Modern Slavery Statement
(Financial Year ending March 2024)
We are committed to providing a high standard of ethical conduct within our business. We take our responsibility under the Modern Slavery Act 2010 (“the Act”) very seriously. This statement outlines the steps we have taken and plan to take to ensure that slavery and human trafficking have no place within any part of our business or supply chain.
2. Organisation structure and supply chains
Organisation Structure
We are a family led, award winning business providing catering services to schools and industry. The company’s office and service outlets are in the UK. The company has an annual turnover in excess of the £36m threshold.
Supply Chains
We are committed to working with our suppliers to build greater transparency. We are committed to acting ethically and we expect the same from our suppliers. We have a dedicated Purchasing Manager who oversees all purchase relationships.
As a minimum we require our suppliers to commit to comply with all applicable laws and regulations and the Company’s policies, including as a minimum meeting the standards set out in our Purchasing Policy. Furthermore, suppliers are subject to our due diligence checks – further details are set out below. In addition to this, as supplier agreements come up for renewal, we shall review and if required, insert comprehensive anti-slavery clauses into our agreements.
3. Policies in relation to slavery and human trafficking
We remain committed to minimising the risk of modern slavery or human trafficking in our supply chain or any part of our business. During this year we have updated the Safer Recruitment Policy. All our policies are reviewed and updated as and when required.
4. Due diligence processes
Within our business
We have strict HR policies and standards to ensure compliance with legislation, including Right to Work, safeguarding awareness, equality, diversity and inclusion policy, enhanced DBS checks for those candidates working with children and vulnerable adults and reference checks for all employees.
During this period, we continued to build upon our compliance processes with our preferred agency worker suppliers. We will continue to review and repeat this process to maintain compliance.
As a result of an internal audit, we improved the Agency Workers Compliance Form and in February 2024 we then wrote to all our agency worker suppliers to request renewed confirmation that they comply with the Modern Slavery Act 2015.
Supply Chains
Should any existing suppliers fail to meet our standards as set out in the Act or our Purchasing Policy, and such a situation is not rectified within a reasonable timeframe, this may result in terminating the relationship with the supplier.
If a potential new supplier does not meet the standards as set out in our Purchasing Policy, they shall not become a supplier until we receive confirmation that this is rectified.
In November 2023, we wrote to our significant suppliers to request confirmation that the suppliers comply with the Modern Slavery Act 2015.
5. Risk Assessment and Management
5. Risk Assessment and Management
Our risk assessment concluded that the main areas of risk of Modern Slavery could be in our supply chain and potentially with certain members of staff. Training takes place via our Harrison Learning Hub to ensure that relevant members of staff are aware of Modern Slavery, how to identify it and what to do if they suspect modern slavery.
6. Training on modern slavery and trafficking
Our bespoke Harrison Learning Hub has a modern slavery and trafficking resource which is mandatory for both new and current relevant members of staff. There is a requirement for all Site Managers and those involved in our purchasing processes to complete a Modern Slavery module on the Harrison Learning Hub.
We have updated the Recruitment and Selection workshop for the site managers to include training on helping identify key issues regarding modern slavery. This workshop runs as and when required throughout the year.
Further to our internal Modern Slavery audit, our Legal Counsel completed an external “Modern slavery in Business” refresher training course. In November 2023, we underwent a Modern Slavery Risk Assessment and carried out a spot check review of our Anti-Slavery and Human Trafficking clauses in our commercial contracts.
7. Next Steps
We shall continue to review, audit and develop our supply chain due diligence and risk assessment to ensure a robust approach to supply chain risks. We will continue to make efforts to identify any significant risks in our business and supply chain and implement any actions appropriate or necessary directly with suppliers.
8. Approval by the Board
This statement is made pursuant to section 54(1) of the Act and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2024. This statement was unanimously approved by our Board of Directors on 31st July 2024.
9. Review
This statement shall be reviewed by our Board of Directors on a regular basis (at least annually) and may be amended from time to time.
| Claire Aylward Joint Managing Director 31 July 2024 |
Gareth Harrison Joint Managing Director 31 July 2024 |
