Modern Slavery Statement
1 - Introduction
2 - Valeo Confectionery Mission Statement
3 - Organisation's Structure
4 - Our Policy Chains
5 - Our policies on slavery and human trafficking
6 - Due diligence processes for slavery and human trafficking
7 - Key Performance Indicators
8 - Training
9 - Finding Help
10 - Publication
11 - Conclusion
Valeo Confectionery Limited is opposed to modern slavery at any level and recognises the responsibility that we share with our suppliers to tackle hidden labour exploitation.
We are committed to understanding modern slavery and human trafficking risks and ensuring that such activities are not taking place in our supply chain or any part of our business. We have a zero-tolerance approach to modern slavery and have taken steps to ensure a high degree of ethics is incorporated into our commercial dealings including all business relationships and supply chains. As a result, we expect and maintain the highest standards from our entire staff, contractors, suppliers and anyone with whom we do business.
One of the key principles of our company ethics is to treat everyone fairly, with dignity and respect. We are committed to continuous improvement in our practices to combat slavery and human trafficking.
This statement is made pursuant to Modern Slavery Act 2015 by Valeo Confectionery Limited (“Valeo Confectionery” “we” “our” “us”). It outlines the measures Valeo Confectionery has taken to access and reduce the risk of slavery and human trafficking occurring in our business or supply chains in the financial year 1st April 2020 to 31st March 2021. It also outlines our commitments to continue to reduce risk in the Valeo Confectionery financial year commencing 1st April 2021.
2 Valeo Confectionery Mission Statement
Valeo Confectionery is committed to continuously improving its practices to identify and eliminate any slavery and human trafficking in its business and supply chains whilst always acting ethically and with integrity in all its business relationships.
Each of Valeo Confectionery’ departments adopt this mission statement when dealing with its suppliers in addition to the following departmental commitments:
To support the company’s Modern Slavery Statement and the eradication of modern slavery and human trafficking within its supply chains and ensuring that our employees, future employees and agency workers are treated fairly with dignity and respect.
Procurement & Operations
To support delivery of the company objectives by providing a supply chain that minimises risk and total cost to the business. To provide a supply base that will help the business maintain competitive advantage through technical competence, efficiency, agility and quality of goods or services.
To help protect the integrity of our business, our brands and our products via robust and detailed technical supply chain assurance. To maintain our business commitment to always act ethically and with integrity whilst also ensuring that everyone within our supply chains takes the same approach.
3 Organisation's structure
Valeo Confectionery is a private limited company registered in England and Wales; company number 02025064
During the period covered by this statement Valeo Confectionery was owned by the Valeo Snackfoods group. Valeo Confectionery operates from six sites across the UK (Pontefract, York, Cleckheaton, Liverpool, Blackburn and Blackpool), is an international supplier and a leading UK independent manufacturer of sugar confectionery.
4 Our Supply Chains
Valeo Confectionery operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on suppliers before allowing them to become a preferred supplier and request that they are SEDEX registered and as such conform to all elements of the ETI (Ethical Trading Initiative) requirements. On site supplier audits are also carried out where deemed necessary.
Compliance with the ETI requires that in supplier organisations:
- Employment is freely chosen
2. Freedom of association and the right to collective bargaining are respected
3. They hold their own suppliers to account over compliance to ETI standards
4. (For UK based suppliers) They pay their employees at least the national minimum wage/ national living wage (as appropriate)
5. (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
6. Are clear that we will terminate the contract at any time should any instances of modern slavery come to light
5 Our policies on slavery and human trafficking
Valeo Confectionery has several policies and/or procedures in place to help it combat modern slavery:
5.1 Code of Conduct Policy (Employees)
This policy sets out Valeo Confectionery’ internal standards, expectations and accountability.
It incorporates an understanding of the risks of modern slavery and human trafficking within our business and supply chains.
The Code of Conduct is available to employees via our intranet and any updates are communicated to employees as appropriate. Employees who breach our Code of Conduct and any related policies may be subject to disciplinary proceedings.
5.2 Whistleblowing Policy
The Whistleblowing Policy allows all employees, agency workers and contractors a route for anonymous reporting of any concerns that they have in relation to a number of issues and it can be used to report suspected incidents of modern slavery. The Policy is reviewed and updated as necessary and then communicated to employees. The main options for reporting are:
- Line management;
- Contact the external whistleblowing provider SeeHearSpeakUp via email, telephone or online, details of which are provided to employees through internal communications.
The Policy also includes our zero tolerance of retaliation.
5.3 Hidden Labour and Exploitation Policy
The Hidden Labour and Exploitation Policy confirms that Valeo Confectionery is an active member of SEDEX (Supplier Ethical Data Exchange). As part of its membership, Valeo Confectionery is required to undertake regular, semi-announced audits based on the ETI (Ethical Trade Initiative) Base Code which is founded on the conventions of the International Labour Organisation and its internationally recognised code of labour practice covering 9 provisions:
- Employment is freely chosen;
- Freedom of association;
- Working conditions are safe and hygienic;
- Child labour shall not be used;
- Living wages are paid;
- Working hours are not excessive;
- No discrimination is practiced;
- Regular employment is provided; and
- No harsh or inhumane treatment is allowed.
Responsibility for the preparation of our Modern Slavery Statement sits with our legal team and is approved by our board of directors. The following departments are responsible for carrying out the implementation of policies, codes and procedures: Legal, Procurement, Technical, Operations & HR.
6 Due diligence processes for slavery and human trafficking
Our direct supply chains include the sourcing of raw materials related to the manufacture of our products, as well as finished goods from our co-manufacturing partners.
To ensure that Modern Slavery is not present in these supply chains, we have communicated our commitment to the Modern Slavery Act 2015 and expressed a requirement that our suppliers and any new supplier that we contract with make the same commitment.
Ethical risk is currently managed via an annual questionnaire (as set out in section 6.4) to suppliers with a thorough investigation of responses or procedures conducted where necessary.
6.1 Procurement Process
Our existing first tier suppliers are subject to an annual review of supply chain risk in terms of ethical, quality and supply capabilities. This enables us to monitor changes and highlight any areas of concern for further investigation and follow up with the individual supplier.
As our portfolio of raw materials and co-manufacturing changes, we endeavour to only source from countries that have a low ethical and sustainability risk.
6.2 Risk Assessment and Management
The following groups of workers have been identified as vulnerable to the risks of modern slavery and Valeo Confectionery’ Human Resources (HR) Team is mindful of this and experienced when dealing with workers who fall into one of the following categories:-
- Migrant workers;
- Minority groups; and
- Contract, agency and temporary workers.
In addition to the above, the following have been identified as potential indicators of modern slavery and our HR team is experienced in maintaining awareness of these and following up in an appropriate manner:-
- Someone who does not have their own passport, ID or travel documents;
- Someone who always allows others to speak for them or talks as though being instructed or coached by someone else;
- Someone who may be withdrawn or appear frightened and may have injuries;
- A person who has limited social interaction and may always be dropped off and collected from work (they may not be able to contact their friends and family easily);
- A person with very few possessions or who lives in a very poorly maintained, overcrowded place (and is often overcharged for this);
- A person who has little control over their finances or who has no access to a bank account;
- Recruitment fees and labour agents;
- Cash in hand payments;
- No unions; and/or
- No access to grievance mechanisms.
This is not an exhaustive list and other factors may also be considered relevant, but the key consideration is awareness. The above are not conclusive evidence of modern slavery but should be taken as warning signs. If a concern is raised to our HR team, the matter would be immediately referred to the relevant Valeo Confectionery Senior Business Partner. Depending on the severity of the issue and warning signs, they may contact the police in the first instance.
In consideration of the indicators above, Valeo Confectionery has several pre-emptive measures in place including:
- We do not accept any communication through a third party on behalf of an employee;
- We do not pay an employee’s salary into a third-party bank account;
- We will not raise a cheque in another person’s name even if requested by the employee;
- We will not process any application for employment or issue a contract of employment unless the employee has an address;
- We do not prevent membership of a union or representative body; and
- We have in place easily accessible grievance procedures available to all employee, agency and contract workers.
Other high risk areas identified are raw materials sourced internationally via agents. Risks are controlled by ensuring that all agents evidence that their suppliers are compliant with the ETI requirements.
6.3 Supplier relationships
Valeo Confectionery’s Head of Procurement is responsible for supplier relationships. If there are concerns related to a Supplier’s conformance to our policies and requirements the Head of Procurement will evaluate the situation and take any further appropriate action which may include (but is not limited to) the following:
- Reporting concerns to the appropriate authorities;
- More frequent audits; and/or
- Termination of the supplier relationship.
6.4 Audit Programme
Audits are conducted by Valeo Confectionery’s Technical Team.
All suppliers are required to complete the Valeo Confectionery Supplier Questionnaire and Risk Assessment every 12 or 18 months depending on risk. If a supplier is not SEDEX registered such supplier will automatically be considered high risk and must provide documentation to Valeo Confectionery to demonstrate it has conducted due diligence with its suppliers.
7 Key Performance Indicators
To monitor the effectiveness of the steps that we have taken to combat modern slavery and human trafficking in our business and its supply chains, we use the following key performance indicators (“KPI’s”) for each financial year:
- All new employees are provided with appropriate training on induction to the business as detailed in section 8, below;
- Our Modern Slavery Policy and any updates are communicated to all employees;
- We will establish which suppliers are considered to be high risk and ensure that our zero-tolerance approach to modern slavery is communicated and require them to confirm adherence to our Modern Slavery Policy as a minimum;
- We will continue to develop our risk assessment and due diligence processes and put in place further measures where areas of risk are identified; and
- The Procurement, Technical and HR teams have each drafted a Mission Statement for their departments underpinning the company’s Mission Statement set out in section 2 of this Statement ensuring that the issue of modern slavery is utmost in the thoughts of its employees when forming new business relationships and making sure that similar standards are maintained in its existing business connections.
Valeo Confectionery conducts training and assessment as part of the induction into the organisation for all new employees via e-learning with a test to demonstrate understanding of the concepts taken at the conclusion of the session with employees expected to gain 80% and above.
9 Finding Help
If you or someone you know is being or has been exploited or you are unsure if someone needs help, assistance and advice is available:
- for life-threatening emergencies, call 999, or for non-emergencies, call 101 for the police;
- Modern Slavery Helplinecan be called on 08000 121 700 or contacted via an online form;
- Victim Supportcan be called on 0808 16 89 111 or contacted via an online form;
- Crimestopperscan be called on 0800 555 111 or contacted via an online form;
- Migrant Helpcan be called on 0808 8010 503;
- The Salvation Armyhave a 24/7 confidential referral helpline, which can be called on 0800 808 3733.
Valeo Confectionery’s Modern Slavery Statements (current and previous Statements) are published on:
- Valeo Confectionery’s website; and
- TISC (Transparency In Supply Chains) – open platform reporting tool which meets the requirements of section 54 of the Modern Slavery Act 2015.
At the date of this statement, Valeo Confectionery has no issues with any of its suppliers or other bodies representing workers that should be disclosed in the context of the Modern Slavery Act 2015.
Valeo Confectionery is constantly striving for improvement to tackle modern slavery head on. During the period 1st April 2020 to 31st March 2021, Valeo Confectionery continued to work to increase awareness of risks and reporting channels. We will continue to develop our commitment to combat modern slavery and will update our company policies, contracts and employee training as appropriate.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st March 2021. It was adopted by the board on 21 September 2021.