MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2018
LONG CLAWSON DAIRY LTD
- Company Statement
1.1 Long Clawson Dairy is committed to improving our practices to combat slavery and human trafficking. We believe that by driving up transparency, modern slavery will be tackled with greater urgency.
1.2 This annual report will set out Long Clawson Dairy’s due diligence processes, the effectiveness of measures taken to combat modern slavery and trafficking, auditing methods and communication to staff and suppliers. This report is endorsed and signed by the Managing Director and made accessible on the company’s website.
- Organisation Structure
2.1 Long Clawson Dairy is a farming co-operative, established in 1911. The head office is based in Long Clawson in Melton Mowbray, with a blended cheese operation site in Bottesford. The company reports a turnover of £56 million and employs 394 permanent employees.
- Our Business
3.1 Our business is organised into functions, Operations, Commercial, Financial and Technical. Each function is headed by an Executive Director, with Senior Managers and staff reporting into them.
3.2 Temporary labour is supplied by three GLA accredited and regularly audited Companies, Turner Stubbs, Ambitions and Barker Ross.
3.3 Milk suppliers are members of our co-operative board of farmers and work in conjunction with our Executive Director Team, led by the Managing Director. As a co-operative we ensure that when we achieve our KPI’s, our profits are shared with all employees through our Profit Related Bonus Scheme.
- Supply Chains and Auditing
4.1 Our supply chain includes sourcing ingredients, packaging and services from approved suppliers and contractors.
- Long Clawson’s policies on Slavery and Human Trafficking
5.1 We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery 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.
5.2 Our existing policies reflect this commitment.
5.2.1 The Ethical Policy shows clear commitment to ensuring that operations and supply chains are trafficking and slavery free.
5.2.2 The Grievance Policy Purpose & Scope states that it is designed to ensure that employees complaints or disputes are dealt with promptly and where necessary, formally. This procedure, though non-contractual, applies to all employees with the aim of ensuring consistent and fair treatment for all in the business.
5.2.3 Policy documents are made available to all staff in their induction booklets and are also available on the company’s shared drive and from the HR Department.
5.2.4 Working in partnership with Crimestoppers, The Integrity Line, is an additional resource in the unlikely event that staff need to pass on anonymous information about wrongdoing at work. The Integrity Line number is displayed on the Crimestoppers poster on Company Notice Boards.
- Long Clawson’s due diligence processes in relation to slavery and trafficking in its business and supply chain
As part of our initiative to identify and mitigate risk 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.
- Monitor potential risk areas in our supply chains and work towards improvement of potential risk.
- Protect whistle blowers, via our new policy on Whistleblowers, via Sedex, self-assessment checking suppliers and our Crimestoppers Integrity Line.
- Work in collaboration with our Customers and act on advice received from the Stronger Together multi-stakeholder initiative.
- Supplier Adherence to our Values.
7.1We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a dedicated compliance team, which consists of the HR Manager, the Technical Director and the Senior Buyer from the following departments:
- Audit and compliance.
- Human resources.
8.1 To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we communicate to our staff via internal communication. We also require our business partners to provide training to their staff and suppliers and providers.
- Our Effectiveness in combating Slavery and Human Trafficking
9.1 We submit to independent third parties, Supplier Ethical Data Exchange and the SEDEX members Ethical Trade Audit to conduct externally facilitated reviews to bring insights on ways to we can tackle slavery and human trafficking.
- Further Steps to prevent modern slavery in our business and supply chain
10.1 We recognise that modern slavery is a complex area and we will continue to improve our approach to mitigating risks in this area, by undertaking activities in 2018, such as;
- Ongoing due-diligence to new starters to the business, supplying them with a copy of the modern slavery policy in their induction booklets.
- Ongoing farmer engagement and awareness raising in the UK.
- Introducing new computer systems to create efficiencies for the ongoing robust checking for internal data in the UK (such as employee bank details and addresses) to identify any risk areas.
- Review of contractor information, including reviewing their commitment to removing risks of forced labour and ensuring sub-contracting does not take place without our consent.
- Ongoing supplier engagement and awareness raising in the UK, further embedding our purchasing policy and correct purchasing behaviour to increase the usage of our preferred suppliers.
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 2018.
Managing Director Dated
On Behalf of Long Clawson Dairy 1st April 2018