The NFT Group (which includes NFT Distribution Operations Ltd and NR Evans Ltd) recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is committed to preventing slavery and human trafficking in all of its activities and to taking steps to ensure that its supply chains are free from slavery and human trafficking.
This statement sets out NFT’s 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 or its supply chains. This statement relates to actions and activities during the financial year ending 30 March 2019.
NFT’s Board has responsibility for ensuring that this Statement is appropriately implemented within the business and that, where required, the appropriate training is provided to employees and suppliers.
ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS
The NFT Group specialises in the delivery of chilled, ambient or frozen food & drink products from production line to retailer distribution centre (RDC). NFT operates via a national network of depots and warehouses, in both Primary (manufacturer to RDC) and Secondary (RDC to store) distribution channels. The organisation currently operates predominantly in the UK with use of sub-contractors in the EU.
NFT is committed to ensuring that its suppliers adhere to the highest standards of ethics. NFT has communicated with all its suppliers to set out the standards expected of them. NFT has sought confirmation from all its suppliers that they agree to adhere to our Modern Slavery and Human Trafficking Policy and a new Code of Conduct that highlights the standards expected from all third party suppliers. All suppliers have been advised that any breach of the Act, the Policy or the Code of Conduct will result in immediate termination of the contract.
NFT works closely with its employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. An agency audit is completed annually.
The Head of Policy and Employee Relations is responsible for implementing and reviewing all policies. All policies are implemented consistently across the business and are reviewed on an annual basis.
NFT 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.
MODERN SLAVERY AND HUMAN TRAFFICKING POLICY
This policy directly addresses NFT’s commitment and adherence to the Modern Slavery and Human Trafficking requirements. The Policy has been publicised across the organisation.
The Whistleblowing Policy encourages all of NFT’s employees, customers and other business partners to report any concerns related to the direct activities of the organization or its supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Whistleblowing Policy is designed to make it easy for workers to make disclosures, without fear of retaliation or reprisal.
The Legal Department is responsible for investigations in relation to known or suspected instances of slavery and human trafficking.
Any matter that gave cause for concern would be thoroughly investigated.
All commercial contracts have been updated to include obligations on both contracting parties to specifically adhere to all legislation relating to modern slavery, human trafficking, anti-bribery and anti-corruption.
NFT regularly evaluates the potential exposure to the risk of modern slavery and human trafficking in the supply chain. NFT is not considered to be operating in high risk sectors or locations and ensures compliance with all legislation.
Where particular activities or countries are considered high risk in relation to slavery or human trafficking, NFT will carry out the appropriate risk assessment, interrogate the results and take action as appropriate.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to the relevant members of staff which includes NFT’s Code of Conduct and the processes to be followed should there be any suspicion of any of our suppliers being involved with any issues that are covered by the Act. The Human Resources department is responsible for training relating to this Policy.
We have invested in upgrading our online training portal with compliance management system to manage training more effectively. Annual refresher training includes Modern Slavery Awareness, Anti-Bribery and Corruption and Whistleblowing with different levels of training provided. The most senior managers receiving advanced training.
Our Modern Slavery training for employees covers:
- Modern Slavery Act 2015
- Different forms of modern slavery
- Indicators of slavery
- Reporting suspicion
NFT is committed to continuously reviewing and training to raise awareness to ensure that modern slavery and human trafficking are prevented.
This statement has been approved by the General Counsel on behalf of the NFT Board, who will review and update it annually. This statement is made pursuant to the section 54 of the Modern Slavery Act 2015 and constitutes NFT’s Modern Slavery and Human Trafficking Statement for the financial year ending 31st March 2019.
Reviewed 14th March 2019