Group Guiding Principles: Health and Safety

Camellia Plc ("Camellia") is the ultimate holding company of a group of companies incorporated in various jurisdictions (the "Group"). Within the Group, Camellia has indirect interests in several entities which have responsibility for managing primarily agricultural operations, including responsibility for managing the assets and workers associated with those operations (the "Operating Companies"). The Operating Companies are predominantly based in Bangladesh, Brazil, India, Kenya, Malawi, South Africa, Tanzania and the UK. The majority of the Group’s turnover is derived from the Operating Companies' work in the agricultural sector through the growing of tea, avocado, macadamia, rubber, blueberries, arable crops, forestry and livestock.

Governance and Strategy

The Operating Companies possess the specialist knowledge, experience and expertise in relation to their own operations. It is the Operating Companies which best understand their own agricultural crops and livestock, the local geographical and climatic conditions, the local legal and regulatory framework with which they must comply and the local socio-political context in which they operate.  Camellia is not an Operating Company and does not claim to possess such specialist local knowledge, experience or expertise. Having regard to this reality, Camellia's business philosophy is based on an approach which promotes a high degree of operational autonomy enjoyed by the Operating Companies. 

Camellia expects the Operating Companies to adopt, comply with, and promote appropriately high standards in respect of their operations. Following engagement with the Operating Companies as to their existing practices and procedures and in line with Camellia’s understanding of international guidelines, Camellia has formulated a series of 'Group Guiding Principles' ("GGPs") which outline the principles and commitments that Camellia expects the Operating Companies to adopt and adhere to in key areas such as human rights, modern slavery, financial crime, environment, quality, certification and traceability, employee wellbeing, health and safety and whistleblowing. Importantly, the GGPs set out the principles which Camellia expects Operating Companies to comply with at a minimum, subject to any local laws which would make it unlawful for the Operating Companies to do so, in which case Camellia expects the Operating Companies to respect and adhere to these principles to the greatest extent legally permissible.  For the avoidance of doubt, nothing in the GGPs prevents an Operating Company from adopting a higher standard, whether in accordance with the requirements of local laws or otherwise having regard to the particular issues arising from their own operations.

Ultimately, the individual Operating Companies have the local expertise and understanding which means they are best placed to identify relevant needs and apply the processes and practices that enable them to operate legally, responsibly and ethically over the long term, and to embed the expectations set out in the GGPs into their own culture, strategy and daily practices. For the same reason, the Operating Companies are also best placed to implement and monitor compliance with the policies and practices that they put in place. This promotes the continuity, development and progressive growth of those individual enterprises in an ethical and responsible way that is relevant to, and supportive of, their own local jurisdictions and cultures.  

The Principles

Camellia aims for the Operating Companies to have an improved health and safety performance year on year. Camellia has accordingly formulated these Health and Safety GGPs which set out Camellia's expectation that the Operating Companies should commit to providing a safe and healthy workplace to protect all their employees, contractors, visitors and the public from foreseeable workplace hazards. 

Operating Companies are expected to adhere to the following general commitments below (where relevant) when considering the health and safety working practices specific to their own business operations, in addition to other actions and commitments that they consider necessary:

• Understanding and complying with applicable health and safety legislation and following principles of recognised good practice in the local environments in which they operate.
• Developing and implementing health and safety risk assessments to minimise and effectively manage hazards in line with applicable legal standards.
• Providing appropriate health and safety resources, supervision and training to employees and contractors of the Operating Company, and keeping those stakeholders informed where appropriate on matters affecting their health, safety and well-being, in line with local legal requirements.
• Documenting accidents/safety failures/risks as they occur, undertaking 'lessons learned' and implementing changes to policies.
• Fostering a culture which encourages accountability within each Operating Company in respect of health and safety matters.
• Collaborating on and sharing good practice within their business and industry including, where practicable, with suppliers on the health and safety procedures and policies of their operations.
• Developing, adopting, implementing, monitoring and updating policies and procedures to ensure compliance with relevant health and safety laws and ensuring that they adequately reflect the specific risks faced by the relevant Operating Company's business and operations. 

Each Operating Company is responsible for, within the above frame of reference, assessing, managing, and addressing the unique health and safety risks as they arise in their own operations. This includes, but is not limited to, implementing adequate policies and procedures, conducting appropriate due diligence, acting on any findings and integrating the responses to these due diligence processes into their own policies and internal systems. 

Operating Companies are expected to undertake and continue training of their relevant directors and employees and, where appropriate, suppliers to raise awareness of health and safety issues and to assist in identifying risks in their given businesses and supply chains.   
Camellia expects that each Operating Company will undertake a regular, risk-based review of their compliance with their policies and procedures including, where necessary, using external expertise.

Any issues identified by any employee, officer, consultant, contractor, volunteer, intern, casual worker and agency worker with respect to these GGPs can and should be immediately notified to the appropriate point of contact at the relevant Operating Company and, where appropriate, in accordance with its whistleblowing and/or speak up policies.