Anti-Slavery Policy

Policy Statement

The DB Food Group commits to developing and adopting a proactive approach to prevent, respond to and remediate the risks of modern slavery, forced and debt-bonded labour, human trafficking and hidden exploitation within its workplaces.

Modern slavery is a broad term used to encompass offences that involve one person depriving another person of their liberty, in order to exploit them for personal or commercial gain.

Forced labour is all work or service that is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.

Debt-bonded labour is where a person’s labour is demanded as a means of repayment for a loan or service.

Human trafficking is the recruitment and transportation of persons by threat, force, coercion or other abuse of power or vulnerability to achieve the consent of a person having control over another person for the purpose of exploitation.

Hidden labour exploitation is action up to and including modern slavery which involves the exploitation of workers and job applicants by internal or external individuals without the sanction or explicit knowledge of the employer or labour provider.

Scope

This policy applies to all sites in The DB Food Group.

Responsibility

This policy will be reviewed and updated by the HR Department.

Policy Commitments

The DB Food Group shall take the following actions for good labour practices:

  1. Follow a full and fair recruitment process for employees joining the business, the HR Department check individual right to work documentation and proof of address as a measure to ensure employment is freely chosen.
  2. Employees have the right to terminate their employment in line with their contract or employment.
  3. The HR Department provides company inductions which give information on Modern Slavery and spotting the signs. It is the responsibility of all employees to be aware of the signs of slavery and escalate where they have concerns for someone’s safety.
  4. An annual report is run and reviewed by the Payroll department to ensure banking information is unique for all employees, and any duplicated banking information is fully investigated.
  5. Ensure Child Labour Laws are followed where applicable.
  6. Ensure all employees have access to our Equal Opportunities and Dignity at Work Policy which outlines our commitment to a work environment free of harassment and bullying, where everyone is treated with dignity and respect. Although we work towards all employees sharing commitment and putting it into practice, there is a grievance procedure in place for employees to raise concerns where they feel they have been unfairly treated, bullied, harassed or discriminated against.
  7. Ensure employees hours are in line with the Working Time Directive. Managers are responsible for ensuring their employees work within the Directive. The Payroll department is to monitor working hours processed for payment and escalate potential breaches of the Directive.
  8. All employees are provided with a Contract of Employment which outlines:
  • the employer’s name
  • the employee’s name
  • the start date (the day the employee starts work)
  • the date that ‘continuous employment’ (working for the same employer without a significant break) started for an employee
  • job title
  • the employer’s address
  • the places or addresses where the employee or worker will work
  • pay, including how often and when
  • working hours
  • holiday and holiday pay
  • any contractual benefits – these are benefits the employer must provide
  • the notice period either side must give when employment ends
  • how long the job is expected to last (if it’s temporary or fixed term)
  • any probation period, including its conditions and how long it is
  • if the employee will work abroad, and any terms that apply
  1. Use temporary workers, contractors and fixed term contracts only when necessary to meet business needs and will not be used to avoid the obligations to employees under labour or social security laws and regulations arising from the regular employment relationship.
  2. Ensure measures are in place for legal salary practices and these are maintained:
  • An annual review of all employee salaries to ensure they are in line with or above the National Minimum Wage.
  • No deductions are taken from employee wages without their express permission or if it is not an agreed contractual clause.
  • Salary information is given to employees in their Offer Documentation and Terms and Conditions of Employment.
  1. Provide safe and clean working conditions with the following:
  • An in-house Hygiene team which maintains cleanliness across our sites.
  • An Engineering department to ensure equipment and sites are maintained and in safe working order.
  • Our Group Head of Health and Safety monitors all aspects of employee’s physical and mental wellbeing including ensuring risk assessments are completed and reviewed, employees undertake relevant training and understand safe systems of work and follow these and PPE is provided where necessary. For further information, refer to the Health and Safety Policy.
  • The DB Foods Group sites have access to clean water and toilet facilities.

How to Spot the Signs of Slavery

There are a number of indicators of trafficking and forced labour. Not all of the indicators will apply in every case, and some may not be immediately apparent.  Victims may be reluctant to tell their story through fear of reprisal or not being believed, through a feeling of shame about letting themselves be treated in this way, or because they do not know their rights and the treatment they are entitled to receive.

There are no set number of signs that will indicate that a person is a victim of trafficking or subject to forced labour. One or a combination of factors could suggest a person is a potential victim, so each case should be considered on an individual basis.

Physical Appearance

Exploited applicants and workers may show signs of physical or psychological abuse and/or appear:

  • Malnourished
  • Dirty
  • Frightened, withdrawn and confused
  • They may have injuries that seem to be the result of an assault

Few or No Personal Effects

Exploited workers may have:

  • No money
  • No personal items e.g. purse, wallet, jewellery
  • With limited or no money to buy clothes, they may wear the same items all the time, or wear clothes that are unsuitable for work
  • They may also have little or no food

Isolation and Control

Exploited workers are rarely left to be on their own and may seem under the control and influence of others for example:

  • Others present their identification documents and speak for them at recruitment
  • Others try to book them onto shifts or speak on their behalf when answering calls whether they are available to work or not
  • One person speaks on behalf of a number of workers and the victims look to him for support or permission
  • Are taken to work and back e.g. a driver may drop them off and collect them

Reluctant to Seek Help

  • Exploited workers may be reluctant to seek help and may:
  • Avoid eye contact and appear frightened
  • Be afraid to talk and reject help when offered – this is often because they don’t know who to trust or fear retribution

Working conditions

Victims may:

  • Have no contract
  • Be unable to negotiate working conditions
  • Be unable to choose when or where they work
  • Be forced to work under certain conditions
  • Work excessively long hours over long periods
  • Not have any days off
  • Lack basic training or professional licenses

Accommodation:

Victims may:

  • Not know their home or work address
  • Not have been able to give their address to friends or relatives
  • Live in poor or substandard accommodation
  • Have no choice where they live or who they live with
  • Live in groups in the same place where they work and leave those places infrequently, if at all
  • Live in degrading, unsuitable places, such as agricultural or industrial buildings

Finances

Victims may:

  • Receive little or no payment
  • Have no access to their earnings
  • Be disciplined through punishment or fines
  • Be under the perception that they are bonded by debt
  • Have had the fees for their transport to the country of destination paid for by facilitators, whom they must payback by working or providing services in the destination
  • Be told that they can pay debts for transport or accommodation when they are found work
  • Be charged for services they don’t want or need
  • Be forced to open bank accounts
  • Have the same bank account as someone else
  • Be forced to sign documents to receive social security benefits, credit agreements or loans

DB Foods Group Supplier Policy

DB Foods Group operates a supplier policy and maintains a preferred supplier list.  We conduct due diligence on all suppliers before allowing them to become a preferred supplier.  This due diligence includes an online search to ensure that the particular Company has never been convicted of offences relating to modern slavery and on-site audits where appropriate which include a review of working conditions.  Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

  • They have taken steps to eradicate modern slavery within their business
  • They hold their own suppliers to account over modern slavery
  • (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
  • (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
  • We may terminate the contract at any time should any instances of modern slavery come to light

How to Report Signs of Slavery

Employees of the DB Foods Group are required to report any signs of slavery within the Company and the supply chain immediately to their manager which must then be escalated to a Director and the HR Business Partner.

Please refer to the Whistleblowing Procedure for further information.

If an employee knowingly identifies slavery and fails to report this in line with this policy, may result in disciplinary action being taken.