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 relates to actions and activities during the financial year 1 April 2017 to 31 March 2018.
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, 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 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 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 Providers are members of SEDEX, certified by the GLA, members of the ALP. Neither agency sub-contract work and all employees are dealt with directly. both agency have been audited by JDM Food Group Ltd in 2018 by the Human Resources Manager.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, Training Co-ordinator, 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 (GLA and ALP) and knowledge of the sector in which we operate.
- Investigations/due diligence: The Human Resources Manager, 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. 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 for 2018 and 2019 moving forward is for further expanded training to be delivered to Managers and Supervisors. The Human Resources Manager, 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. JDM Food Group Ltd has placed a number of whistle blowing posters on noticeboards in different languages appropriate to teh staff on site. Furthermore, for reasons of confidentiality, we have placed these same posters inside the bathroom cubicle so staff can make a note of the numbers in the strictest of confidence and without fear of being seen.
- 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.
- Employee Engagement JDM Food Group Ltd is re-defining the activitiees 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.
- 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. All Procurement, Sales and Technical staff who have contact with suppliers, contractors and customer 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;
- As of 2019 JDM Food Group Ltd shall be creating an annual risk profile for each supplier;
- Participating in collaborative initiatives focused on human rights in generate, and slavery and human trafficking in particular “Strong 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 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. These agencies must have a valid GLA operating license, be members of the Association of Labour Providers (ALP), be members of SEDEX with a completed SAQ, hold full business insurance and documentated policies for 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 within the Human Resources offices, with two members of staff co-ordinating all activities and working in hand with JDM Food Group Ltd staff. The second labour privider have on-site co-ordinators in place as a point of references for staff and JDM Food Group Ltd.
The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation has:
In 2018, JDM Food Group Ltd further improved its management of business ethics by way of recruiting a new Human Resources Manager along with two support staff. Together with the Technical Director, the team has 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 2019.
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.
In 2018, JDM Food Group Ltd up-graded its SEDEX membership from a B to an A/B membership giving the business improved visibility of its supply chain.
During 2018, the organisation has 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 GLA leaflets on induction in own language and posters placed on noticeboards for all to read.
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.
- what external help is available, for example through the Modern Slavery Helpline.
- whistle blower helpines.
- 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 17th December by the organisation’s Managing Director who reviews and approves it annually.
JDM Food Group Ltd