Contents
1 Introduction
2 Kettle Foods Mission Statement
3 Organisation’s structure
4 Our Supply 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
Kettle Foods Ltd 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 Kettle Foods Ltd (“Kettle Foods” “we” “our” “us”). It outlines the measures Kettle Foods 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 Kettle Foods financial year commencing 1st April 2021.
Kettle Foods 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 Kettle Foods’ departments adopt this mission statement when dealing with its suppliers in addition to the following departmental commitments:
HR
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.
Technical
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.
Agriculture
To ensure an aligned, invested and engaged supply chain with our agricultural supply partners which manages and maintains the highest standards within its supply base.
Kettle Foods is a private limited company registered in England and Wales; company number 2238320.
During the period covered by this statement Kettle Foods was owned by Valeo Foods. Kettle Foods is a UK snack manufacturer supplying snack food to several countries and employing on average 420 people in the UK.
Founded in 1988 and with potatoes being one of our key raw materials we chose Norfolk as our home in order to be as close as possible to many of our potato growers.
Having expanded our snack portfolio to include Vegetable Chips, Popcorn and Rice Cakes, we now have in excess of 400 direct product suppliers.
Kettle Foods undertakes the manufacture of various snacks foods as set out below:-
All of our potatoes are sourced from farms in the UK and within an average of 30miles of the Kettle Foods factory in Norwich where supply permits. Kettle Foods’ Head of Agriculture is responsible for managing the supply chain and part of that role is to ensure that our potato suppliers maintain high ethical and environmentally sustainable practices. We only contract with potato suppliers who maintain high standards across all their practices. As testament to this, each supplier is contractually obliged to be a member of The Assured Produce Scheme and shall have passed its annual audit with 100% compliance. Our supply base and its suppliers are compelled to use seasonal labour each year to manage the seasonal nature of the industry. This labour force will be sourced from recognised and approved agencies. The agricultural suppliers are audited to the satisfaction of the Red Tractor or Global Gap Audits – this will be internally audited on an annual basis by Kettle Foods to ensure compliance. SEDEX Accreditation is the preferred status of Kettle Foods agricultural suppliers.
The Kettle Foods Potato Contract precedent has been amended to include a clause dedicated to modern slavery ensuring its suppliers comply with the law including but not limited to the Modern Slavery Act 2015 as well as other contractual obligations regarding combating modern slavery by requiring each potato supplier to:
All raw materials required to produce the potato chips including seasonings, film, cardboard and oil are sourced direct by our procurement team who ensure that due diligence is carried out before orders are placed. Kettle Foods has long standing relationships with the majority of our suppliers who maintain high standards and are as equally committed to ensuring that modern slavery is eradicated. As contracts between Kettle Foods and such suppliers are updated, renewed or new suppliers are engaged, Kettle Foods shall ensure that modern slavery is adequately addressed as part of the supplier’s contractual obligations.
Our Vegetable Chips are entirely sourced from our co-manufacturing partner within the EU, Yellow Chips B.V. (a company owned by the same parent company as Kettle Foods) and are supplied to either our Norfolk warehouse or direct to the customer. We maintain our high levels of ethical and environmental sustainability by working in close collaboration with our co-manufacturer.
As part of our responsible supply chain governance we ensure that raw materials such as root vegetables are sourced from reputable sources who undergo periodic audits by our co-manufacturer.
Our popcorn brands are all manufactured under Kettle Foods’ control at our Wednesbury facility in the West Midlands of the UK. The Wednesbury facility is managed under the same high ethical and environmental sustainability practices as our Norwich facility.
The popcorn kernels are all sourced from a sole supplier within the EU who is SEDEX registered and audited, and who is working with selected farms to develop a more sustainable and ethically aware process of producing popcorn kernels.
Our Rice Cakes are entirely sourced from a co-manufacturing partner within the EU before being supplied to either our Norfolk warehouse or direct to the customer. We maintain our high levels of ethical and environmental sustainability by working in close collaboration with this co-manufacturer.
As part of our responsible supply chain governance we ensure that raw materials such as rice and chocolate are sourced from reputable sources who undergo periodic audits by the co-manufacturer.
At the date of this statement, Kettle Foods 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.
Kettle Foods has several policies and/or procedures in place to help it combat modern slavery:
All suppliers are required to comply with our Anti-Slavery Policy as part of their contract. Our Anti-Slavery Policy sets out the minimum standards for working conditions that Kettle Foods expects its suppliers to adhere to in the production of raw materials required to make our products.
The Policy is subject to ongoing review and an updated version was made available during the period covered by this statement in September 2020. Some of the principles included in the Policy are:
Kettle Foods will not tolerate modern slavery, forced labour or human trafficking within our business dealings or supply chains. Where any non-compliance issue is identified, we expect and require our suppliers to address it. If this does not occur within a reasonable timeframe, we reserve the right to terminate our relationship with the supplier/third party in question.
This policy sets out Kettle Foods’ 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.
The Whistleblowing Policy allows employees 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:
The Policy also includes our zero tolerance of retaliation.
The Hidden Labour and Exploitation Policy confirms that Kettle Foods is an active member of SEDEX (Supplier Ethical Data Exchange). As part of its membership, Kettle Foods 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:
Kettle Foods has a trained ethical auditor who carries out such audits every 6 months. In addition, this Policy confirms that Kettle Foods is committed to investigating its tier 1 suppliers and has carried out risk assessments to satisfy itself that their actions are sufficient. Where Kettle Foods suppliers are not SEDEX registered, they are required to complete an “Ethical Supply Questionnaire” and are encouraged to gain SEDEX registration.
Any breaches of this Policy are reportable and appropriate action will be taken. The Policy was issued in January 2021 and will be reviewed and updated annually or sooner if necessary.
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, Agriculture & HR.
As set out in section 5.4, Kettle Foods is an active member of SEDEX a not for profit membership organisation that offers members a simple and effective way of managing ethical and responsible practices in supply chains.
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. These supply chains stretch across Europe and the UK.
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.
To this end, we have investigated how these direct suppliers are tackling the challenge and have carried out risk assessments to satisfy ourselves that their actions are sufficient; should we identify a risk then we will carry out follow up audits and education for the supplier. This will be an ongoing programme as we expand our reach into our extended supply chains.
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. All Kettle Foods’ suppliers are located within the European Union.
As set out in section 4.1, all Kettle Foods’ agricultural suppliers are required to adhere to contractual obligations regarding modern slavery. In this way, Kettle Foods ensures that its farmers/agricultural suppliers are aligned in their joint efforts to eradicate modern slavery in this aspect of the business.
All of Kettle Foods’ seasoning houses who supply the blended seasonings that are used to give the flavours to our snack products are SEDEX approved.
Kettle Foods imposes contractual obligations regarding Modern Slavery on its Suppliers and operates an ongoing programme of ensuring that such provisions are incorporated into the wording of its contracts starting with those that pose the highest risk, including but not limited to the following:
Our procurement team ensure, through the governance of the procurement process, that efficient, accountable, transparent and ethical practices are applied to acquire the materials and products that our business requires. Due diligence is completed before engaging with a supplier which may include a site visit and auditing of working conditions.
Governance of the procurement process includes:
Our existing first tier suppliers are subject to an annual review of supply chain risk in terms of ethical, environmental, sustainability and supply. 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, as such our current first tier supply chains stretch across Europe, and include Italy, France, Netherlands, Denmark, Germany, Slovenia and Czech Republic.
The following groups of workers have been identified as vulnerable to the risks of modern slavery and Kettle Foods’ Human Resources (HR) Team is trained to be mindful of this when dealing with workers who fall into one of these categories:-
In addition to the above, the following have been identified as potential indicators of modern slavery and our HR team is trained to be aware of these and act as appropriate:-
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 Kettle Foods’ HR Director. Depending on the severity of the issue and warning signs, the HR Director may contact the police in the first instance.
In consideration of the indicators above, Kettle Foods has several pre-emptive measures in place including:
Kettle Foods’ Head of Procurement and its Head of Agriculture are responsible for supplier relationships. If there are concerns over performance, these individuals will decide whether to continue to do business with the relevant supplier and take any further appropriate action which may include (but is not limited to) the following:
Audits are conducted by Kettle Foods’ Technical Team. Also, our HR team conducts regular audits of our recruitment agencies where temporary staff are supplied to our 3 sites in the UK which includes a verification that the agency provider has developed and implemented a “tracking modern slavery policy” detailing the processes it will take to prevent forced labour.
As part of our SEDEX membership, and our conditions of supply with a number of our key customers, we are required to undertake regular semi-announced SEDEX Members Ethical Trade Audits (SMETA).
All suppliers are required to complete the Kettle Foods 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 Kettle Foods to demonstrate it has conducted due diligence with its suppliers.
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:
Kettle Foods 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.
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:
Kettle Foods’ Modern Slavery Statements (current and previous Statements) are published on:
In addition, this Modern Slavery Statement will be published on the UK Government’s Modern Slavery Statement Registry.
Kettle Foods is constantly striving for improvement to tackle modern slavery head on. During the period 1st April 2020 to 31st March 2021, Kettle Foods 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 25th August 2021. |
Modern Slavery Statement dated 22.09.20 from Apr 20 to Mar 21
Modern Slavery Statement dated 22.09.20 from Aug 19 to Mar 20
Modern Slavery Statement dated 23.01.20 from Aug 18 to Jul 19
Modern Slavery Statement dated 24.01.19 from Jan to Jul 2019
Modern Slavery Statement dated 27.06.18 for financial year 2018
Modern Slavery Statement dated 22.06.17 for financial year 2017
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