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Modern Slavery Act 2015


Statement of compliance for the year to 31 December 2018

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 and investments. The Group has operations in Bangladesh, Brazil, Germany, India, Kenya, Malawi, South Africa, 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, wine grapes, arable crops, forestry and the raising of cattle. We consider that the agricultural businesses have the greatest exposure to risk of modern slavery and human trafficking.

The Group is fundamentally connected to the welfare of its communities and the environments in which it operates. As part of the Board’s long-standing commitment to managing its businesses in accordance with high legal and ethical standards, slavery, human trafficking or forced labour in any form is prohibited in its operations. We recognise that modern slavery exists in many different forms and can be difficult to detect, particularly in the supply chain.

The agricultural division has substantial operations in India, Bangladesh, Brazil, Kenya, Malawi, South Africa and the USA.  As is common in the sector, it is necessary to employ a large number of seasonal employees to harvest, process and transport crops at peak times. We pay fair wages, benefits and allowances in accordance with local legislation and Trade Union agreements and have received and maintain certifications with challenging ethical standards from inter alia Fairtrade, Ethical Tea Partnership, UTZ, WIETA, SMETA-ETI and Rainforest Alliance which require detailed audits of employment practices in the Group and key suppliers.

The Group has undertaken and completed training of its employees in the agricultural operations to raise awareness of the Act and assist managers with identifying risks in its operations and the supply chain. Changes have been made to auditing standards and our policy has been circulated to tier one suppliers and some tier two suppliers. To date, no concerns have been identified.


In 2017, our operation in Malawi was recognized by the Government of Malawi for its comprehensive control mechanisms to ensure that there is no child labour within its jurisdiction. In 2018, our tea operation in Malawi was recognised by the Tea Association of Canada and Tea Association of USA for its comprehensive anti-slavery and anti-human trafficking programme. On the same platform, our tea operation in Kenya was recognized for its smallholder and outgrower empowerment programme which promotes the same tenets as the letter and spirit of the Act.

Smallholder Empowerment Programme

In 2018, our Africa operations rolled out The Sexual Harassment, Awareness, Reporting and Prevention (SHARP) Programme. SHARP was established to enforce our zero-tolerance framework. 

SHARP Programme


The majority of the tier one suppliers for our agricultural operations are outgrowers and smallholders. The Group purchases product from these growers at a market related price which it then processes, packs and sells via its own channels to market. We have set up programmes to support and nurture our outgrowers and smallholders to help them invest in their farms and crops and consistently grow high quality products that will command higher market prices. All product purchased is paid for in a timely manner. We also provide advice to these farmers on how to improve yields and adopt sustainable cultivation practices to help ensure a consistent and sustainable source of income. These efforts have been beneficial both to them and the Group over recent years through achieving increased volumes and quality. We have undertaken training within our outgrower and smallholder groups on the provisions of the Act and will continue this process. Some of the tea smallholders are Fairtrade and Rainforest Alliance certified.

Where applicable, risk assessments on the other major tier one and two suppliers to the agricultural operations will continue in 2019.


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 has its roots firmly embedded in 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.

Whilst the Group cannot guarantee that our supply chain is completely free of slavery or forced labour, we believe that the steps being taken will give greater visibility of the employment practices of the supply chain network which in turn will allow us to ensure compliance with the Act.


A risk assessment of the key tier two suppliers will be expanded and completed. In addition, further training of the smallholders and outgrowers will continue.

This statement was approved by the Board of Camellia Plc on 20 December 2018.


Tom Franks
Chief Executive

2019 ESG Report