we will be far more effective in meeting our common goal of eradicating Modern Slavery. 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2023. 

Kevin Hand 
Title General Manager, Elkes Biscuits Ltd