Modern Slavery Act Statement – January 2024
Introduction
Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “MSA”) and a violation of fundamental human rights.
Modern slavery can occur in various forms including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery.
This document sets out Agrii’s policy on modern slavery including (anti-slavery and human trafficking) and outlines the core processes and procedures with the aim of preventions of opportunities for Modern Slavery to occur within our own business and that of our supply chains.
The policy is supported by other materials, training and guidance as identified below.
This policy also makes it clear how these processes fit together and how these are governed through a collaborative approach overseen by the Agrii board.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. You are invited to comment on this policy and suggest ways in which it might be improved.
Comments, suggestions and queries are encouraged and should be sent to: hrservices@agrii.co.uk
This policy does not form part of any employee's contract of employment and we may amend it at any time.
Our stance on Modern Slavery
Agrii is committed to conducting itself with the highest ethical and legal standards, ensuring that the operations within Agrii and its supply chain meet those standards at all times.
Agrii is compliant with the Modern Slavery Act 2015 and will not accept non-compliance to the act within its operations or those of partners or suppliers. We are aware that human traffickers and illegal/unlicensed gang-masters target a range of industries including those involved in the agricultural sector. It remains important therefore that we maintain our vigilance and activities, inclusive of those highlighted in this policy.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
Our resources and processes in summary:
The processes we have in place:
1. Supplier onboarding process, inclusive of reporting. We require new suppliers, as part of an onboarding process, to read and accept our agreement in relation to preventing Modern Slavery and demonstrate their Company’s commitment to complying with the MSA. We have a new Supplier Code of Conduct launched in 2022 which enhances the commitment we require from suppliers.
2. Employee training, guidance and support for raising issues. Our company intranet contains guidance on Modern Slavery for employees, including how to spot risks or contraventions of anti-slavery law and how to report issues. Our statement is available to new starters as an introduction. In 2020 we launched our first e-learning module on Modern Slavery and continue to ask employees to complete their training as necessary. We ensure a more targeted approach to education by sending out (at least annually) updated guidance for employees to read relating to Modern Slavery, ensuring awareness of key roles/people where they are engaged in field-based work in the Agricultural environment.
3. Annual review of statements, compliance and best practice, supported by external legal advice. Every year we seek external support and advice on the latest changes in the law, the government’s stance / initiatives, and any ‘best practice’. We review that advice internally as part of our governance review meetings.
Compliance with this policy
All employees must ensure that they read, understand and comply with this policy. As an employee, you are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your manager or a member of the Agrii Senior Management team (or make a complaint using the anonymous Whistleblowing Service, NAVEX, as detailed in this policy) as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or a member of the Agrii Senior Management team as soon as possible (or make a complaint using the anonymous Whistleblowing Service, NAVEX, as detailed in this policy).
You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or a member of the Agrii Senior Management team (or make a complaint using the anonymous Whistleblowing Service, NAVEX, as detailed in this policy).
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.
Breaches of this policy (internal and external)
External
If an issue is identified with a supplier we will work with them to prepare a corrective action plan and resolve all violations within an agreed upon time period. In the most serious of situations or where there is a failure to improve on a matter that Agrii has highlighted, Agrii is be prepared to terminate our relationship with individuals and organisations in our supply chain.
Internal
If our own employees have committed any act of misconduct in relation to MSA (including but not limited to failing to report instances of Modern Slavery or committing an act of Modern Slavery itself) such instances will be investigated thoroughly in line with Company disciplinary policy and may result in disciplinary action (including termination of employment for misconduct or gross misconduct).
Governance and Review
Every year, our statutory directors sign off on our annual MSA statement, as published on the Company website. A working group within Agrii comprising of HR, Operations / Procurement and Finance leaders meet every year (or as often as necessary) to review feedback, outstanding actions, and opportunities to further improve our processes and procedures to prevent modern slavery occurring in our business or supply chains. Once per year as a minimum, the Company will update its MSA statement and MSA policy, acquiring external guidance and advice where appropriate.