This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It sets out the steps taken and progress made by Hovis Limited during the financial year ending 30 September 2023 to prevent modern slavery and human trafficking in its business and supply chain.
Hovis is an iconic household brand with over 135 years’ experience in the baking industry. Our core values apply to everything we do and are centred on three key principles: quality, accountability and trust. We are proud of our heritage and reputation and are committed to putting Hovis goodness at the heart of every day. We recognise that, to achieve this, we must adhere to the highest possible standards in everything we do. This commitment includes ensuring that people within our business and our supply chain are treated with dignity and respect and taking proactive steps to tackle and prevent slavery, servitude and human trafficking.
Our business and supply chain
Hovis Limited is the trading entity for the Hovis group which is ultimately owned by Endless LLP. The
Hovis group structure is as follows:
Headquartered in High Wycombe, Hovis Limited (“Hovis”) employs around 2,900 employees in the United Kingdom. We also use a small percentage of agency labour in our business which is sourced through carefully selected, reputable recruitment agencies who are signed up to our terms and conditions for modern slavery. We recognise and respect our employees’ rights to join trade unions and to bargain collectively and we adopt a collaborative approach to working with trade unions within our business.
We have eight bakeries in England, Scotland and Northern Ireland producing high quality bread and other bakery products. We also have one flour mill based in Wellingborough and two regional distribution centres, enabling us to deliver over one million loaves every day of the week throughout the United Kingdom and Ireland. Our core brands include Hovis®, Mothers Pride® and Ormo®.
We work with over 1200 suppliers across our supply chain. Our suppliers are an integral part of our business, and we work closely with them to build sustainable and trusted business relationships. Our direct suppliers provide ingredients and packaging for our products. The majority of our raw ingredients and packaging materials are sourced from suppliers based in the United Kingdom and Europe; however, we do source some minor and seasonal ingredients from further afield such as Turkey and China. Our indirect suppliers provide us with goods or services to support the day-to-day business operations, such as utilities, maintenance, logistics and baker equipment.
Our policies on slavery and human trafficking
Hovis does not tolerate any form of modern slavery in its business or supply chain and is committed to
eradicating such practices and protecting the workforce. We employ a number of policies, systems and
controls to ensure that we are conducting our business in an ethical, responsible and transparent
Anti-slavery Policy: This policy applies to all employees and agency workers of Hovis. It sets out roles and responsibilities, what behaviours constitute slavery, how to identify any
instances of slavery or servitude and the procedures to follow if concerns are identified.
Recruitment Procedure: We (and our recruitment agencies) operate a robust recruitment
procedure, including conducting eligibility to work in the UK checks for all employees and
agency workers, to safeguard against human trafficking or individuals being forced to work
against their will.
Whistleblowing Policy: This policy applies to all employees and agency workers of Hovis. It sets out how to raise concerns about how employees are being treated, or practices within our business or supply chain, without fear of reprisals.
Safecall line: Hovis supports a culture of openness and transparency. In conjunction with the
Whistleblowing Policy, Hovis operates a Safecall line that can be contacted (by telephone) 24 hours a day, 365 days a year to allow employees and workers to report (anonymously if they wish) concerns of unethical conduct or behaviour. This therefore gives individuals a method of reporting suspected incidents of slavery or servitude in a confidential manner. All complaints or reports are investigated.
Code of Conduct: This code aligns with our core values and explains the way Hovis operates as an organisation and how we expect our employees and workers to behave. In particular it requires all employees and agency workers to ensure that they comply with applicable laws, rules and regulations; to act with honesty and integrity; and to treat people fairly with dignity and respect. Non-compliance with the code may result in disciplinary action being taken.
Human Rights Policy: Hovis’ Human Rights Policy is publically available on the Hovis website (www.hovis.co.uk). It sets out our commitment and the steps we take to meet our responsibility to respect internationally recognised human rights standards. It is guided by the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. It applies to Hovis employees, workers, contractors, suppliers and any other third parties working with us.
Due diligence processes for slavery and human trafficking
Forced labour, in any form, has no place in Hovis’ operations and supply chains. Hovis has an Ethical Trading Policy Statement, which is based around internationally recognised code of labour practices, setting out the minimum standards we expect all of our suppliers and business partners to adhere to. Suppliers are obliged to adhere to our Ethical Trading Policy Statement, as well as our Human Rights Policy, as part of our standard terms and conditions of purchase and the Ethical Trading Policy Statement is reissued to all incumbent suppliers on an annual basis to reinforce the expectations placed on our suppliers to respect workers’ rights and improve working practices.
Hovis continues to be a member of SEDEX (the Supplier Ethical Trading Data Exchange), a not-for-profit membership organisation dedicated to driving improvements in ethical and responsible business practices in global supply chains. We require all direct ingredients and packaging suppliers to be members of SEDEX to give us visibility of their ethical performance and to aid the assessment of risk in our supply chain. In addition, all of our manufacturing sites are SEDEX registered and have completed the self-assessment questionnaire, providing a risk rating. Furthermore, most sites are independently audited to the SMETA standard. Actions to correct any non-conformances resulting from the audits are detailed by the site in a corrective action plan.
All procurement centrally sourced suppliers must complete a Supplier Due Diligence Questionnaire to enable the business to understand the steps prospective suppliers are taking to prevent modern slavery and human trafficking in their supply chains and to identify and work with them to mitigate any risk. This measure gives Hovis greater visibility and understanding of its supply chain from the outset and ensures that Hovis does not appoint or work with any centrally sourced suppliers unless and until it is satisfied that they demonstrate and implement standards that are aligned with our policies, expectations and values.
To ensure that Hovis’ suppliers comply with the Modern Slavery Act 2015, we continue to include contractual ‘anti-slavery’ provisions in our agreements that require our suppliers to confirm to us that they have and continue to take steps to prevent modern slavery within their business and supply chain and to report any incidents or suspected incidents to us. Where appropriate, we also include a contractual right to conduct audits of suppliers to ensure compliance with all applicable laws, regulations and contractual terms, including the prohibition against forced labour, slavery and human trafficking.
Assessment of risk
We work in conjunction with our suppliers to assess the risk of slavery and human trafficking in our supply chain. Hovis purchases a wide range of goods and services, predominantly from suppliers based in the UK and Europe, which are seen as lower risk, however, we do procure products from the agriculture sector and a limited range of goods from suppliers outside of Europe, which are considered to pose a greater risk from a modern slavery perspective.
We have a compulsory ethical component incorporated into our food safety and compliance audits to ensure that both physical (higher risk) and desktop (lower risk) supplier audits include questions which are specifically designed to help identify potential signs of modern slavery in the workplace. In addition, we have worked closely with and provided training to key internal stakeholders in our procurement and technical functions, who will often visit suppliers’ premises, to enable them to know the signs to look out for during any such visits and they are encouraged to report any concerns.
In 2022 we continued to work with an independent external compliance organisation to conduct SMETA audits of a further 5 key suppliers who were identified by our procurement function as being medium to high risk from a modern slavery perspective based on Stronger Together guidance on assessing supply chain risk, Hovis’ knowledge, the source of the raw materials and/or the nature of the services and the level of spend. As a result of the audits conducted, several minor non-conformances were identified and raised with suppliers, including lack of signposting to modern slavery (ETI base code) documents, working hours exceeding legal limits, a reduction in the amount of training due to the Coronavirus pandemic and general policy updates being required. We are working with these suppliers to ensure that appropriate corrective action plans are in place so that these points are rectified within reasonable timeframes (more than 90% of which are already complete). Importantly, the external auditor also noted some extremely positive practices including free transport and meals, bonus payments, good health care and ISO accreditations.
In 2022 we also continued our supply chain mapping exercise of our key tier 1 suppliers to enable us to have a greater understanding of our supply chain and more easily identify higher risk suppliers based on sector, country of origin of raw material, SEDEX risk rating and a geographical risk index pertaining to human rights. This has enabled us to start to identify higher risk key tier 2 suppliers, which will allow us to expand our risk assessment strategy and conduct audit beyond our immediate supply base, thereby further enhancing our compliance.
We have also considered the risk of slavery and human trafficking in our operations via the use of agency labour, and we consider the risk to be low due to the robust recruitment and on boarding processes that we, and our recruitment agencies, abide by. In addition, members of our Human Resources team, who have received modern slavery awareness training, conduct regular audits of the recruitment agencies we use, including selecting a random sample of workers to speak with to identify any concerns or breaches of the applicable legislation and policies. In the 2022/3 financial year, no material non-conformances were identified as a result of these audits.
Key Performance Indicators
We monitor and measure for signs of modern slavery through several key indicators including: the number of whistleblowing reports received in relation to modern slavery; the number of non- conformances in audits; the number of non-conformances in ethical audits (SEDEX) and the number of external alerts in relation to modern slavery. Our monitoring was positive with no reports of exploitation, modern slavery or trafficking.
Training & Education
We regard training as being a fundamental way of raising awareness of the issue of modern slavery and labour exploitation, giving staff the tools to be able to identify suspected cases and to know what to do if they encounter a situation that causes concern.
In the 2022/3 financial year, we continued to build on our training programme ensuring including modern slavery training in our induction programmes.
We continue to ensure that any new starters within our Procurement team receive focused Stronger Together training on tackling modern slavery through purchasing practices, to enable them to better understand and assess modern slavery risks in our supply chain and how they play a pivotal role in helping the business to prevent such at an operational level by being the forefront of our business controls.
During the week commencing 18 October 2023, Hovis held its third Anti-Slavery Awareness Week event across all sites to coincide with International Anti-Slavery Awareness Day to highlight the issues and the ways in which Hovis are working to tackle and prevent human trafficking and modern slavery.
Events included the displaying of information on site, quizzes (with prizes) relating to modern slavery, lunch and learn sessions and the distribution of materials to colleagues.
During the 2023/4 financial year we will continue to raise employee’s awareness of modern slavery through: continued training and awareness for all colleagues refresher training for our HR and operational colleague in relation to spotting the signs of modern slavery; undertaking proactive screening in relation to modern slavery red flags and introducing e-learning modules in relation to modern slavery.
This statement was approved by the Board of Director of Hovis Limited on 29 November 2023.