Modern Slavery and Ethical Trading Statement 2022
Modern slavery is a global problem now affecting every economy, industry and sector. Aimia Foods Limited (“Aimia”) recognise that modern slavery is an indefensible violation of an individual’s human rights, and is committed to preventing slavery and human trafficking in all of its activities. We require the same commitment from every supplier that we work with.
Aimia is committed to preventing slavery and human trafficking in its corporate activities, to ensuring as far as we are able that our supply chains are free from slavery and human trafficking and that we trade ethically with our supply chain partners.
This statement relates to actions and activities during the calendar/financial year 2022, and is published in accordance with Section 54 of the Modern Slavery Act 2015.
2. Organisational Structure and Supply Chains
Aimia operates in the UK and has 3 sites in close proximity to one another in the UK.
o 2 sites are manufacturing and 1 site is logistics.
• Aimia’s large manufacturing footprint, broad distribution network, substantial research and development capability and high-level of quality and customer service enables us to offer our customers a strong value-added proposition of low cost, high quality products and services.
• Aimia produces multiple beverages in a variety of packaging formats and sizes, including juice-based products, hot chocolate, coffee, malt drinks, creamers and whiteners, cereals and others. This means that some of the areas in which we operate are at higher risk of modern slavery, for example the sourcing of fruit juices in areas such as China, the sourcing of coffee in India, Vietnam and West Africa, and the sourcing of cocoa in areas such as the Ivory Coast and Ghana, and all other materials sourced from geographic regions identified as areas of risk.
Aimia have a dedicated team for slavery and human trafficking risks, consisting of relevant leaders of the Human Resources, Technical, Purchasing and Operations functions, as below:
- Head of HR (David Whittingham)
- Technical Director (Alex Wright)
- Head of Purchasing (Graham Hill)
- Operations Director (Mat Austin)
This team are responsible for the implementation, development and ongoing maintenance of Aimia’s Modern Slavery policy within their respective business units.
4. Relevant Policies and Processes
Aimia operates the following policies that describe its approach to the identification of modern slavery risks and steps to prevent slavery and human trafficking in all its activities:
4.1 Whistleblowing Policy: The organisation encourages all its colleagues, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our independent confidential helpline www.ethicspoint.com and complete our confidential disclosure form.
4.2 Business Code of Conduct and Ethics: The organisation’s code makes clear to colleagues the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
4.3 Recruitment and Agency Workers: Aimia only use reputable employment agencies to source labour and always verifies the practices of any new recruitment agency before accepting workers from that agency. Aimia carries out annual audits based on the GLAA principles on each agency we partner with, including randomly selecting individual workers for interview.
4.4 Supplier Code of Conduct: The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship. We seek to develop long-term relationships with our suppliers based on the principles of fair, open and honest dealings at all times. Only suppliers that share these principles and can demonstrate compliance to ethical standards will be considered appropriate to trade with.
5. Due Diligence
Aimia undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Technical, Purchasing, HR and Operations are responsible for any investigations, due diligence and corrective actions. Aimia’s due diligence and reviews include:
- Evaluating the modern slavery and human trafficking risks of each new supplier;
- Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers or requiring them to implement action plans;
- Participating in collective efforts focusing on human rights, slavery and human trafficking, informed by “Stronger Together” or “Ethical Trading” initiatives;
- As per our Code of Conduct, we will not knowingly transact with any supplier or customer involved in illegal or unacceptable business practices. We reserve the right to invoke sanctions against suppliers that fail to improve their performance in line with an action plan, up to and including the termination of the business relationship.
6. Risk Assessments
We assess all our suppliers through our robust risk-based systems and then monitor them accordingly. Our assessment tools determine the level of risk posed by each supplier, with the highest risk supplier sites being required to regularly demonstrate compliance via a third party independent ethical audit and to ensure any non-compliances are addressed within the timescales appropriate to the criticality.
7. Support and Development
Aimia are committed to providing guidance and support, where and when appropriate, for our colleagues and suppliers to identify and resolve modern slavery, human trafficking and ethical issues. We encourage and support continuous improvement in supplier standards.
8. Training and Raising Awareness
The organisation is committed to training key colleagues within the organisation to complete training on modern slavery, human trafficking and ethical trading. Ordinarily this would be completed via in-person training sessions but this has not been possible due to the COVID-19 pandemic. Aimia are in the process of reviewing its existing Modern Slavery training content and format, and are committed to developing an online Modern Slavery e-learning module.
As well as training colleagues, Aimia are committed to raising awareness of modern slavery issues by distributing information to colleagues, creating a dedicated notice board for all modern slavery resources, putting up posters around site in different languages spoken by Aimia colleagues, and circulating regular communication to colleagues.
These efforts explain:
• How to identify the signs of slavery and human trafficking;
• What initial steps should be taken if slavery or human trafficking is suspected;
• How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger Together” initiative.
9. Senior Leadership Team Approval
This statement has been approved by Aimia’s Senior Leadership Team who will review and update it annually. This statement is made pursuant of section 54(2) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2022.