For the Financial Year Ending March 2024

Bennett Opie Ltd is a food manufacturer and importer that has been trading for over 140 years. We are extremely proud to have remained an independent 5th generation family business that clearly recognises the value of ethical and fair trading. Our Board of Directors are fully supportive in the aims of the Modern Slavery Act 2015, and in line with our internal Ethical Trading and Ethical Policy (POL38), we are committed to combatting the risk of human trafficking and slavery within our business and also in any association to our organisation.

Bennett Opie is fully committed to ethical working practices and deem any inhumane conditions unacceptable, this includes both within our organisation and through our supply chains. As we have a zero tolerance for inhumane conditions, we approach tackling any such conditions throughout our supply chains by ensuring we demonstrate due diligence by requesting Supplier Approval

Questionnaires are completed namely; Supplier Approval Questionnaire, Primary Supplier Approval Questionnaire, Supplier Ethical Questionnaire are completed to ensure as a business, we are promoting and ensuring ethical trading.

Here at Bennett Opie, we have a zero tolerance approach to modern slavery and we recognise that this may be demonstrated in multiple ways, for example; slavery, worker exploitation, human trafficking and financial exploitation in both adults and children, and we believe in the freedom of choice without any form of exploitation.

As part of Bennett Opie's commitment to helping increase awareness of the issues directly and indirectly associated with Modern Slavery, we are a member of SEDEX (not for profit organisation) dedicated to improving ethical business practices throughout organisations and their supply chains. We encourage our suppliers to become members of SEDEX and where less frequent business transactions take place with our suppliers, we encourage them to also join SEDEX as members, and where this is not the case, we seek confirmation of their commitment to the Modern Slavery Act 2015 by means of their own Modern Slavery Statement.

We at Bennett Opie Ltd strive to support the eradication of human trafficking and slavery and aim to work towards any means within our control to do so.

 

Risk Assessment

For all our core raw materials, ingredients and packaging used in the production of our products within our Sittingbourne factory these suppliers are approved based on SEDEX registration or Ethical questionnaire which includes the ETI base code.

The Global Slavery Index 2018, identifies several of our main Countries of sourcing as medium risk (India Vietnam) and high risk (China). The report identifies agriculture in these Countries as being of particular risk as by its nature it is very labour intensive and not well regulated so the risk for forced labour is high, this will initially concentrate our resources with regards to direct supplier visits.

Among other services supplied to us within the U.K include but are not limited; laundry, machinery maintenance, cleaning contracts, freight, couriers, telecoms, PPE and whilst some of these offer their own statements on MSA not all are transparent. All our subject to U.K labour law- which though not a guarantee of compliance does suggest a lower risk.

 

Actions to Reduce Risk

Buyers play a key role in encouraging ethical practices in supply chains. Trading fairly has and continues to be core to our business and values with so much of our existing procedures and ethos already helping to mitigate the risk of slavery within our supply chains.

It is our intention with the services identified as at higher risk for Modern Slavery (Cleaning contractors and laundry been the most obvious) to further audit these suppliers.

We have applied to become a Business Partner member of the Stronger2gether organisation allowing us to work in partnership having completed their training and to enhance further training and understanding as an organisation allowing us to work in conjunction with our customers and suppliers to promote the reduction /abolishment of Modern Slavery as the primary aim. This partnership programme includes a monitoring system that will measure the effectiveness of our actions and progress over time of key goals and KPl's.

Now that the Covid restrictions on travel have been lifted we will reinstate the process of planning to visit to our main overseas raw material suppliers from countries considered areas of medium to high risk on a minimum of a Tri Annual basis to further understand, see first-hand how their businesses work and to discuss in person issues arising from the possibility of modern slavery not only in their physical business but also within their supply chain to help to promote an open and ethical trading relationship.(We started this process in January 2023 with a visit to our Indian suppliers where the topic was discussed in all the meetings that we held.)

Detailed supplier visits and ethical questionnaires managed by our Procurement and Technical teams

Working where possible with third -party accredited ethical schemes that comply with the ETI base code.

Avoid trading with high risk areas of the world.

 

Targets

To complete a full supplier base risk assessment and engage with those identified as high risk to understand and agree ways to reduce that risk via audit, targeted questionnaires and external resources such as SEDEX at least every 3 years or if the risk changes.

Continue to build awareness of Modern Slavery through targeted staff training those individuals that have direct interaction with our supply chain

For our application as a Stronger2gether partner to be completed and be fully in place by the 31st May 2024

The higher awareness and access to training that this partnership will give us will enable the business to give the identified key staff sufficient knowledge to enable us in all direct meetings with those businesses that pose a possible high risk within our supply chain, to highlight the topic and issues surrounding and directly linked to Modern Slavery firmly into the mainstream of any discussion, interactions and/or negotiations.

Continuing to encourage any colleagues or anyone within our supply chain to take the appropriate action by contacting the Modern Slavery UK Helpline, to raise any concerns either direct or indirect to Modern Slavery.

Continuing to highlight and make aware to all employees of the business the signs of Modern Slavery across staff notice boards using the U.K Governments published promotional information.

Continuing to reduce any requirements to utilise the work force requirements via agency partnering, whilst also ensuring that any requirements to do so, are done so by following our due diligence in ensuring safer recruitment.

If we find incidences of slavery in our supply chains, our priority remains to cause no further harm to the victim(s). We would ideally want to help resolve the underlying causes of the problem by liaising closely with the supplier, though if no solution is possible we would cease our trading relationship with the supplier over an agreed timescale.

To set further compliance targets to reduce the risk and enable us to measure our progress.

In doing this work we recognise that we may not be in control of the organisations we partner with,we are however, committed to continuing to find meaningful ways to improve ways in which we can support the reduction and tackle Modern Slavery and welcome feedback to do so