Anti-Modern Slavery Policy

ANTI-MODERN SLAVERY POLICY

 

William Croxson & Son, Limited (trading as Croxsons) understands that people underpin our business and have driven its success since its formation in 1872. In this context, we are committed to taking action to minimise the risk of modern slavery taking place within our business and through out our supply chain, and to encourage decent working conditions amongst workers within our field of influence.

We know that ethics have played an important part in our history, and we will continue to ensure that our business and business practices are underpinned with strong ethics. This includes but isn’t restricted, to how we trade with our business partners, suppliers and customers. We include the Ethical Trading Initiative ‘ETI’ Base Code as part of our strategy.

We are conscious that our global supply chain extends into some countries that pose higher levels of risk in relation to modern slavery. As such, we strive to only work with suppliers, contractors and agencies (‘Suppliers’) that we are satisfied apply the principles set out in the ETI. We also encourage our Suppliers to cascade these principles amongst their own sub-suppliers.

 

Scope of the Policy

 

This document sets out the policy of Croxsons towards modern slavery in its business and supply chain, as well as the policy of Croxsons towards our own fantastic team.

The term ‘modern slavery’ includes slavery, servitude, forced or compulsory labour, and human trafficking based on the definitions provided in Annex 1 of the Statutory Guidance relating to Section 54 of the United Kingdom’s Modern Slavery Act 2015 (‘Modern Slavery Act’).

 

What We Commit To

 

  • Excluding modern slavery within our business, primarily through our ongoing compliance with national law and application of responsible human resource processes relating to, for example: employee documentation; employment eligibility checks; employee exit and notice periods; freedom of association; and working hours. In the United Kingdom, we will only use employment agencies licensed by the Gangmasters Licensing Authority.
  • Not doing business with any Suppliers (or other business partners) that knowingly benefit from modern slavery – whether directly or indirectly. If a Supplier is found to be knowingly, cynically and persistently benefiting from modern slavery, we will terminate the relationship. We will require a Supplier to rectify the situation if a Supplier is found to be unknowingly benefiting from modern slavery, or where in good-faith Suppliers self-report newly discovered cases of modern slavery. Where Suppliers are unwilling or lack capacity to prevent the repetition of violations, we will consider terminating the relationship.
  • Carrying out due diligence of new suppliers to understand their commitment to excluding modern slavery from their businesses. To this end, we will:
    – Require all new suppliers to provide information regarding responsible recruitment practices (including their use of labour agencies) and working conditions within their operations. This can be provided directly to Rowse Honey Ltd or through collective industry data sharing initiatives.
    – Identify new Suppliers who we believe may pose higher levels of risk of modern slavery. We will also explore the future application of ethical auditing to high-risk new suppliers.
    The outcomes of this process will inform whether we decide to engage with new Suppliers.
  • Enhancing product traceability and the mapping of our extended supply chain. This includes engagement with our Suppliers to understand the ultimate source of our products and their own sub-suppliers (where this is not already known). Our efforts will be carried out on an ongoing basis and are subject to any relevant contractual and/or legal restrictions.
  • Better understanding the modern slavery risks posed by our supply chain through the application of periodic risk assessments. We will also explore: (a) how we might encourage high risk suppliers to apply appropriate risk mitigation measures in future; and (b) the potential avoidance of new contracts with high risk suppliers who prove unwilling orunable to apply such measures.
  • Facilitating the reporting of actual or suspected cases of modern slavery in our business or supply chain. We will do so by:
    – Providing our employees and workers with access to a confidential internal whistleblowing procedure and independent hotline, in addition to a formal human resources grievance mechanism. All employees and workers raising actual or suspected cases through these means will be protected from retaliation.
    – Publicising the United Kingdom’s 24-hour Modern Slavery Helpline within our Business. We will also encourage Suppliers to publicise this helpline in the UK (or equivalent helplines within their own countries of operation where available).
    – Requiring new Suppliers to report on whether they provide their employees and workers with access to grievance mechanisms equivalent to those set out above.
  • Communicating the commitments set out in this Policy within our business and amongst our Suppliers.

 

What This Looks Like Practically for Croxsons

 

We do not ask for or require:

  • Employees to incur debt, or pay for, recruitment fees.
  • Employees to make a financial deposit as a condition for working for us.
  • Employees to make a financial guarantee to secure employment with us.
  • Employees to surrender original copies of their identification documents.

We confirm that:

  • All employees receive a wage above the national legal standards.
  • We pay employees for a maximum of 30 days, and we make payment in full (other than legally allowed deductions) no later than 30 days from the beginning of the wage period.
  • All employees are able to end their employment with Croxsons, without excessive notice periods, or inappropriate fines for termination.
  • All employees are able to travel freely.
  • All employees are 16 or older, and the age of all our team has been verified.
  • All employees have a minimum of 2 scheduled rest days per 7 calendar days.
  • Working hours of all our team do not exceed 60 hours per week, with no more than 12 hours of voluntary overtime within that limit. Where working hours are flexible, or where overtime is required, this is documented.
  • All of our team have their right to work in the UK checked by Croxsons.
  • We comply with all local legislation with regard to labour laws and worker leave.
  • We treat all employees with dignity, respect and we support equal opportunities across the company.

 

How We Implement the Policy

 

This Policy has been approved by the CEO. Responsibility for the implementation of this Policy is shared:

  • The Commercial Director is responsible for implementation within our own business.
  • The Commercial Manager is responsible for implementation within our supply chain Implementation of this policy will be supported by:
    – Guidance (where necessary) for relevant internal stakeholders
    – Our Ethical Framework Pack for suppliers as part of our QMS. This will include – Periodical modern slavery risk assessments, new supplier questionnaire, Sedex membership guidelines, ETI Code of Conduct and supplier compliance form
    – The recording and monitoring of Supplier information and risk assessment results– as well as cases of suspected and/or actual cases of modern slavery raised by internal and external stakeholders
    – Internal and external reporting on our performance – including through the preparation of Modern Slavery statements as required under the Modern Slavery Act

In future, we will also explore how we can support the implementation of this policy through supplier auditing against the principles contained in our Ethical Trading Framework.

The Policy will be reviewed by the Chief Executive on a regular basis and may be amended from time to time.

Signed and authorised by:

Chief Executive Officer

Tim Croxson

Date: 03/01/2024