Modern Slavery Statement March 2023
This statement has been published in accordance with the MSA, 2015 and Global Sourcing Principles, 2016.
It sets out the steps taken by Wholebake Ltd (and associated companies) during the previous year as well as commitments, in the coming year, to tackle Modern Slavery and protect Human Rights in its business and supply chains.
Wholebake Ltd is a food manufacturer producing gluten free snacks, based at 3 BRC AA graded sites in North Wales. Our supply chains are global and are managed closely and transparently having focused on building good relationships from the outset.
The company operates using core values that are based around passion and integrity; focusing heavily on engagement, empowerment and entrepreneurship.
We know that despite being a small business, that Modern Slavery risks exist and we all have a responsibility to be alert to these risks however small in our business and in our supply chains.
Wholebake Ltd publishes this new statement to include steps to apply the Global Sourcing Principles on forced labour and agency labour and reduce the risks of forced labour within the supply chain. We audit our labour providers against these principles and carry out audits and due diligence with our Suppliers, however, in the coming year, we plan to expand this work by further mapping our supply chain and working with suppliers on more specific requirements.
Policies and Contractual Controls
Wholebake Ltd internal policies confirm that we will not tolerate or condone abuse of human rights in any part of its business or supply chain and will take seriously any allegations made in this regard. We are audited every 2 years via a SM ETA audit and are linked to our suppliers and retailers on SEDEX.
Whole bake offer the below opportunities to access to remedy for employees, agency workers and contractors:
• External Whistleblowing Hotline with See Hear Speak Up
• An internal whistleblowing policy
• Publication of external agencies such as Modern Slavery Helpline and GLAA throughout our sites and in strategic places
• Internal Grievance procedures
*All reports will be fully investigated by Senior Management and remedial actions taken. In cases of Modern Slavery, Wholebake Ltd will also work with relevant agencies such as GLAA and Modern Slavery Helpline in an open, collaborative and transparent way.
Awareness and Training
The Wholebake Executive and Senior Management Team have attended Stronger Together training, which ensures that the subject of Modern Slavery and exploitation is embedded right from the top of the organisation and sits with those who influence and lead behaviour through policy and training, and also those who drive the objectives which become the accountability of everyone.
We carry this awareness training further throughout the organisation with the introduction of training for Line Leaders and Supervisors to understand the signs of Modern Slavery and the process for reporting this.
We have also included Modern Slavery as a stand alone subject within New Starter Inductions, as well as including Stronger Together literature in all starter packs.
All Labour Providers who supply to workers to Wholebake Ltd, are expected to have a strong focus on their own ethical agenda, including Stronger Together Training, as well as any continuous improvement in regard to the prevention of Modern Slavery.
Within Service Level Agreements, Wholebake Ltd outline expectations to audit Labour Providers with both announced and unannounced audits, based on the requirements of ETI Basecode and the Wholebake Ltd Policy on Ethical Trading.
Over the last 12 months, all Labour providers have been audited by Wholebake Ltd. Where agencies have been found to have corrective actions, full support has been given and a plan put in place to address actions.
We understand that our biggest exposure to Modern Slavery is in our product supply chains. Over the past year, we have increased our focus on Modern Slavery within our wider business operations and our supply chain.
Although we have yet to map out the supply chain and carry out individual risk assessments, Wholebake Ltd are committed to commencing this mapping exercise over the coming year.
We have already identified our more high risk areas within the supply chain, but this work will continue to the rest of Wholebake Suppliers. We issue SAQ's and carry out Sedex checks to ensure basic compliance with Ethical Standards. However, we are aware that there are limitations to "mainstream audits" and as part of our supply chain assessments will carry out our own risk assessments as we progress through the mapping exercise with risk being based on:
• Volume of supply
Assessment and monitoring of the above will be measured by audits (both announced and unannounced) as well as through risk assessments, SAQ's and checks on Sedex.
As a BCorp certified and SM ETA audited business, we feel that we are taking every step possible to hold ourselves to the highest standards of ethical behaviour and collaborate with other businesses to encourage them to do the same.
We will continue to assess our performance in these areas as well as seeking opportunities to mitigate further any risks of Modern Slavery wherever we can.