Modern Slavery Statement
This statement is made in line with Section 54 of the Modern Slavery Act 2015. It sets out the steps Riverford Organic Farmers have taken to reduce the risk of modern slavery in our supply chain, and our own operations, for the financial year ending April 30th 2019.
We’ve put together a transparent report on:
- The measures we take against actual and potential risks of modern slavery
- Progress we’ve made in the past year
What is modern slavery?
Modern slavery is a crime that encompasses the many ways people can be exploited and forced to work for little or no pay – such as forced labour or forced marriage. Victims are controlled by force, threats, coercion, abduction, fraud and deception.
It’s a growing problem; in 2016, up to 40.3 million people across the globe were estimated to be living in some form of modern slavery. Increased migration is making many people more vulnerable to human trafficking and exploitation, with modern slavery being found in all industry sectors, from agriculture and fishing to domestic work.
The problem isn’t limited to any one region. While Africa has the highest prevalence of victims of modern slavery (7.6 people per 1000) and is perceived as a risk area because of high incidences of migration and conflict, the UK still had 6,993 potential cases of modern slavery in 2018, a 36% increase on 2017 (Unseenuk, 2018), with estimates of up to 13,000 trafficking victims (Dept of Justice, 2018).
Riverford is known for dealing fairly with co-owners, suppliers and customers; fairness is one of our founding values, and remains at the heart of all we do. We are committed to remaining vigilant against the risks of modern slavery throughout our supply chain.
Key progress in the 2018/19 financial year
We have built on our work from the 2017-18 financial year (where systems to monitor, assess and report the risks of modern slavery in our supply chain and our own operations were formalised), and have been carrying out increased checks for the risks of modern slavery in our supply chain. We have also integrated the following into our due diligence processes and labour monitoring systems:
- Riverford’s Fair Labour Policy integrated into our induction process
- Communicating the Ethical Trading Initiative (ETI) Base Code to all suppliers
- Capacity building across our franchisee and supplier networks
- Modern slavery training and sector specific briefings for our Procurement Team
- Supplier visit reports
Our business and structure
Riverford Organic Farmers is an employee-owned company, growing, packing and delivering organic produce direct to customers’ doorsteps in England and Wales. 85% of our products are fresh fruit and veg straight from farms – mostly sourced in the UK, but we also work with organic farmers overseas.
Organic suppliers across the world
Policies and contractual terms
We have developed Riverford’s policies for effective due diligence and the assessment of modern slavery risks based on:
- The UN Universal Declaration of Human Rights
- The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work
- The Base Code of the Ethical Trading Initiative
Despite having a largely UK-based supply chain, we also source some products globally. With global sourcing activities come an increased risk of modern slavery in our supply chain. To mitigate this risk, we embed the principles of the above documents and our own stance on ethical food production into our sourcing principles and supplier approval process.
We make sure that our Whistleblowing Policy and Fair Labour Policy are both available to all Riverford co-owners as part of the induction process. The Whistleblowing Policy provides a safe channel of communication for co-owners to voice concerns about modern slavery or anything else relating to poor business or labour practices at Riverford that may be worrying them, and the Fair Labour Policy describes how co-owners at Riverford can expect to be treated.
Due diligence and risk assessment
Riverford is rare for a business of our size in that we deal directly with the vast majority of our suppliers, avoiding middlemen that disconnect the retailer from the producer. Having direct, long-lasting relationships with a network of small suppliers gives us greater confidence in their production practices and their treatment of staff. However, remaining vigilant against the risks of modern slavery is paramount.
To assess actual and potential risks of modern slavery in our supply chain, all suppliers are subject to a three-stage process used to identify any risks of modern slavery within their operations.
Desk-based due diligence research process into modern slavery risks
Modelled on processes in the Ethical Trading Initiative Base Code (an internationally recognised code of labour practice), our Procurement team researches country-specific risks, sectoral/product-specific risks, and regulatory, socioeconomic and political factors affecting the supplier’s country or region.
Supplier self-assessment questionnaire (SAQ)
Our Ethics and Environment SAQ (filled out annually by suppliers) includes questions on labour standards, and is used to assess modern slavery risk by identifying employment practices and working conditions.
Supplier visits: Modern Slavery Indicators checks
Also modelled on the Ethical Trading Initiative Base Code, our Modern Slavery Indicators Checklist is a suite of 11 indicators that we use to assess the risk of modern slavery when visiting a supplier.
The greatest risks in our supply chain are the growing and harvesting of crops. We are developing a programme of supplier visits to assess our suppliers’ operations.
In our own operations, we have identified the use of labour agencies as a risk: it means that we don’t have direct relationships with some employees. To prevent modern slavery, we work with licensed recruitment agencies, regularly audit the agencies we work with to ensure they are licensed by the Gangmasters and Labour Abuse Authority (GLAA), and talk to employees to establish an on-the-ground picture of working conditions.
If slavery is suspected in our supply chain or our operations, our Slavery Reporting Process will be used:
Monitoring and Key Performance Indicators (KPIs)
Our due diligence processes allow us to scope for country- and sector-specific risks, while a direct working relationship (where possible) with suppliers gives us greater visibility of our supply chain. However, modern slavery is not always obvious – people may go to great lengths to conceal this criminal activity. Therefore, we are working to increase supplier visit frequency.
We compile supplier visit reports from every visit we make to farms, in order to keep a record of labour conditions in our supply chain, and to see where improvements can or have been made over time. Reporting on generated risk factors in our supply chain is still in its infancy. However, using supplier visit reports and checks on labour conditions, compiled and carried out by our Procurement Team, has provided valuable insight into labour conditions in our supply chain and our own operations:
- There have been no actual or suspected instances of modern slavery found in our own operations or our supply chain.
- Visits to growers have shown that labour conditions are safe, and visited workforces are generally relaxed and happy. There are also growers providing above expected pay to agricultural workers in our supply chain.
- Whilst one food processor was shown to have no designated break area, their workforce are provided with ample breaks, and are happy with the flexible working hours that they are provided with. Flexible and part-time working options were available at several of our food processing suppliers, indicating a progressive structure. One supplier provides staff with access to communal veg gardens as part of their break/leisure time.
- Percentage of suppliers visited to check labour conditions 2018-19, categorised by UK suppliers, European suppliers, and suppliers outside of Europe:
- 46 % of UK suppliers
- 57 % of European suppliers
- 13 % of suppliers outside Europe
- Risk factor for suppliers, generated through the labour standards questions in our supplier principles questionnaire:
- Due to the number of suppliers and the complexity of developing our supplier risk assessment factors, assignment of risk factor is still in development. We expect this to be operational during the 2019-20 financial year.
- Number of suspected or actual cases of modern slavery reported in Riverford operations and our supply chain for the year: zero.
Due to the nature of our supply base (a great number of smaller suppliers and family farms) it is difficult for us to visit 100% of suppliers in a year. Our Key Performance Indicators (KPIs), below, show that while supplier visit coverage could benefit from an increase, the number of suspected or actual cases of modern slavery is at zero.
While it is easy to see a positive image of labour conditions in our supply chain, we are aware of the hidden nature of modern slavery issues. Therefore, we will continue to embed modern slavery indicator checks and visits into our procurement and supplier relationships.
Following the delivery of Modern Slavery Risk Awareness training to relevant co-owners at Riverford (key members of our Operations, Senior Management, People, Technical and Procurement teams), which introduces indicators of modern slavery, we have begun to provide sector-specific, detailed training to our Procurement Team. This includes specific indicators of modern slavery that should be scrutinised when visiting a supplier.
Planning for the future
The previous two financial years saw developments in modern slavery due diligence process and monitoring for us. We are committed to continual improvement of our management of modern slavery risks in our own operations and our supply chain, with the following actions planned for the 2019-20 financial year:
- Increased frequency of visits to suppliers by our Procurement Team
- Cementing our ‘Supplier Principles’ – which includes our policies on ethics and labour
This statement has been approved by the Riverford Board of Directors.
Rob Haward, Managing Director
GLAA, 2017. Modern slavery. [online] Available at: http://www.gla.gov.uk/who-we-are/modern-slavery/
ILO, 2017. Global Estimates of Modern Slavery. [online] ILO:Geneva. Available at: http://www.ilo.org/wcmsp5/groups/public/---dgreports/---dcomm/documents/publication/wcms_575479.pdf. Accessed on: 25.07.2018.
ETI, 2017. Base Code Guidance: Modern Slavery. [online]. ETI:London. Available at: https://www.ethicaltrade.org/resources/base-code-guidance-modern-slavery. Accessed on: 23.07.2018.
Global Slavery Index, 2018. Global Slavery Index. [online] Available at: https://www.globalslaveryindex.org/2018/data/maps/. Accessed on: 30.08.2018.
National Crime Agency, 2017. National Referral Mechanism Statistics Annual Report. Available at: http://www.nationalcrimeagency.gov.uk/publications/national-referral-mechanism-statistics/2017-nrm-statistics/884-nrm-annual-report-2017/file. Accessed on: 11/09/2018.
Unseen UK, 2018. Modern Slavery Facts and Figures [online]. Available at: http://www.nationalcrimeagency.gov.uk/publications/national-referral-mechanism-statistics/2017-nrm-statistics/884-nrm-annual-report-2017/file. Accessed on: 30/08/2019.
Department of Justice, 2018. 2018 UK Annual Report on Modern Slavery [online]. Available at: http://www.nationalcrimeagency.gov.uk/publications/national-referral-mechanism-statistics/2017-nrm-statistics/884-nrm-annual-report-2017/file. Accessed on: 30/08/2019.