Modern Slavery Act Statement

Winterwood Farms Limited Modern Slavery & Human Trafficking Statement for Financial Year 2020/21

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that Winterwood Farms Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Winterwood Farms Limited has a zero-tolerance approach to any form of modern slavery which is shared on our website. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our business and supply chain

Winterwood Farms Limited produce a wide range of fruit from our farms in the United Kingdom, France, Poland and South Africa, with nearly 2000 hectares combined. Our farms allow us to be the largest growers of Blueberries in Europe and Southern Africa.

Alongside our farming operations, we also pack fruits from around the world at our packhouse in the UK. These fruits are mostly marketed to various multiple retailers and supermarkets in the UK.

We purchase all our fruit from the farms on which they are grown, from our own farms or through reputable marketing agents. We have very close, successful and long-term relationships with all our suppliers.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

  1. Ethical Trading Policy: The company is committed to ethical trading. In addition, a program of external ethical auditing is in place including publishing the results of third-party audits on SEDEX (Supplier Ethical Data Exchange) website.
  2. Worker Welfare Policy: The company has a duty of care to all its employees. The company conducts an extensive induction programme before employees commence work which covers health and safety, job descriptions, pay and training.
  3. Bribery and Corruption Policy: The Company prohibits bribery or corruption in any form whether direct or indirect.
  4. Human Rights Policy: The company has human rights policy covering employment, harassment, discrimination, accommodation, harassment in accommodation, violation of the human rights policy and consequences.
  5. Confidential Whistleblowing Policy: The company has a confidential whistleblowing policy designed to make disclosures without fear of retribution.
  6. Equality, Diversity & Inclusion Policy: The company has a policy not to discriminate against people and provides equal opportunities to all.
  7. Forced Labour Policy: The company has a policy against all forms of forced labour which covers prison labour, bonded labour, coercion and child labour.
  8. Recruitment Policy: The recruitment policy aims to define the processes by which the company recruits and selects its employees.
  9. Remediation and Grievance Policy: The company has a policy on the reporting and remediation of negative impacts on human rights caused by its operation and supply chain.

Due diligence

Employees at Winterwood Farms Limited’s own farm and packhouse in the United Kingdom are employed directly by the company and are given a written contract of employment. If agencies are required in the future, we would require the agencies to be registered and certified with the GLAA and have a demonstrable commitment to mitigating the risks of modern slavery.

Winterwood Farms Limited recognise there is scope in our supply chain for slavery and human trafficking to occur. Winterwood Farms Limited operates a supplier approval procedure and maintains a preferred supplier list.

We conduct due diligence on all potential suppliers before allowing them to become a supplier. The company requires all fruit suppliers to register on SEDEX (or with SIZA for South Africa) and complete the self-assessment questionnaire (SAQ). The company assess compliance to national and international standards, through second party auditing and third-party auditing to SMETA protocol. Suppliers are required to operate to the Ethical Trading Initiative (ETI) principles which the company offers support where needed.

Training and awareness

Key members of staff have attended the Stronger2gether workshop to understand the signs of modern slavery and what to do if they suspect that it is taking place within our business or supply chain. Staff that conduct inductions and interviews have completed Stronger2gether trafficking and modern slavery e-training course. During induction new staff are made aware of modern slavery using resources provided by Stronger2gether. A modern slavery questionnaire is completed during induction 1 on 1 with the new employee in the employees own language. The modern slavery questionnaire is conducted by our trained inductors who are trained to spot signs of modern slavery. Since July 2020, 1 new staff member has completed the Stronger2gether e-training course. We currently have a total of 15 staff who have attended Stronger2gether training. For the forthcoming year Winterwood Farms will increase the number of staff who attend Stronger2gether training.

Awareness will be raised through posters and visual prompts in our employee areas.

Board approval for this statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the company’s slavery and human trafficking statement for the financial year ending 30/04/21. This statement has been approved by the board of directors.

Name: Stephen Taylor (Managing Director)

Date: 24/06/21

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