2019 Modern Slavery and Human Trafficking Statement
This is the fourth LDH Modern Slavery statement prepared in accordance with the Modern Slavery Act 2015. In this statement we describe the steps taken by LDH during the financial year ending 31st December 2019 to prevent, identify, and remediate modern slavery within our business and supply chains.
In line with the United Nations Guiding Principles on Business & Human Rights (2011), we are committed to upholding the principles set out in the UN Declaration on Human Rights, and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work (1998). Pursuant to these principles, LDH (La Doria) Ltd (LDH) has developed systems and controls to identify and address the risk of modern slavery within our business and supply chains.
Our Business, Structure, and Supply Chains
LDH is an importer and distributer of ambient grocery food products, packed seasonally and throughout the year to UK retail, foodservice and manufacturing sectors. The company ownership encompasses a small number of shareholders; Gruppo La Doria S.p.A, Thai Union Group PCL, Pastificio Di Martino Gaetano & Fili S.p.A, and LDH company directors. As set out below, LDH has procedures in place to support the verification and monitoring of its suppliers to ensure that suppliers meet the standards that LDH expects.
The Responsible Sourcing Manager drives the development and implementation of all activities related to responsible sourcing and human rights, including modern slavery and human trafficking in our supply chains. The Technical Director, who sits on the Board of Directors, has oversight and close involvement with the responsible sourcing programme and informs all company directors of progress and issues on a quarterly basis. There is close contact on a regular basis with the Procurement team, and internal escalation mechanisms to Director and CEO level, which have been effectively applied in the last year in response to human rights violations detected at a manufacturing site.
The company’s focus is on private-label ranges, predominantly ambient pasta, vegetables, pulses, fruits, fish, chocolate, cooking sauces, condiments, and meal kits. Due to the nature of products carried the majority are sourced from outside the UK, with global sourcing of ingredients and commodities. Given that no country is fully exempt from modern slavery and human trafficking risks, we acknowledge that our supply chains and manufacturers need to be aware of and mitigate these risks. As their UK buyer, LDH has established due diligence and communication channels with suppliers for this end, which includes communicating customer human rights and ethical trade policies. We have developed strong, long-term relationships with our suppliers globally and have broadened our supply chain mapping process to cover an increased range of products back to source.
Policies in relation to slavery and human trafficking
LDH has a whistleblowing policy which sets out the process for our employees to raise any concerns that they may have in relation to compliance with our legal obligations, including in relation to modern slavery and human trafficking. Our whistleblowing policy ensures that there is adequate protection for employees who raise grievances or make protected disclosures.
In 2018, we began developing our responsible sourcing strategy. This included the creation and implementation of LDH’s responsible sourcing risk assessment framework. As a next step, by the end of 2020 we plan to enhance our due diligence process through the creation of a company-wide Human Rights Policy and a Supplier Code of Conduct, covering modern slavery and human trafficking. In order to do this, LDH will seek input from stakeholders across the business, and consult with external human rights experts.
Due Diligence and Risk Assessments
We recognise that modern slavery risks exist in our supply chains, and we have therefore taken practical steps to identify and prioritise addressing these risks.
- Information gathering
LDH has been a member of Sedex (Supplier Ethical Data Exchange) since 2007 and require production sites to upload information through the Self-Assessment Questionnaire (SAQ). Updated on an annual basis, this is the first step in helping us understand at individual site level the working conditions, recruitment, labour management, policies, and workforce demographics. In addition, we are in the process of mapping all supply chains back to source with in-depth details regarding farm workers and vessel crew.
SMETA (Sedex Members Ethical Trade Audit) audits are conducted at sites by third party auditors on a risk basis as determined by customer policy. Audits provide verified visibility of working conditions and insight into worker feedback. The SMETA audit reports on Sedex provide a record of compliance against the Ethical Trading Initiative’s (ETI) Base Code. Compliance to the ETI Base Code is widely regarded as the most rigorous benchmark at factory level of best practice for working conditions, verifying labour agencies, recruitment fees, and grievance channels. In addition, an increasing number of our supply chains are implementing Global G.A.P GRASP at farm level, assessing the risks associated with child labour and forced labour.
- Risk Assessments
All tier 1 suppliers have been assessed against LDH’s responsible sourcing risk assessment framework. Information sources include the Food Network for Ethical Trade (FNET) risk tool, SMETA audit reports, Sedex SAQ, and technical supplier visits. The criteria are individually scored and include audit performance, recruitment method, worker representation and implemented policies. The outcome of this assessment is an understanding of the modern slavery and human rights risks by supplier, and each supplier is given a high, medium or low risk rating. This risk rating helps to prioritise and inform supplier action plans, which are developed in dialogue with suppliers. Having completed prioritised supply chain assessments back to source, our aim is to continue this exercise for a broader scope of high-risk products by the end of 2020.
Audits to assess compliance against the ETI Base Code and assessments such as GRASP are helpful in determining whether human rights risks and violations are present. But they are only one tool within the evolving LDH toolkit against modern slavery. Open and transparent relationships with our suppliers are also essential in order to know, understand, and improve working conditions in our supply chains. Our assessment process for supplier selection is conducted with a view to forming long-term partnerships with frequent communication, both remotely and on-site. We carry out these assessments using a range of technical and ethical performance indicators and targets. Our shareholders supply 70% of our turnover, with whom we have regular discussions on labour improvement projects and horizon scanning.
Performance Indicators and Targets
To date, LDH has primarily used Sedex to understand and monitor supplier ethical progress and performance through SAQs and SMETA audits. The latter give a full understanding of whether the supplier is compliant with national labour legislation, and the ETI Base Code. Building on that, we deploy our responsible sourcing assessment framework to evaluate supplier performance against known risks, indicators, and criteria.
The results of tier 1 supplier assessments for 2019 are seen below. Compared to 2018, there are fewer high-risk sites and more medium-risk and low-risk sites. We recognise it is important to work with all of our suppliers, but we have prioritised high risk (red) for action plans, before moving onto medium risk (amber). The improvements seen as a result of the 2018 action plans – with some high-risk sites moving into the medium risk and even into the low-risk category – indicate the process is effective. Sites should continue to improve as we continue to have detailed and targeted conversations with suppliers on forced labour risks and solutions.
Our targets for the next three years focus on moving all high and medium risk suppliers and supply chains to medium or low risk. We plan to achieve this progress through the action plans and continued close dialogue with, and monitoring of, supplier performance. In practical terms, we recognise the importance for workers in our supply chains to raise grievances, and this is actively monitored through our risk assessment process. We are working with suppliers to improve these feedback and dialogue mechanisms.
Suppliers that fail to improve in accordance with their action plan are required to take immediate corrective action. LDH provides increased support and assistance where necessary to help build capacity and capability. Employees who violate LDH’s policies are likely to be subject to disciplinary action up to, and including, termination of employment.
Training and Capacity Building
We are committed to raising awareness about human rights risks, including modern slavery, across our business and our supply chains. A training programme for relevant staff has been developed to help them to understand and identify modern slavery risks. This programme is aimed at increasing capabilities for detecting modern slavery during technical supplier audits, which complements visibility provided by SMETA audits. In addition, modern slavery training was conducted at Director level in 2018, with the participation of 80% of relevant staff.
Our staff training demonstrates a pro-active approach to addressing these complex ethical issues. To support this further we are evolving and strengthening our approach in order to provide a greater understanding of the issues surrounding modern slavery from the source of the product and throughout the supply chain. This will enable us to advance the development of skills, processes and resources within our organisation. For example, our Technical Manager has attended Stronger Together training on Tackling Modern Slavery in Global Supply Chains with further training and capacity building being planned for relevant staff across LDH.
Collaboration and Engagement
LDH recognises that there are entrenched, systemic socio-economic realities that negatively influence worker and stakeholder rights. We also acknowledge that addressing the source of modern slavery and human trafficking is often beyond the leverage of any single buyer or supplier. Therefore, LDH are members of FNET and the ETI Italian Agriculture working group. Through co-operation and the sharing of best practice we can identify and collectively overcome modern slavery in supply chains. LDH actively participate in the FNET Worker Representation Seafish Ethics Common Language Group.
We are aware that our shareholders have engaged with NGOs during 2019, in particular La Doria participated in Oxfam’s Human Rights Impact Assessment in Italian Processed Tomato Chains, and Thai Union has worked with Impactt to better understand the implementation and effectiveness of their Ethical Recruitment Policy.
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes LDH (La Doria) Ltd’s slavery and human trafficking statement for the financial year ending 31 December 2019.
This statement has been considered and approved by LDH (La Doria) Ltd on 30th June 2020.
Signed by Barry Fine, CEO
Original signed document held at LDH House at the address below: