Walk Free+MSA training (revised)+ECOM AGROTRADE LIMITED+2020+Discussion

It states of providing training to its staff at origin level and at other points in the supply chain. We considered staff at origin level as employees of the company.

pg. 2

"ECOM has various initiatives to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, including, within the cocoa and coffee markets, the provision of annual training to our staff through ECOM’s Sustainable Management Services (“SMS”) initiatives at origin level and at other points in the supply chain."

"We have raised and continue to raise, awareness of the importance to ECOM of our SMS philosophy through effective communication and training on our SMS Code, ECOM Supplier Code of Conduct and Internal Code of Conduct, as well as our activities in the identification, mitigation and eradication of modern slavery. ECOM shall be implementing enhanced modern slavery training covering our due diligence toolkits in this respect. "

Here the origin level is concerned with the farmers, who are also a part of the supply chain. Hence, training is provided to the supply chain and there is no mention of employees.

pg. 3

"Through SMS programs at origin level, SMS looks to improve farmer yields through technical support, and provision of inputs and equipment, thus improving farming practices. "

. ECOM shall be implementing enhanced modern slavery

training covering our due diligence toolkits in this respect. 2