PREVENTING HIDDEN LABOUR EXPLOITATION
At Burts Snacks Limited, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. Burts Snacks Limited commits to developing and adopting a proactive approach to tackling hidden labour exploitation.
Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.
Hidden labour exploitation is exploitation of job applicants and workers by third party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as forced use of accommodation. It is understood that it is often well hidden by the perpetrators with victims, if they perceive of themselves as such, reluctant to come forward.
We have taken concrete steps to tackle modern slavery and this statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2020/21.
Burts Snacks Limited:
- Designates appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.
- Accepts that job finding fees are a business cost, and will not allow these to be paid by job applicants. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
- Ensures that all staff responsible for directly recruiting workers are trained to be aware of issues around third party labour exploitation and signs to look for
- Ensures that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
- Adopts a proactive approach to reporting suspicions of hidden worker exploitation to the Gang-masters Licensing Authority and police.
- Provides information on tackling “Hidden Labour Exploitation” to our workforce at induction, workforce training and post information and worker leaflets on the noticeboards.
- Encourages workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
- Positively encourages and supports employees and agency workers to report such exploitation which may be occurring within their communities
- Requires labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with the above.
Our Business and Supply Chains
Burts Snacks Limited is an award-winning premium snack manufacturer, mainly based in the South West of the UK. We produce a growing range of brand, licensed and private label snacks, driven by our ambition to deliver premium quality snacks with exceptional taste and flavour.
Our thick-cut British potato chips are hand-cooked in Devon, using locally sourced Red Tractor Assured potatoes. We use the best quality ingredients, sourced locally, to reduce our impact on the environment.
We’re keen for Burts Crisps to be a key part of our local communities, and support a variety of local and community based activities, as well as supporting several national charities and working with/supporting local suppliers.
Increasing our international footprint is important to us. So we’re continuing to focus on the export market and Burts Snacks now sold in over 22 countries around the world.
We have two separate manufacturing facilities, located in Plymouth and Leicester, where we can provide state-of-the-art manufacturing of your premium brand and private label snacks.
We carefully evaluate suppliers and their ethical credentials and have established a relationship of trust and integrity with all our suppliers located globally, which is built upon mutually beneficial factors.
We have over 60 direct suppliers of raw materials and packaging. Most of our suppliers are based in the UK however we also work with suppliers based in the EU, USA and other parts of the world such as Turkey and Malaysia.
Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.
We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.
In the past year, we have risk assessed our supply chain by taking into account:
- The risk profile of individual countries based on the Global Slavery Index
- The business services rendered by the suppliers
- The presence of vulnerable demographic groups
- A news analysis and the insights of labour and human rights groups
These assessments determine our response and the risk controls that we implement.
Burts Snacks Limited is also, with the help of partners who are specialists in this field looking for ways to further enhance, manage and identify risks within our supply chain.
Supplier due diligence
Burts Snacks Limited conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:
- Assessing risks in the provision of particular services
- Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
- Requiring improvements to substandard employment practices
- Sanctioning suppliers that fail to improve their performance in line with our requirements
We require all suppliers to attest that:
- They don’t use any form of forced, compulsory or slave labour
- Their employees work voluntarily and are entitled to leave work
- They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
- They don’t require employees to post a deposit/bond and don’t withhold their salaries for any reasons
- They don’t require employees to surrender their passports or work permits as a condition of employment
Burts Snacks operates the following policies for identifying and preventing slavery and human trafficking in our operations:
- Whistleblowing Policy – we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers.
- Code of Conduct – our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
- Purchasing Code – we have updated our Purchasing Code and supplier contracts to make explicit reference to slavery and human trafficking.
Burts Snacks Limited has raised awareness of modern slavery issues by sharing information with members of staff, informing them of the Company’s commitment to fighting modern slavery, the red flags for potential cases of slavery or human trafficking and how employees should report suspicions of modern slavery.
In addition to the awareness programme, Burts Snacks Limited has rolled out a fresh elearning course to all employees and supplier contacts, which covers:
- Various forms of modern slavery in which people can be held and exploited
- The size of the problem and the risk to our organisation
- How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
- How employees should respond if they suspect slavery or human trafficking
- How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation
- What external help is available for the victims of slavery?
- What terms and guidance should be provided to suppliers in relation to slavery policies and controls
- What steps this business will take if a supplier fails to implement anti-slavery policies or controls
- An attestation from employees that they will abide by Burts Snacks Limited’s antislavery policy
Measuring how we’re performing
Burts Snacks Limited has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:
- How many employees have completed mandatory training?
- How many suppliers have filled out our ethics questionnaire?
- How many suppliers have rolled out an awareness and training programme that is equivalent to ours?
- How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues?
This statement covers 1 January 2020 to 31 December 2020 and has the support of the Board of Burts Snacks Limited.
Appendix 1 – Modern Slavery Policy
- POLICY STATEMENT SLAVERY AND HUMAN TRAFFICKING
- Burts Snacks Limited has committed to doing everything within its power to stopslavery and human trafficking in our business and in our supply chains.
- Burts Snacks Limited has always striven to operate with the highest standards of ethics and responsibility and our approach to stopping modern slavery reflects that. This policy applies to all persons working on our behalf in any capacity.
- Burts Snacks Limited is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
- COMPLIANCE WITH THE POLICY
- You must ensure that you read, understand and comply with this policy.
- The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
- You must notify your manager as soon as possible if you suspect that a breach of this policy has or will occur.
- You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
- If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or Human Resources.
- For the avoidance of doubt no fee or cost for recruitment will be charged to workers, directly or indirectly, in whole or in part.
- We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
- COMMUNICATION AND AWARENESS OF THIS POLICY
- Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the training process for all individuals who work for us, and regular training will be provided as necessary.
- Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
- BREACHES OF THIS POLICY
- Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
- We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Appendix 2 – Guidance for Line Managers and Businesses on Preventing Modern Slavery
Recorded cases of human trafficking and forced labour by hidden exploiters and criminal gangs are on the increase in the UK. We call this modern slavery and there are now modern slavery laws in the UK.
It is hard to detect and your business may be at risk. Protect your business by following some straightforward checks:
- Ensure your workers didn’t have to pay to get work
- Workers may have been forced to pay to secure a job at your site. This is against the law.
- Agency and job finding fees are a business cost, and shouldn’t be inflicted onto workers.
- Ensure workers are not abused and are treated well
- Keep a close eye on behaviour – ensure workers are free from intimidation from supervisors, other workers or suspicious individuals who may deliver and take them home.
- Ask workers how they are being treated.
- Make sure the wages you pay go to the workers
- Avoid cash in hand and cheque arrangements.
- Ask your agency why, if they won’t pay into bank accounts.
- Be aware that workers may be forced into debt and have bank accounts controlled by exploiters.
- Ask some of the workers whether they know of this happening on your site.
- Ask if the workers are free to leave of their own free will
- Is there any penalty for leaving?
- Have they had passports/ID taken away from them?
- Ask about their accommodation and travel
- Is it safe and clean?
- Are they threatened with immediate eviction or for unpaid rent?
- Are they free to travel to work by their own means?
- Workers should have accommodation and rental agreements that meet legal standards.
- They should be free to travel and eat how they wish.
- If you are in food or agriculture, ensure that anyone supplying you with permanent or temporary labour even if just for a day is licensed by the Gang masters Licensing Authority Check their licence by calling the GLA on 0345 602 5020 or at Gang masters Licensing Authority website
For access to a range of free guidance including toolkits, a video for workers on avoiding forced labour, workplace posters, induction materials and details of workshops visit Stronger2gether.
If you have any suspicions about potential human trafficking, forced labour or any other hidden labour exploitation please notify the Gangmasters Licensing Authority on 0800 432 0804.