This statement is made by Emmett UK Ltd and Emmett UK Produce Ltd (together “Emmett”). It is a statement made in accordance with section 54 of the Modern Slavery Act 2015 and covers the year from December 2020 – November 2021.
Emmett is committed to acting ethically and with integrity in all our business dealings and relationships.
Our values help us to be consistent in what we do and guide our decision making when the answer is not always clear. One of our core values is to “Treat people as we wish to be treated” and it is imperative that we take the right steps to ensure that modern slavery is not occurring in our workplace or supply chains.
We have a zero-tolerance approach to modern slavery occurring within our own business and our supply chains. We understand that we have a responsibility to address modern slavery risks and to support this we have robust policies and training in place to tackle and prevent modern slavery practices.
Emmett is a privately-owned agricultural business that grows vegetables and packages them for the retail sector.
We have farming operations across the UK, Spain and Italy. Our Head Office is situated in Fosdyke, Lincolnshire which is where we pack and dispatch the majority of our products.
We have a diverse workforce and employ many different nationalities. In 2015 we set ourselves an aim to directly employ 100% of our staff in small teams by the end of 2018. We are making good progress towards our target and over the past 12 months we have reduced our percentage of staff engaged through labour suppliers to less than 10%. Whilst we might not reduce this figure to zero by our target date, we remain committed to our goal and hope to achieve it during 2021.
Where we do continue to engage staff via labour suppliers, we only work with a small number of reputable labour suppliers, all of which are licensed by the Gangmasters and Labour Abuse Authority (“GLAA”). We only use labour suppliers where needed to address fluctuations in the workforce and productivity levels.
The labour suppliers we work with are required to meet specific labour standards set by the GLAA relating to pay and conditions. As detailed below, we carry out audits of the labour suppliers on a 6-monthly basis, during which we inspect payslips, timesheets and the initial paperwork completed by the labour supplier for each worker, including contracts and work details.
Our employment practices
Our employment practices are regularly reviewed in the light of relevant employment and health and safety legislation. Responsibility flows from the top and our Directors take full responsibility for our anti-slavery initiatives and in executing our Preventing Hidden Labour Exploitation Policy. Emmett undertakes due diligence practices which include activities such as internal auditing of information and demographic monitoring of the workforce to identify any high-risk areas within our business. Where concerns exist, we would investigate and act upon these appropriately and immediately, and training in Investigative Interview Techniques has been undertaken by relevant staff.
Having said that we recognise that all employees across the business can support in identifying and preventing labour exploitation. We have set out below our achievements in training staff over the past year and our intentions for the year, in order to continue with our commitment to educate all staff about modern slavery and what they can do to identify and prevent exploitation both within our own business and our supply chains.
Our policies on the prevention of modern slavery
Emmett has an up to date Preventing Hidden Labour Exploitation Policy which sets out the Company’s commitment to prevent labour exploitation. In addition to this we support Managers in the business to attend relevant training and workshops to increase awareness and understanding of the issue and how it can be prevented and combatted in our business and supply chains. We have a full suite of policies throughout the business on all employment matters which reflects our commitment to act ethically and with integrity at all times.
Supplier due diligence
The Company recognises that there may be a risk of modern slavery practices in our business and supply chains and that one of the most significant risk areas is in the provision of labour to our operations. We thoroughly audit any labour suppliers that we use, and our audits are based around the Association of Labour providers (ALP) standards. This ensures that our labour providers are compliant with the requirements of the GLAA, employment and health and safety legislation and helps to ensure modern slavery is not practised and that all workers are treated ethically. Our audit process is regular and prior to engaging with a labour supplier a pre-audit will be conducted, with subsequent audits being conducted 6-monthly thereafter.
Emmett will not knowingly support or deal with any business involved in slavery or human trafficking but will support our suppliers in the eradication of modern slavery where this is uncovered in their business if practicable.
Training and education
Directors and Senior Managers within the business have and will continue to attend workshops on modern slavery and brief their teams accordingly.
Our induction programme includes slides on Modern Slavery and the video from Stronger Together – Daniel and Weronika’s Story.
We roll out the Stronger Together training module ‘Tackling Modern Slavery in UK Businesses’ to all Managers and Team Leaders and host events for Stronger Together on site (unfortunately though not this year owing to Covid restrictions).
Raising awareness among the wider workforce
We are continuing to raise awareness of our zero-tolerance approach to modern slavery across our Company and suppliers by doing the following:
- Displaying posters and materials to raise awareness.
- Offering a confidential ‘Speak Up’ helpline should employees wish to raise the matter confidentially.
- Conducting audits of our labour suppliers which may include worker interviews and verification of information to ensure workers are paid in accordance with legislation and are not subjected to forms of modern slavery.
- Continuing to work with Stronger Together to understand further actions we can take as a business.
- Enforcing strict controls throughout our recruitment process.
- Operating in accordance with ETI and SEDEX baselines.
Alex Boughton, Managing Director
This statement has been approved by the organisation’s board of directors who will review and update it annually.