W.B. Chambers Ltd. Modern Slavery and Human Trafficking statement for the Financial Year 2017.

In line with the UK Modern Slavery Act 2015, this statement has been published and produced with regard to the business activities and the company supply chains, which will be reviewed annually alongside the annual financial reporting, last reviewed on 31st January 2018.

The business operates a number of UK farming sites, and also works with a global supply base which allows for an annual business model to operate during the calendar year. Allowing for seasonal fluctuations in each country due to weather conditions.

The importing, growing and retailing of the produce it grows and procures is done with key strategic partner growers, all have a desire to eliminate modern slavery, and produce the best quality produce.

The collective business in the past 12 months has been taking steps to eliminate slavery and human trafficking in any of the supply chains that it has, and within the specialist business units that it operates which is reflected in W.B. Chambers Farms Ltd business and linked companies.

The business has a ‘zero tolerance’ for any modern slavery . This can take many forms, including forced labour, child labour, human trafficking and bonded labour. We are strongly committed to eradicating modern slavery and recognise the importance of transparency in Supply Chains in driving collaborative action to help eliminate the incidence of modern slavery.

To prevent modern slavery in our business or our supply chains, we need to make our own Directors and employees aware of the issues and provide them with the tools to tackle it.

We have the policies covering the procedural guidance, training, and business commitments. Policies cover direct and indirect obligations to reducing Modern Slavery and Human Trafficking. Directors, Managers and employees are instructed allowing them to highlight and tackle potential issues.

We have a number of policies which cover a multitude of aspects these being: –

Children under 18 .

Equal Opportunities Policy.

Ethical Trade policy (ETI Base code).

Induction Policy and procedures.

Eligibility to Work in the UK.

Welfare Policy.

Health & Safety policy.

Labour Exploitation policy.

The business has attended several Stronger Together Initiative workshops which work to reduce exploitation of workers. The Initiative aims to reduce human trafficking, forced labour and exploitation or workers for the prevention of modern slavery.

W.B. Chambers is a member of SEDEX Information Exchange (SEDEX), which is a not-for-profit membership association, a collaborative platform for buyers, suppliers and auditors to store, share and report on information.

W.B. Chambers also recognises and works towards the ETI Base code (Ethical Trade Initiative), which is founded on the conventions of the Internationals Labour Organisation (ILO), and is an Internationally recognised code of labour practice.

The business has various ways of working with it’s key partners and growers based around the globe. As the business is changing and growing, these methods of engagement are key to the growth of the business which will underline the knowledge base of the supply chain.

Communication – All of the companies that we work with can speak to key individuals within the company. Often these routes to conservations will be via telephone / and or email, through the commercial, procurement and technical teams.

Hand in Hand – Many of the sites, growers we work with have been visited on a number of occasions by the management team. This has been in the form of checks, audits, growing advise or commercial negotiations. Work to improve this visibility of information about the growers is ongoing. We will support and assist any of the sites that require advice or information. (second party auditing will increasingly be an important part of the supply chain understanding). Risk Assessment highlighting the areas of Modern Slavery will change for the country and complexity of the supply chain.

3rd Party Verifications – All of the sites that we work have 3rd certification for various farming standards. Increasingly growers are required to have 3rd party Ethical Audits in a number of countries, and these have been conducted on announced or semi-unannounced basis.

These audits are based on the Ethical Trade Initiative base code, and typically are SMETA (SEDEX Members Ethical Trade Audit) Pillar 2. This allows for collaboration of the audit findings and improves ways of working, and encourages business improvement, that helps the overall supply chain. We are also working with growers, who via Global GAP have added the GRASP module to the third-party audits, (GRASP Global G.A.P. Risk Assessment on Social Practice), which is committed to social aspects, including worker health & safety and welfare.

W.B. Chambers Farms Ltd., also has a third-party verification process once every two years, which is against the SMETA audit Pillar 2, on a semi-announced basis, to verify and indicate any key aspects of ethical welfare of it’s workers including the SMETA methodology using the ETI Code and local laws as the measurement tool, it includes Health & Safety and Labour Standards.

The business employs a significant number of seasonal staff for the main farming activity during the UK Summer months. Numbers of these staff come from the European Union, mainly from Eastern European countries.

Checks are carried out prior to, and during the recruitment process, and then during the period of employment. As the business has worked with the same countries for numbers of years, a good reputation has been established and the exit procedures of the company are just as important. This ensures that there is a good return rate for employment the following season.

The business operates to the following aspects: –

1. Designated managers who have attended “Tackling Hidden Labour Exploitation” training and have responsibility for developing and operating company procedures relevant to this issue.

2. W.B. Chambers works with a non-profit organisation that has a strong reputation for recruiting seasonal workers, this company does not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee. These businesses are registered on the Gangmasters Licensing Authority (GLAA – Gangmasters Licensing Abuse Authority)

3. Numbers of staff via word of mouth or previous employees recommend the business to families and friends; the managers responsible for directly recruiting workers are aware of issues around third-party labour exploitation and signs to look for during the recruitment process.

4. Labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members with a clear hierarchy and areas of responsibility.

5. Proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and local authorities is encouraged.

6. “Hidden Labour Exploitation” information and notices are available around all the key farming sites and communal staff areas, in multiple languages to our workforce.

7. Workers are encouraged to report cases of hidden third-party labour exploitation or other grievances to the site wardens, support teams, or anonymously, which means that swift actions can be taken. Reporting mechanisms can be via the seasonal site wardens and other site wardens, alongside whistleblowing retailer services and comments boxes.

8. An annual check of personnel records identifying any duplicate home addresses, bank accounts, phone numbers emergency contact numbers and next of kin as alert flags that may indicate potential worker exploitation. Any suspicious duplicates (i.e. not joint accounts for two related workers) are investigated and remedial action is taken as appropriate. New banking checks with our bank are being planned for the 2018 season, to further identify any risks.

Managing Director – Tim Chambers
Date 31 January 2018