This statement sets out JDM Food Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. JDM Food Group Ltd complies with the provisions of the UK’s Modern Slavery Act 2015 and the duty it places on businesses to disclose publicly the steps they are taking to tackle forced labour and human trafficking. This statement relates to actions and activities during the financial year 1 April 2016 to 31 March 2017.
As part of a global food supply chain, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
• JDM Food Group Ltd operates in some of the largest food markets around the world and works with a diverse global supply chain. JDM Food Group Ltd is a key provider of a vast range of prepared foods from its single site in Lincolnshire.
• JDM Food Group Ltd operates from within the UK. It supplies retail and manufacturing customers here in the UK and abroad. Export countries extend from Europe, Australia, Israel, Dubai and USA.
• JDM Food Group Ltd imports raw materials and packaging globally and its supply chain extends from Europe, USA, Brazil, China, South Africa, Argentina, India and Israel.
The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
• JDM Food Group Ltd is a member of SEDEX and has undertaken a Smeta audit, the results of which are within our SEDEX site. We have an Ethical Policy based upon the Ethical Trade Initiative key principles and is applied to all our activities. We are members of Stronger Together.
The following activities are considered to be at high risk of slavery or human trafficking:
• Our UK operation is considered high risk. Our risk assessment concluded that the site is high risk due to the presence of non-UK European workers and the use of a GLA certified Labour Provider. We ensure that we apply all appropriate controls when recruiting staff and ensure that their welfare is of paramount importance. Our Smeta audit is undertaken in order to provide a third party assessment of our organisation. Our Labour Provider is a member of SEDEX, certified by the GLA, member of the ALP, does not sub-contract work and is audited by JDM Food Group Ltd.
Responsibility for the organisation’s anti-slavery initiatives is as follows:
• Policies: these are researched, internalised, documented, trained and monitored by a number of persons on site, Technical Director, Operations Director and Training Co-ordinator.
• Risk assessments: Risk assessments are conducted using the tools from within the Stronger Together site. The risks are taken into account from historical knowledge, partnership working groups (GLA and ALP) and knowledge of the sector in which we operate
• Investigations/due diligence: Operations Director, Technical Director, Senior Managers as necessary would be involved in the investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
• Training: Key staff have undertaken training related to the Ethical Trade Initiative, ALP, Stronger Together and various other customer codes of conduct. The plan for 2018 moving forward is for further expanded training to be delivered to Managers and Supervisors. The Technical Director and training Co-ordinator have attended external workshops on Modern Day Slavery.
• Whistleblowing policy JDM Food Group Ltd encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use various confidential helplines to report such instances. All members of staff have the right to a confidential face to face meeting with a Manager to discuss their concerns.
• Employee code of conduct JDM Food Group Ltd has an Employee Booklet which makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier/Procurement code of conduct JDM Food Group Ltd is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. JDM Food Group Ltd works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship. We ensure that suppliers are active members of SEDEX and where appropriate (China and South Africa) have undertaken a third party ethical audits in the form of Smeta or Siza. During routine audits by JDM Food Group Ltd staff, the arena of staff welfare and health and safety is checked.
• Recruitment/Agency workers policy The organisation uses only specified, reputable and GLA certified employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:
• Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• Evaluating the modern slavery and human trafficking risks of each new supplier via SEDEX or our own Ethical Trade Questionnaire.
• In future JDM Food Group Ltd shall be creating an annual risk profile for each supplier;
• Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular “Stronger together” or “Ethical trading” initiatives.
• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship
The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is:
Requiring all suppliers to be aware of Modern Day Slavery issues and implementing internal policies and controls by the end of 2018.
• Developing a system for supply chain verification expected to be in place by the end of 2018 whereby the organisation evaluates potential suppliers before they enter the supply chain.
• Reviewing its existing supply chains expected to be completed by the end of 2018 whereby the organisation evaluates all existing suppliers.
As well as training staff, the organisation has raised awareness of modern slavery issues by distributing flyers to staff, putting up posters across our facility, issuing staff with GLA leaflets on induction.
The handouts, posters all explain to staff the basic principles of the Modern Slavery Act 2015;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• what external help is available, for example through the Modern Slavery Helpline.
• Whistle blower helplines.
• Contact details for the GLA.
• Contact details for key retailers.
This is an issue which shall receive the attention and support of all staff at JDM Food Group Ltd, and we continue to remain steadfast in ensuring that we remain a fair and rewarding place to work for all our staff, suppliers and customers.
This statement was approved on 20th February 2018 by the organisation’s Managing Director who review and update it annually.
JDM Food Group Ltd