Modern Slavery Act 2015
Prinova Europe Limited
Slavery and human trafficking statement 2018/2019

Introduction

This statement sets out Prinova Europe Limited’s (“Prinova Europe”) 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. This statement relates to actions and activities during the financial year 1 April 2018 to 31 March 2019.

As part of the global distribution industry in relation to food ingredients, 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 Chain

This statement covers the activities of Prinova Europe:

A distributor of food ingredients globally, Prinova Europe provides ingredients and flavour solutions to the global food, feed and wellness industries

Countries of Operation and Supply

The organisation currently operates in the following countries:

  • Europe– We operate in numerous countries in Europe including UK / Ireland / France / Germany / Spain / Italy / Belgium / Holland / Poland / Portugal – Europe is where most of our Employees are based and where most of our customers are located. UK has the highest number of employees at the European headquarters in London (70% of overall employee number). We import our commodities mainly from Asia (China / Indonesia / India) and distribute to customers in the European region
  • Turkey– We have an office in Istanbul and numerous customers in this region. We import our commodities mainly from Asia (China / Indonesia / India) and distribute to customers in this region.
  • China– We have numerous producers of our commodities in this region that we work with. These commodities and transported to Europe for distribution to our customers.
  • India– We have numerous producers of our commodities in this region that we work with. These commodities and transported to Europe for distribution to our customers.
  • Indonesia– We have numerous producers of our commodities in this region that we work with. These commodities and transported to Europe for distribution to our customers.

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:

High-Risk Activities

The following activities are considered to be at high risk of slavery or human trafficking:

  • Supply of commodities by producers within the region of Asia

In relation to forced labour, the prevalence of this is highest in Asia and the Pacific, where four out of every 1,000 people were victims, followed by Europe and Central Asia (3.6 per 1,000), Africa (2.8 per 1,000), the Arab States (2.2 per 1,000) and the Americas (1.3 per 1,000) (source – International Labour Organisation ‘ILO’ – Global estimates of Modern Slavery: Forced labour and Forced Marriage – Geneva, September 2017)

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows

Policies:

  • Executive Management Team

On an annual basis, the Executive Management Team (EMT) reviews the Modern slavery and human trafficking statement contents and agrees a plan of action to ensure it is updated and implemented to ensure that a robust risk management process is in place to remove the risk of the prevalence of slavery within the business supply chain

  • Human Resources

On an annual basis, the Human Resources Department drafts the Modern slavery and human trafficking statement following updates from the EMT and other relevant departments within the organisation and ensures that the statement is published within 6 months of the previous financial year on the company website if possible or if not at least have it available to respond to any requests for the statement within 30 days of request date.

  • Quality

On an annual basis, the Quality Department reviews the Modern slavery and human trafficking statement following updates from the other relevant departments within the organisation and ensures that the statement is accurate based on the actions of the Quality Department in relation to supplier audits that take place for new suppliers or on an adhoc basis when audits are required at relevant suppliers.

In addition to the Statement, Prinova Europe intends to;

  • Ensure that it has an Ethical / Human Rights policy defining the ethical principles the company will up hold with regard to its own workers and workers in its supply chain.
  • It has a recruitment policy that sets out the requirement to be aware of modern slavery in recruiting staff, and that the company will not employ slaves.
  • It has a Supplier Code of Conduct which sets out Slavery and Labour standards to be upheld by direct suppliers and in the supply chain.
  • In all the above, focus on a proportional and targeted response to slavery risks that can be incorporated within an organisational approach to other issues such as Labour Standards, Right to work, Immigration etc.

Risk Assessments:

When considering risk assessment actions we consider the following;

  • Size & location of risk
  • The probability of the risk occurring, and the impact if it does
  • Leverage to influence the supply chain
  • Opportunities to improve
  • Analysis of where the greatest likelihood of slavery is within the company’s operations, and within its supply chain, including sub-contractors
  • Maintenance of an ethical risk log that is regularly reviewed
  • Organisation participates in a supply chain mapping process

Investigations / Due Diligence:

Individuals / departments responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking

  • Management – COO

To ensure that any known or suspected instances of slavery and human trafficking are dealt with quickly and effectively and that all relevant stakeholders are made aware of the matter in question

  • Quality Department – European Quality Manager

To work with any auditors on the ground or local authorities to conduct an efficient and robust investigation and collate all relevant data on the matter in question

  • Human Resources – Human Resources Director – EMEA & APAC

To ensure compliance with all policies in relation to this and any external advice is sort as required to ensure any suspected instance of slavery or human trafficking is dealt with appropriately

Training:

The Quality and Human Resources Departments are ultimately responsible for putting together training plans to ensure that all relevant employees / or external contacts such as suppliers or customers to ensure that they better understand and respond to the identified slavery and human trafficking risks

Relevant Policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations

Whistleblowing policy

The organisation 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 complete our confidential disclosure form.

Employee code of conduct

The organisation’s code 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

The organisation 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. The organisation 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.

Recruitment policy

The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due Diligence

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;
  • Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • Conducting supplier audits or assessments through[the organisation’s own staff/third party auditor as applicable, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through third party auditors and requiring them to implement action plans;
  • Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular such as “Stronger together” / “Ethical trading” initiatives;
  • Using details of ethical supplier database, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular;

and

  • 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.

Performance Indicators

The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is:

  • Requiring all staff/staff working within the supply chain process of our business to have completed training on modern slavery within 12 months on the issuing of this statement;
  • Developing a system for supply chain verification expected to be in place within 12 months of the issuing of this statement, whereby the organisation evaluates potential suppliers before they enter the supply chain; and

Training

  • The organisation requires all staff working within the supply chain process of our business / HR professionals within the organisation to complete training on modern slavery as a module within the organisation’s wider human rights/ethics/ethical trade training programme.
  • The organisation requires all staff working within the supply chain process of our business / HR professionals to sign up to one of a number of training sessions that are being run in the next 12 months in relation the organisation’s human rights/ethics/ethical trade training programme.

The organisation’s modern slavery training covers;

  • Our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
  • How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • How to identify the signs of slavery and human trafficking;
  • What initial steps should be taken if slavery or human trafficking is suspected;
  • How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;
  • What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies;

and

  • What steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Awareness-Raising Programme

As well as training staff, the organisation is planning to raise awareness of modern slavery issues by circulating a series of emails to staff on this topic.

The emails explain to staff:

  • The basic principles of the Modern Slavery Act 2015;
  • How employers can identify and prevent slavery and human trafficking;
  • 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.

Director Approval

This statement was approved on 8th August 2019 by the organisation’s Directors, who review and update it annually.