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 31 December 2020 to prevent modern slavery and human trafficking in its business and supply chains.
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 was acquired by Endless LLP from The Gores Group (51%) and Premier Foods Group Limited (49%) on 5 November 2020.
Headquartered in High Wycombe, Hovis Limited (“Hovis”) employs around 2,850 employees in the United Kingdom. We also use agency labour in our business which is sourced through carefully selected, reputable recruitment agencies. 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 1100 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, security and office supplies.
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 manner:
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 colleagues 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. Any complaints or reports will be investigated.
Code of Conduct: This code aligns with our core values and explains the manner in which 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.
In 2020 the above policies were reviewed to ensure that they are robust, fit for purpose and in line with best practice, thereby ensuring that they are an effective tool in helping to prevent any form of modern slavery or labour exploitation in our business. In addition, to enhance our governance in this area further, we established an Ethical Standards Committee with key representatives from HR, Legal, Procurement, Technical, Logistics and Manufacturing functions. This Committee met, and will continue to meet, quarterly and are responsible for:
investigating any complaints or concerns raised regarding modern slavery in our business or supply chain;
ensuring that Hovis is continuously improving and enhancing its compliance programme to combat human trafficking and modern slavery;
overseeing Hovis’ compliance with its responsibilities pursuant to the Modern Slavery Act 2015; and
monitoring progress against the performance indicators set out in our Slavery and Human Trafficking Statement.
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 (which covers approximately 63% of our total annual spend) 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. No concerns or non-conformances were identified in 2020, however, it is noted that due to the Coronavirus pandemic the number of physical site visits were limited.
In 2020 we continued to work with an independent external compliance organisation to conduct SMETA audits of a further 6 key suppliers who are 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 relating to working hours, overtime pay and policy improvements were identified and raised with the suppliers. 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 (some of which are already complete). Importantly, the external auditor also noted some extremely positive practices including bonus and recognition payments, ISO accreditations and positive workforce engagement and attendance.
In 2020 we also commenced work on conducting a 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 will, in turn, help us to take a more structured, targeted approach to our audit activities and enable us to develop a longer term strategy thereby 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 2020, no material non-conformances were identified as a result of these audits.
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 2020, we continued to build on our training programme in this area:
by including a modern slavery section within our compulsory legal compliance training that all new senior management team members must attend as part of their induction on joining the business;
with a further 56 stakeholders attending training workshops with Stronger Together on tackling modern slavery in UK business, including a number of site FLMs and Union Representatives. This takes the total number of stakeholders who have received the Stronger Together training in the last two years to over 140 people.
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.
In addition, in November/December 2020 Hovis held its first Anti-Slavery Awareness events across all sites to:
increase awareness across the entire workforce of the steps the business is taking to tackle and prevent human trafficking and modern slavery in our business and supply chain; and
highlight the circumstances that may indicate a person is being exploited and signposting them to both internal and external sources to raise their concerns and/or seek help and support.
These awareness events included:
displaying a presentation on screens regarding Hovis’ Ethical Standards Committee and the steps the business is taking to prevent modern slavery and human trafficking in our business and supply chain;
displaying materials (posters and videos) from Stronger Together and the GLAA signposting external resources for help and information;
running awareness stands, hosted by HR and our primary agency labour providers, with leaflets available; and
running quizzes / competitions based on statistics regarding modern day slavery to encourage engagement.
Feedback on this initiative has been extremely positive and it gained a good level of engagement at all stakeholder levels, therefore, the business intends to make this an annual event going forwards.
Effectiveness in combating slavery and human trafficking & report on progress in 2020
We set ourselves a number of performance indicators for 2020 against which we would measure our progress in taking steps to identify, assess and combat modern slavery, labour exploitation and human trafficking in our business and supply chain. We are pleased to report that we have achieved all of our performance indicators for 2020 as detailed above.
Performance indicators for 2021
In order to assess our progress and to ensure continuous improvement, in 2021 we will take the following actions:
Our appointed auditors will complete three (3) ‘at source’ audits of ingredients suppliers in Turkey and China and a further three (3) audits of UK suppliers that have been identified as higher risk from our supply chain mapping exercise;
We will ensure that a further twenty five (25) suppliers complete Hovis’ due diligence questionnaire and review process;
We will hold an anti-slavery awareness event across all sites to coincide with International Anti-Slavery Awareness Day on 18 October 2021;
We will ensure that a minimum of twenty five (25) further stakeholders within the business undertake compulsory modern slavery training with Stronger Together, including FLMs, Union Representatives and Wellbeing Champions;
We will promote the business’ commitment to tackle slavery and human trafficking and the work of the Ethical Standards Committee’s via our company communication platform and at quarterly site briefings;
We will constantly seek to improve our working practices and reduce the number of non-conformances from our sites SMETA audits year on year, whilst closing out any such non-comformances, where appropriate, in a timely manner.
This statement has been approved by the Board of Directors of Hovis Limited on 13 May 2021.