Modern Slavery & Human Trafficking

Introduction

Trewithen Dairy is a Cornish business. It produces milk, cream, butter and yoghurt for retail and foodservice, both for private label and Trewithen brand.

The company employs around 200 staff depending on the time of the year, servicing all areas of the business and with each sector and department headed up by a member of the Senior Management Team.

We are committed to reviewing and continuously improving our processes for identifying and assessing modern slavery and human trafficking for the purposes of labour exploitation risks within our own operations and supply chains. This statement has been published in accordance with the Modern Slavery Act 2015.

OUR POLICIES ON MODERN SLAVERY AND HUMAN TRAFFICKING

Trewithen Dairy’s reputation and continued growth rests with its people and the Company continues to put into place policies, practices and training to ensure that both itself and its supply chain adhere to best practice in all areas of employment, including the terms by which and conditions within individuals are employed.

The policy sets out the principles to which Trewithen Dairy aims to adhere, at all times. All employees, suppliers and sub-contractors shall be made aware of this policy and shall be expected to comply with the provisions of the policy or, for suppliers and subcontractors, to meet the same standard through their own policy.

We expect our suppliers and subcontractors to support the required processes fully and to encourage their own suppliers to also work to the same standards. To ensure adherence to and continual improvement against the policy, Trewithen Dairy reserves the right to assess our suppliers’ commitment to the policy whenever deemed appropriate.

The provisions of the policy detailed below constitute minimum and not maximum standards, and the policy should not be used to prevent others from exceeding these standards. The policy, and any application of the provisions, must be interpreted to comply with national and other applicable law. In the event that the policy exceeds the protections offered under the national or other applicable law, the provisions of the policy shall apply.

Within the Trewithen Dairy company, the responsibility for communicating and enforcing the policy ultimately lies with the Board, supported by the Senior Management Team. Each member of the latter will be responsible for ensuring compliance within his or her own area of the business through appropriate training and regular communication, by employees or any suppliers or subcontractors engaged in that area of the business.

Employment:

All employees shall be free to choose their employment and shall not be forced to work against their will.
Employees shall not be required to pay to work and must provide proof of eligibility to work.
No original identity papers shall be retained by the employer.
All employees shall be free to leave their employment after reasonable and/or contractual notice.
Recruitment/Agency Workers:

The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
Working conditions and hours:

A safe and hygienic working environment shall be provided and adequate steps shall be taken to prevent accidents and injury to health including the provision of regular health and safety training and appropriate personal protective equipment.
Records shall be kept of accidents, injuries and known exposure to health and safety risks at work in accordance with relevant legislation.
Accommodation, where provided, shall be clean, safe, and meet the basic needs of employees.
Working hours shall comply with all national laws and any overtime will be voluntary wherever possible.
Employees shall be given reasonable breaks while working and sufficient rest periods between shifts.
Pay and benefits:

Pay and benefits shall meet, at a minimum, national legal standards.
All employees shall be provided with written and understandable information about their employment conditions including pay within the required legal time frame and will receive a detailed pay slip for each relevant pay period.
Child Labour:

No child under the age of 16 shall be employed in a role that is likely to be hazardous or to interfere with the child’s or young person’s education or to be harmful to their health or physical, mental, spiritual, moral or social development.
Equality and Respect:

All candidates, employees, subcontractors and agency workers will be treated equally and with respect, irrespective of age, gender, sexual orientation, religion, social background, disability, race, union membership or political affiliation.
The company will deal swiftly and appropriately with any incident which serves to discriminate, harass or intimidate any candidate, employee, subcontractor or agency worker.
Freedom of association:

Employees shall have the right to belong to, or join, a trade union of their own choosing.
No employee shall be dismissed solely because of their affiliation to a trade union.
Employee representatives shall not be discriminated against and shall have access to carry out their representative functions in the workplace.

Reporting concerns:

Everyone is encouraged to report suspected wrongdoing or poor practice as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate and that their confidentiality will be respected.
Concerns should be raised directly to line managers, Human Resources, or to another senior member of management, or to a director.
Trewithen Dairy also has a Whistle Blowing policy which includes details of an anonymous reporting system for any employee to report concerns.

Non-Compliance:

Employees who fail to comply with the provisions of the Code may be subject to disciplinary action which could result in their immediate suspension or the termination of their employment. Failure to comply by agency workers will result in their actions being immediately reported to the agency and a request that they are replaced by another worker.
In relation to our suppliers and sub- contractors, we believe that transparency is vital to a successful business relationship. We are committed to building long-term relationships with suppliers and value open and honest communication with them. In the event of non-compliance, we expect our suppliers to be committed and engaged in remedying the issue within a time-frame set out in a corrective action plan to be agreed with the supplier. Trewithen Dairy reserves the right to terminate any agreements in line with any contractual obligations should a supplier decide that compliance with this Code is impossible or where a supplier shows repeated disregard for the provisions of this Code.

REVIEW

Following its initial adoption, this policy will be reviewed by the company’s Board of Directors on a regular basis (at least annually) and may be amended from time to time.