Modern Slavery Act 2015
Statement of compliance for the year to 31 December 2016
This statement is made pursuant to section 54, Part 6 of the Modern Slavery Act 2015 (“the Act”) and sets out the steps that Camellia Plc (“the Company”) has taken to ensure that modern slavery and human trafficking is not taking place either within the wider group or in the supply chains of our businesses.
The Company is the ultimate holding company of a diverse group (“the Group”) with interests in agriculture, engineering, food service, banking and financial services and investments. The Group has operations in Bangladesh, Brazil, Germany, Hungary, India, Kenya, Malawi, the Netherlands, South Africa, Switzerland, the USA and the UK. The majority of the Group’s turnover is derived from its businesses in the agricultural sector through the growing of tea, avocado, edible nuts, citrus, rubber, pineapple, wine grapes, arable crops, forestry and the raising of cattle.
The agricultural businesses of the Group have substantial operations in India, Bangladesh, Brazil, Kenya, Malawi, South Africa and the USA. It is necessary to use a large number of seasonal labourers to harvest and process crops at peak times. The Group does not permit slavery or forced labour on its operations. We pay fair wages, benefits and allowances in accordance with local legislation and Trade Union agreements and has received certifications from Fairtrade, the Ethical Tea Partnership and the Rainforest Alliance which require an audit of the Group’s employment practices as part of maintaining the accreditations. The Group has also started a training programme for its employees in high risk regions to raise awareness of the new policy and assist managers with identifying risks in the supply chain.
Supply Chain Risks
The Board has initially decided to focus its efforts on assessing the potential use of slavery or forced labour in the tier one supply chain in the agricultural division for the purposes of this statement.
The majority of the tier one suppliers for our agricultural operations are outgrowers. The Group purchases product from these outgrowers at a fair price which it processes, packs and then sells via its own channels to market. The outgrowers are located in countries where the sale of excess crops is an important source of income for the local community. We have set up programmes to support and nurture our outgrowers to help them invest in their farms and consistently produce quality products that will command higher prices. All product purchased is paid for in a timely manner. We also provide advice to outgrowers on how to improve yields and adopt sustainable cultivation practices to help ensure a consistent source of income. These efforts have been beneficial both to the outgrowers and the Group over recent years by increasing volumes and quality. In conjunction with monitoring our own operations, we also have begun the process of assessing our outgrowers to ensure compliance with the requirements of the Act.
Supply Chain Standards
The ethos of the Group is very clear whereby the directors consider themselves as custodians of the Group’s assets and businesses which should be grown and nurtured in a sustainable way with respect for human rights, the environment and the wider communities in which the Group operates. Our relationship with our suppliers is a key part of this ethos. Respecting human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility. However, as customers we play an active role in supplier development and have adopted policies to communicate our expectations.
During the year, the Group’s agricultural operations started a programme to review its supply chain network and has updated a number of its policies relating to its tier one suppliers and employees to ensure compliance with the requirements of the Act. We have also started a training programme for our employees in Africa and Brazil which will be expanded over the next year to the rest of the Group, in particular to India and Bangladesh.
Whilst the Group cannot at this point ensure that our supply chain is completely free of slavery or forced labour, it hopes that the steps that are being taken will give greater visibility of the working and employment practices of the supply chain network.
The auditing of the supply chain and the employee training programme will be expanded to cover more of the Group’s operations over the next year. Further work will also be undertaken in the agricultural operations on training and review of other tier one suppliers. In addition, a risk assessment of the key tier two suppliers will be undertaken.
This statement was approved by the Board of Camellia Plc on 15 December 2016.