Slavery and Human Trafficking Statement 

This statement sets out Prinova Europe Limited’s (“Prinova Europe”) 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 and its supply chains. This statement relates to actions and activities during the financial year 1 April 2019 to 31 March 2020.

As part of the global distribution industry in relation to food ingredients, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Prinova Europe is a supplier of ingredients for the food, feed, personal care, pharmaceuticals, health supplements, and other related industries globally. This statement covers all of our business activities:  brokering, import, export, cross-trade, storage, processing, and distribution of ingredients to our customers.

This statement encompasses activities carried out by the following branches of our Prinova Europe business:

• Prinova Europe Limited 

• Prinova Benelux & France N.V

• Prinova Spain S.L.U 

• Prinova Gida Ve Kimya Ticaret Limited Sirketi (Turkey)

• Prinova Australia & New Zealand 

• Prinova Mexico S. de R.L. de C.V.

• Prinova Solutions Europe Limited 

Prinova Europe operates across the globe.

Our head office is based in London (UK) and we have a number of sales offices around the globe (Belgium, Spain, Turkey, Mexico, Australia), as well as a manufacturing facility in Kent (UK). From those entities we trade globally: within the EU/UK, in the South East Pacific region, Turkey, Russia, Middle East, Mexico, and North Africa.

The manufacturers for the ingredients we source and supply are based across the globe. The majority of those are located in China and India. However, we also source a significant number of products from within the UK/EU zone, South East Asia and the USA.

Prinova Europe has identified the following activities considered to be at high risk of slavery or human trafficking: 

• Supply of commodities by producers within the region of Asia 

In relation to forced labour, the prevalence of this is highest in Asia and the Pacific, where four out of every 1,000 people were victims of modern slavery or human trafficking, followed by Europe and Central Asia (3.6 per 1,000), Africa (2.8 per 1,000), the Arab States (2.2 per 1,000) and the Americas (1.3 per 1,000) (Source : International Labour Organisation ‘ILO’ – Global estimates of Modern Slavery: Forced Labour and Forced Marriage – Geneva, September 2017) 

The team responsible:

• Executive Management Team

On an annual basis, the Executive Management Team (EMT) reviews the Modern slavery and human trafficking statement contents and agrees a plan of action to ensure it is updated and implemented to ensure that a robust risk management process is in place to remove the risk of the prevalence of slavery within the business supply chain.

• Human Resources

On an annual basis, the Human Resources Department drafts the Modern slavery and human trafficking statement following updates from the EMT and other relevant departments within the organisation and ensures that the statement is published within six months of the previous financial year on the company website if possible, or if not, at least have it available to respond to any requests for the statement within 30 days of request date.

• Quality

On an annual basis, the Quality Department reviews the Modern slavery and human trafficking statement following updates from the other relevant departments within the organisation and ensures that the statement is accurate based on the actions of the Quality Department in relation to supplier audits that take place for new suppliers or on an adhoc basis.

In addition to the Statement, Prinova Europe intends to;

• Ensure that it has an Ethical/Human Rights policy defining the ethical principles the company will uphold with regard to its own workers and workers in its supply chain.

• It has a recruitment policy that sets out the requirement to be aware of modern slavery in recruiting staff, and that the company will not employ slaves.

• It has a Supplier Code of Conduct which sets out Slavery and Labour standards to be upheld by direct suppliers and in the supply chain.

• In all the above, focus on a proportional and targeted response to slavery risks that can be incorporated within an organisational approach to other issues such as Labour Standards, Right to work, Immigration etc.

Prinova Europe had established and will ensure the adherence to:

• Our Global Code of Conduct (POLGLOBAL017) sets forward the rules of conduct required of our people as representatives of the Company when dealing with other employees, governmental authorities, suppliers, consumers, competitive commercial bodies, and the community within which Prinova conducts its business. This Code of Conduct is also applicable to affiliates, co-manufacturers, distributors, and agents conducting business on behalf of Prinova. It defines the ethical principles the company will uphold with regard to its own workers and workers in its supply chain.

• Our recruitment policy (SOPHR001) sets out the requirement to be aware of modern slavery in recruiting staff, and that the company will not employ slaves.

• Our Quality T&C for Prinova ingredients suppliers and manufacturers (SOP-GLOBAL-04) sets out Slavery and Labour standards to be upheld by direct suppliers and in the supply chain.

In all the above, Prinova Europe has focused on a proportional and targeted response to slavery risks, that can be incorporated within an organisational approach to other issues such as Labour Standards, Right to work, Immigration etc.

Prinova Europe has taken the following criteria into consideration for the risk assessment of suppliers with regards to slavery and human rights:

• Size & location

• The probability of the risk occurring, and the impact if it does

• Leverage to influence the supply chain

• Opportunities to improve

• Analysis of where the greatest likelihood of slavery is within the company’s operations, and within its supply chain, including sub-contractors

• Maintenance of an ethical risk log that is regularly reviewed

Prinova Europe maintains an up to date mapping of its supply chain to assist with the risk assessment. Sedex is used as a key tool to assist us in those efforts.

The following individuals and/or departments are responsible for the investigations and due diligence in relation to known or suspected instances of slavery and human trafficking within our business or supply chain:

• Management – Nic Dam, Group Managing Director:

To ensure that any known or suspected instances of slavery and human trafficking are dealt with quickly and effectively and that all relevant stakeholders are made aware of the matter in question.

• Quality Department – Fanny Crossley, European Quality Manager:

To work with any auditors on the ground to investigate areas of concerns for supplier rated as high risks to investigate actual practices.

To escalate concerns over slavery practices within supply chain to EMT.

To conduct an efficient and robust investigation and collate all relevant data in the event of known instances of slavery within our supply chain.

• Human Resources – Thomas Gill, Human Resources Director – EMEA & APAC:

To ensure compliance with all policies in relation to this and any external advice is sought as required to ensure any suspected instance of slavery or human trafficking is dealt with appropriately.

To conduct an efficient and robust investigation and collate all relevant data in the event of known instances of slavery within our supply chain.

The Quality and Human Resources Departments are ultimately responsible for putting together training plans to ensure that all relevant employees or external contacts such as suppliers or customers better understand and can better respond to the identified slavery and human trafficking risks.

Prinova Europe 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.

Prinova Europe encourages all its workers, customers and other business partners to report internally any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. This whistleblowing process is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form. 

Prinova Code of Conduct makes clear to employees the actions and behaviour expected of them when representing the company. Prinova Europe strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. 

Prinova Europe is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the Quality T&C for Prinova ingredients suppliers and manufacturers (SOP-GLOBAL-04) will lead to the termination of the business relationship. 

Prinova Europe uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. 

Prinova Europe undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Our approval procedure (SOPQUA005) must be followed and completed prior to the commencement of any commercial activity. Prinova Europe’s due diligence and reviews include:

• Evaluating modern slavery and human trafficking risks of each new supplier;

• Mapping our supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking; 

• Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;

• Conducting supplier audits or assessments through internal or third-party auditors as applicable, which have a greater degree of focus on slavery and human trafficking where general risks are identified; 

• Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through third party auditors and requiring them to implement action plans;

• Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular, such as the “Ethical Trading Initiative”; 

• Using details of ethical supplier database, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular;

• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship. 

Prinova Europe has reviewed its key performance indicators (KPIs). As a result, the organisation is:

• Requiring all staff/staff working within the supply chain process of our business to have completed training on modern slavery within 12 months on the issuing of this statement;

• Developing a system for supply chain verification expected to be in place within 12 months of the issuing of this statement, whereby the organisation evaluates potential suppliers before they enter the supply chain.

Prinova Europe requires all staff working within the supply chain process of our business/HR professionals within the organisation to complete training on modern slavery as a module within Prinova Europe’s training programme.

The course content may vary depending on the employee’s role within the business, but some core principles should be covered:

• Our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;

• How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;

• How to identify the signs of slavery and human trafficking;

• What initial steps should be taken if slavery or human trafficking is suspected;

• How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;

• What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority, and “Stronger Together” initiative;

• What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies;

• What steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

As well as training key supply chain staff, Prinova Europe will continue to bring awareness of modern slavery issues through internal communication channels, such as dedicated emails, company newsletter, or all-hands meetings.

Awareness programme is aimed at all employees and should cover the following topics:

• The basic principles of the Modern Slavery Act 2015;

• How employers can identify and prevent slavery and human trafficking;

• What employees can do to flag up potential slavery or human trafficking issues to;

• The relevant parties within the organisation;

• What external help is available.

This statement was approved on 29/09/2020 by the following company Directors:

Nic Dam, Managing Director for Prinova Europe.

Director’s signature:

Thomas Gill – HR Director EMEA & APAC

Director’s signature: