Modern Slavery Statement
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 was published on the 2nd January 2021 and relates to actions and activities during the year 1 January 2021 to 31 December 2021.
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 Dubai, USA, Norway, Denmark, Germany, France, Hungary, Poland, Spain and Russia.
- JDM Food Group Ltd imports raw materials and packaging globally and its supply chain extends from Europe, China, South Africa and India.
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 an A/B member of SEDEX and has undertaken a SMETA audit in November 2018, 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 two GLAA certified Labour Providers. 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 Providers are members of SEDEX, our providers are both certified by the GLAA and members of the ALP/GEC. Neither agency sub-contract work and all employees are dealt with directly. Both agencies are audited by JDM Food Group Ltd at a frequency of every six months by the Human Resources department and following GLAA Guidelines.
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; Human Resources Manager, Technical Director and the Operations Director.
- 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 (GLAA and ALP) and knowledge of the sector in which we operate.
- Investigations/due diligence:The Human Resources Manager, Operations Director, Technical Director and 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. Where there is evidence of this, then the appropriate authorities shall be notified immediately for advice and involvement moving forward.
- Training:Key staff have undertaken training related to the Ethical Trade Initiative and the Stronger Together campaign and various other customer codes of conduct. The plan moving forward is for further expanded training to be delivered to Managers and Supervisors. The Human Resources Manager, Technical Director and some managers 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 or the HR Department to discuss their concerns. JDM Food Group Ltd have placed a number of Whistle-blowing posters on notice boards in different languages appropriate to the staff on site and have their own Whistleblowing hotline. Furthermore, for reasons of confidentiality, we have placed posters inside the bathroom cubicles so staff can make a note of the numbers in the strictest of confidence and without fear of being seen.
- Employee code of conductJDM Food Group Ltd has an Employee Handbook which makes clear to employees the actions and behaviours 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.
- Employee Engagement JDM Food Group Ltd is re-defining the activities and membership of the current Management & Employee Health & Safety Team. This seeks to enhance the activities of the team by including staff from different disciplines within the business. The activities, outputs and requirements shall have the support of the Operations Director, Technical Director and Procurement Director. JDM operates a bi-monthly Employee Forum to engage with staff from all areas of the business to understand feedback from it’s employee community, actions are recorded, agreed and feedback on the outcome of this information to improve employee and worker communication and engagement.
- Supplier/Procurement code of conductJDM 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. All Procurement, Sales and Technical staff who have contact with suppliers, contractors and customers are aware of the company’s Anti-bribery policy and have been signed for by those members of staff.
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.
- Since 2019 JDM Food Group Ltd shall has created an annual risk profile for each of its suppliers.
- Participating in collaborative initiatives focused on human rights in general, 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.
Recruitment/Agency workers policy The organisation uses only specified, reputable and GLAA certified employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. These agencies must have a valid GLAA operating license, be members of SEDEX with a completed SAQ, hold full business insurance and documented policies for the recruitment of staff, induction, training, monitoring and supporting all staff supplied to JDM Food Group Ltd. One of the labour providers have an on-site office located next to the Human Resources office, with a member of staff co-ordinating all activities and working in hand with JDM Food Group Ltd staff.
The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation has carried out the following to date:
In 2018, JDM Food Group Ltd further improved its management of business ethics by way of recruiting a new Human Resources Manager along with three support staff. Together with the Technical Director, the team have improved the content and robustness of our ethical policies and procedures.
Requiring all suppliers to be aware of Modern-Day Slavery issues and implementing internal policies and controls by the end of 2020.
The organisation raised awareness of modern slavery issues by including a section related to business ethics, modern day slavery, whistleblowing lines within our first day inductions of new staff. Staff are issued with GLAA leaflets on induction and on an annual basis in own language and posters are placed on notice boards for all to read. The GLAA Video’s are played at all inductions to share the closeness of the issue of Modern Slavery and to highlight the importance of reporting any concerns to JDM Food Group Ltd.
The handouts, posters and booklets 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.
- what external help is available, for example through the Modern Slavery Helpline.
- whistle blower helplines.
- contact details for the GLAA.
- 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, contractors, and customers.
This statement was approved in 2021 by the organisation’s Managing Director who reviews and approves it annually.
JDM Food Group Ltd