Modern slavery policy

Modern Slavery Statement 2024

1: Opening statement from senior management

Wismettac EMEA Holdings Limited (also referred to as ‘we’, ’our’ or ’us’) is, and will continue to be, committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chain. As such, we impose the same high standards on our suppliers. We are aware as a business, which is part of a global group, that we have obligations to do what we can to prevent slavery and human trafficking in our supply chains and we take a zero-tolerance approach slavery and human trafficking.

Building on previous years, we continue working together as a group to approach the issue of slavery and human trafficking. We have identified slavery and human trafficking as a key area of importance at group level and we have strengthened our commitment to prevent slavery and human trafficking.

Tackling slavery and human trafficking is a high priority for us and we have put new measures in place to enable us to work towards preventing slavery and human trafficking in our supply chains. Whilst we are proud of the steps we have taken so far, it is our aim as a business to continue to develop our approach and strategy so that we can strengthen how we deal with slavery and human trafficking.

This statement sets out information about our business and supply chain, what steps we have taken to combat modern slavery and what our key priorities will be for the next financial year.

2: Structure of the organisation

Wismettac EMEA Holdings Limited operates as a holding company for the EMEA region covering entities in the UK, France, Germany, Italy and Netherlands. In the UK, Wismettac Harro Foods Limited in Chessington and Sco-Fro Group in Glasgow carry out our operations. We are part of the Nishimoto Wismettac Group (the ‘Group’), which is a global group in the sector of wholesaling and distribution of food. The Group employs more than 2,000 employees across the world, and we and our subsidiaries employ around 300 employees in the UK and Europe.

In order to supply food products, we work with a range of suppliers both in the United Kingdom and overseas. As is the case for many food suppliers, our supply chains are fluid and many of our suppliers in turn source products from other suppliers. It is our hope that the measures we have put in place and will continue to put in place, will have a positive effect in relation to our supply chains as a whole.

In addition to suppliers of food, we also work with suppliers of goods and services relating to our offices.

3: Our policy

As part of our commitment to combating slavery and human trafficking, we have implemented the Wismettac EMEA Holdings Anti-Slavery Policy (the ‘Policy’) which ensures that we have effective systems and controls in place to reduce the risk of slavery and human trafficking in our supply chains.

The Policy has been made available to our employees and it forms an important part of the policies we require our employees to be aware of and adhere to.

We also make sure our suppliers are aware of the Policy and require that they adhere to the same high standards.

4: Preventing modern slavery and human trafficking in our business

In addition to our Policy (which is described above), we have in place procedures to reduce the risk of slavery and human trafficking in our own business. This includes:

a) carrying out checks to make sure that our own employees and workers have the legal right to work in the United Kingdom;

b) ensuring that we engage only with reputable recruitment agencies and requiring them to carry out checks on workers; and

c) encouraging employees and workers to notify management if they have any concerns connected to modern slavery so that we are able to investigate and deal effectively with potential issues.

5: Due diligence

Due Diligence Procedure

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted due diligence procedures that are designed to:

  • establish and assess areas of potential risk in our business and supply chains;
  • monitor potential risk areas in our business and supply chains;
  • reduce the risk of slavery and human trafficking occurring in our business and supply chains; and
  • provide adequate protection for whistleblowers.

Sedex

We are a member of Sedex, which is an online platform designed to improve conditions in supply chains. It is our intention to utilise the Sedex platform to promote transparency about our company and suppliers.

6: Risk and compliance

Wismettac EMEA Holdings Limited regularly evaluates the nature and extent of its exposure to the risk of slavery and human trafficking occurring in our supply chain. It is our intention to strengthen our approach over the coming financial year by considering whether circumstances warrant us carrying out audits of suppliers for their compliance with our Policy.

We also intend to assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts. Using our risked-based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Policy, which sets out the minimum standards required to combat slavery and trafficking.

We ensure all our suppliers adhere to our Policy. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find evidence of a failure to comply with our Policy we will immediately seek to help them identify areas for improvement within a defined timeframe.

7: Effectiveness and KPIs

Wismettac EMEA Holding Limited uses key performance indicators (KPIs) to measure how successful we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains. We conduct an annual survey of our suppliers, and target more than 50% participation each year. When ranking our suppliers’ approach to tackling Modern Slavery, we can see signs of improvement as awareness grows. In 2024, we intend to continue and refresh our own awareness training for staff, and review and survey our suppliers again to track progress.

8: Training

Wsimettac EMEA Holdings Limited has developed a training programme which aims to educate our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees are encouraged to identify and report any potential breaches of our Policy. Employees are also taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

We started the training programme in early 2021 and continue it with all newcomers to the company.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2023

This statement was approved by the board of directors on 9 October 2024

Signature:

Ian Hetherington, CEO – EMEA
Region Wismettac EMEA Holdings Limited
Date: 9 October 2024