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Slavery and human trafficking statement
Introduction
This statement sets out Karnova’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. This statement relates to actions and activities during the financial year 2023.
As part of the meat industry, 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
This statement covers the activities of Karnova:
- Meat processing to supply protein ingredients in a business to business environment
Countries of operation – United Kingdom
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:
- We operate in line with our Responsible Sourcing Policy and our supplier approval process as well as in line with current ETI base code
Karnova considers ourselves as not having been involved in any high-risk of slavery or human trafficking.
Relevant Policies
The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
- Whistleblowing Policy
The organisation 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 our external confidential helpline ‘Safecall’ or use our confidential disclosure post box. Telephone numbers are displayed on our notice boards.
- Employee Code of Conduct
The organisation’s code 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 both at the organisations premises and when operating abroad and managing its supply chain.
- Responsible Sourcing Policy
The organisation 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. The organisation 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.
- Recruitment/Agency Workers Policy
The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. Agencies are audited in detail every 6 months by our HR department in risk of slavery and human trafficking.
- Human Rights Policy
In our Company and across our system, we are committed to ensuring that people are treated with dignity and respect. The organisations Human Rights Policy is guided by international human rights principles encompassed in the Universal Declaration of Human Rights, the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact and the United Nations Guiding Principles on Business and Human Rights.
- Health and Wellbeing Policy
We have conducted Mental Health awareness training which this policy aims to provide a workplace where staff can speak openly about their Mental Health and offers protection against discrimination for those who suffer from Mental Illness.
Risk Assessments and Due Diligence:
- After the Stronger Together training, we have implemented an action plan to identify and respond to risks in our business and supply chain. We use Sedex to help us assess and manage compliance in our business.
- SMETA audits are undertaken by a select number of approved independent third-party audit providers using established SMETA methodology. Our last Audit was conducted in February 2024, which we passed.
Due Diligence
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:
- evaluating the modern slavery and human trafficking risks of each new supplier
- reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
- evaluate audits or assessments conducted through a third-party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified.
- taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through third party auditor and requiring them to implement action plans
- participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular, such as participation in “Stronger together” or “Ethical trading” initiatives.
- using Sedex, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
- 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.
- Any changes on official guidelines regarding COVID 19 are displayed and communicated to the employees.
- All workers are still able to access procedures and that new or adapted procedures are available where necessary.
Training
- Stronger Together training has taken place within the company, at senior management and stake holder level, to better understand and respond to the identified slavery and human trafficking risks. It is our intention to train all Managers/Supervisors in this area.
The organisation’s modern slavery training covers:
- our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
- how to identify the signs of slavery and human trafficking.
- what initial steps should be taken if slavery or human trafficking is suspected.
- how to escalate 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, Gangmasters and Labour Abuse Authority (GLAA) and “Stronger together” initiative.
- what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
- what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.
Mental Health Awareness Training
- An external company, ‘MIND’ conducted training for all our Managers on mental health awareness.
- This could enable the Managers to identify the signs which could indicate a mental health concern arising from human trafficking.
- MIND helpline contact details have been displayed on company notice boards.
- We have mental health first aiders on site and external training was conducted with the HR department.
- On the last Friday of each month, we have a trained counsellor on site from MIND, for any of our employees to drop in to speak with them throughout the day.
Awareness-Raising Programme
As well as training staff, the organisation has raised awareness of modern slavery issues by putting up posters across the organisation’s premises.
The posters explain to staff:
- the basic principles of the Modern Slavery Act 2015.
- how employers can identify and prevent slavery and human trafficking.
- what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
- what external help is available, for example through the Modern Slavery Helpline and MIND helpline, and the external confidential whistleblowing line.
This statement has been approved by the organisation’s board of directors, who will review and update it annually.