Aimia Foods Modern Slavery and Ethical Trading Statement

01 January 2020


Aimia Foods is committed to preventing slavery and human trafficking in all of its activities, and we require the same commitment from every supplier that we work with. As a responsible company, we strive to always do the right thing, to help us meet this objective we have implemented robust practices and policies

This statement sets out Aimia Foods actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the 2019 -2020 financial year.

As part of the Food & Beverage manufacturing sector, we recognise our responsibility to take a robust approach to these issues. The organisation is absolutely committed to preventing modern slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking and that we trade ethically with our supply chain partners.

Organisational structure and supply chains

This statement covers the activities of Aimia Foods Ltd

  • Aimia Foods Ltd operates in the UK and has 3 sites in close proximity in the UK- 2 manufacturing and 1 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 types of beverages in a variety of packaging formats and sizes, including juice-based products, hot chocolate, coffee, malt drinks, creamers / whiteners, cereals and others. This means that some of the areas in which we operate are at risk of 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


The relevant leaders of the HR, Technical, Purchasing and Operations functions are responsible for the implementation, development and ongoing maintenance of the policy within their respective business units.

Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Policies: The Human Resources department are responsible for putting in place and reviewing policies in relation to anti-slavery. These policies were drawn up in consultation with external and internal legal counsel, applying the principles and protocols of Stronger Together.
    • Sedex: We are members of Sedex (Supplier Ethical Data Exchange) which is a web-based system for suppliers to share ethical trading information with their customers.  We expect all our suppliers to have ethical processes and policies in place throughout their supply chain and manufacturing operations. As part of our commitment to ethical trading our suppliers of raw ingredients and labour are requested to register with Sedex.  We will monitor supplier compliance with this policy through the Sedex platform (where applicable) and /or through a range of other tools to support the risk management including the requirement for suppliers to provide reasonable information as evidence of compliance to the Modern Day Slavery Act.
    • SMETA Audit: Aimia complies with the SEDEX members ethical trading audit’s measurement criteria and implements best practice guidelines on Anti-Slavery provisions including: employment is freely chosen, child labour & young workers and discrimination-free working practices.
    • 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.
    • Monitoring:  Through active monitoring we measure the performance of our Suppliers against the Modern Slavery Act and the GLAA Licensing Standards, identify emerging trends and corrective actions.
    • Investigations/due diligence: Technical Audit, Purchasing, HR and Operations are responsible for any investigations, due diligence and corrective actions.
    • Training: Key Managers will attend the “Tackling Modern Slavery in UK Businesses and Supply Chains” workshop
    • Supervisors and Recruiters will be trained to spot the signs of hidden labour exploitation.

The HR Manager has been appointed to be responsible for:

  • Implementing processes and procedures for tackling hidden labour exploitation.
  • Ensure that all staff responsible for directly recruiting workers are trained on issues around third party labour exploitation and signs to look for.
  • Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
  • Encourage staff that are trained, to adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters and Labour Abuse Authority (GLAA) and police.
  • Provide information on tackling “Hidden Labour Exploitation” to our workforce in a variety of formats such as workplace posters and worker leaflets.
  • Circulate the Whistleblowing Hotline and the principles of the ETI Base code annually.

Support and Development

  • We 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 and we regularly measure supplier improvement.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy. The organisation encourages all its workers, 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 and complete our confidential online disclosure form.
  • Employee code of conduct. The organisation’s code makes clear to employees 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.
  • Supplier/Procurement Requirements. 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, treat workers with dignity and respect, and act ethically and within the law in their use of labour, we measure this through the Self-Assessment Questionnaire which we require all of our suppliers to complete. We recognise the need to communicate our commitment to key stakeholders including the public, our customers and our suppliers.  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 Aimia Foods.
  • Recruitment/Agency workers policy. The organisation 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.  Aimia Foods carries out twice yearly audit questionnaires on every agency and also randomly selects individual workers for interview.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

  • evaluating the modern slavery and human trafficking risks of each new supplier;
  • conducting supplier audits or assessments through Agency Audits to ensure a greater degree of focus on slavery and human trafficking where general risks are identified;
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through Agency Audits and requiring them to implement action plans;
  • participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular participation in “Stronger together” or “Ethical trading” initiatives;
  • using SEDEX, SMETA and the GLAA Licensing Standards where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation is:

  • requiring all senior managers, key staff working in purchasing, supply chain managers and HR professionals to have completed training on modern slavery;
  • developing a system for supply chain verification whereby the organisation evaluates potential suppliers before they enter the supply chain; and
  • reviewing its existing supply chains whereby the organisation evaluates all existing suppliers.


The organisation requires all senior managers, key staff working in Technical Audit, Purchasing, Supply Chain and HR professionals within the organisation to complete training on modern slavery, human trafficking and ethical trading.

The organisation’s modern slavery training covers:

  • 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;

Awareness-raising programme

As well as training staff, the organisation has raised awareness of modern slavery issues by distributing flyers to staff/putting up posters across the organisations premises/circulating a series of emails to staff.

The flyers/posters/emails explain to staff:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.

Performance Indicators 2019

1.         Sedex Self-Assessment Questionnaire Completion

Aimia Foods SAQ % Completion

Number of Suppliers Sedex Registered

Number of Suppliers Completed 95% of Sedex SAQ

% Signed Aimia Supplier Code of Conduct




2.       Audits Completed on Labour Providers

Number of labour providers supplying Aimia Foods

Number of labour providers supplying Aimia Foods

Number of labour providers supplying Aimia Foods

Number  of labour providers supplying Aimia Foods





3.         Awareness Raising

Number of employees attended Tackling Modern Slavery workshop

% of employees briefed in Modern Slavery Awareness

Number of key staff working in Technical Audit, Purchasing, Supply Chain and HR completed training on modern slavery, human trafficking and ethical trading.


Approx. 61%


Targets for 2020

The Aimia Foods Sedex Steering Group will have responsibility for ensuring that the targets below are met, however the HR team will have overall accountability in the delivery of the targets.




Develop a Supplier Code of Conduct and integrate it into all supplier relationships



Work towards increasing the number of our suppliers (from 22 to 72) signed up onto SEDEX



Aspire for all of our suppliers on SEDEX to be 100% for the new SAQ by end of 2020.



Aimia Foods 100% SAQ Completion for 2020, for both Penny Lane and Dixon Close sites

Human Resources


Work towards all key employees to be trained in modern slavery, human trafficking and ethical trading, including SLT Members, Plant Managers and Shift Managers

Human Resources

Senior Management Team Approval

This statement has been approved by the organisation’s senior management team members, who will review and update it annually.