Direct/Tier 1 involvement along with research and collaborations with other relevant suppliers in the market, however no mention of direct suppliers ensuring that their suppliers also adhere to the company’s relevant policies:
1. "In addition to the work in our own supply chains and operations, we continue to prioritise collaborations, which we view as essential given the deep rooted and systemic nature of many manifestations on Modern Slavery.Focusing on understanding further our supply chains including labour providers and recruiters to supply chain and services, including sub-contractors, distribution, equipment and services." (Page 1)
2. "We have continued to implement Stronger Together within our Food business, and supported the expansion of Stronger Together into South Africa. As described above we have held a flagship Indian conference, developed a new International Modern Slavery toolkit and supported roll out of Issara responsible recruitment toolkit. We have supported Car wash providers through training and audit and encouraged Vietnamese, Thai, Italian, Spanish and Malaysian suppliers to access relevant collaborations training." (Page 10)
3. "In 2017-18 we consulted suppliers on a new Global Labour Provider Policy" (Page 4)
4. "During this year we have undertaken research with a select number of suppliers and labour providers to further understand how growers and labour providers in the UK Produce industry undertake direct recruitment from origin countries and the costs incurred." (Page 5)
5. "Our Global Sourcing Principles (GSP) have applied to product suppliers since 1998, and as of May 2016, have been extended to all suppliers and franchise partners – including goods not for resale. We updated our standard supplier contractual terms for new suppliers in 2016 and 2017 to include obligations on Modern Slavery Act risk assessment, controls, and notification of Modern Slavery findings.
In 2018 we have further strengthened our Global Sourcing Principles, this included clarifying position on non- payment of recruitment fees, expectation on Supplier transparency and requirement for additional due diligence if operating or sourcing in High risk locations. For goods and services not for resale procurement we introduced Supplier management policy which includes Global Sourcing principles to ensure all businesses are captured." (Page 5)