Slavery and Human Trafficking Statement 

Modern Slavery is a serious and often hidden crime in which people are exploited for criminal gain. Modern slavery takes various forms: slavery, servitude, forced and compulsory labour and human trafficking. There were an estimated 40 million people in slavery globally, 24.9 of those in forced labour (64% of which in the private sector). It is estimated that 136,000 people are living in modern slavery in the UK (2016 data). However, it is estimated that many more victims are not identified or reported, both in the UK and abroad.

Prinova is part of a global distribution industry, and we recognise our responsibility to take a robust approach to slavery and human trafficking. Prinova has a zero-tolerance approach to modern slavery. This statement sets out our actions to understand all potential modern slavery risks related to our business and to put in place steps to ensure that there is no slavery or human trafficking in our own business and our supply chains.

This statement is made in accordance with our obligations under the Modern Slavery Act 2015 and relates to actions and activities during the financial year 1 April 2020 to 31 March 2021.

Prinova Europe is one of the world’s largest distributors of functional ingredients and a provider of integrated solutions such as nutrient premixes and particle management services. The products we supply are used 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, blending, packing, 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 GmbH Germany
• Prinova Mexico S. de R.L. de C.V.
• Prinova Solutions Europe Limited

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 vision is to “make a bigger global impact by helping our customers grow their business, by improving consumers’ quality of life, and by advancing the highest principles of quality, safety and sustainability” is guided by 7 core values. Out of those, 3 are particularly relevant to Prinova’s commitments to prevent modern slavery within its business:
 

• Accountability - Accountability is being responsible for the things you say you will do, and doing them. We and our customers have high expectations for performance. Commit to quality work and meeting commitments, while maintaining high ethical standards.

• Integrity - With transparency, honesty, and open communication, we’re committed to doing the right thing — simply because it’s the right thing to do.  
  

• Safe Positive & Engaging Work Environment - We promote a respectful team environment that inspires us to be our best, and a workplace that is safe, positive, and engaging.
   

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. HR and Quality departments are involved in the support of all activities related to the agreed plan of action, both internally and with our suppliers.

Prinova Europe has developed 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:

• 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 up hold with regard to its own workers and workers in its supply chain. The core clauses of our code of conducts are based on the ETI base code, supporting ethical labour practices.
  

• 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. All of our suppliers as part of our approval process, are required to read and confirm adherence to those standards. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. Violations of the Quality T&C for Prinova ingredients suppliers and manufacturers (SOP-GLOBAL-04) will lead to the termination of the business relationship.

• Whistleblowing Policy - 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.

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 and Immigration.

The following individuals and their reporting teams 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:

• Executive Management – Group Managing Director & Director of Operations

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

• Quality & Regulatory Departments – Head of Compliance, Quality Managers & Regulatory affair manager

To manage our supply chain mapping and risk assessment risk of modern slavery

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 – Director of People and Culture & HR manager

To ensure compliance with all policies in relation to employees rights

To review any external advice as required to ensure any suspected instance of slavery or human trafficking is dealt with appropriately

To coordinate matters brought to our attention via our whistleblowing policy

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

Our first priority during the Covid-19 pandemic was to safeguard our employees. Where possible, all our employees worked from home when lockdowns were imposed in our various locations. We maintained the working from home well past the lockdown restrictions where possible, to continue to protect our employees and their families from risk of infection. Understanding our team members individual circumstances were varied, Prinova worked hard to arrange for flexible working and support (financial and material) to accommodate the impact working from home had. A strong focus was place on support our team’s mental health through various initiatives, guidance and individual support.

For our factory-based teams, where working from home was not an option, we implemented social distancing measures and additional hygiene controls (such as restrictions on visitors, additional cleaning regimen etc.) to ensure the safety of our staff.

All employees classified as vulnerable, or with a vulnerable family member, were identified early on and special measures put in place to shield them.

With regards to our business partners, our commercial teams worked very closely with our manufacturers & customers to ensure minimal disruption to our supply chain. Prinova honoured all contract placed with suppliers and did not implement any sort of penalties for the delays caused by the pandemic, as per best supply chain practices. Prinova managed stock and inventory in view to honour customer contracts, prevent shortages from panic buying which could have led to significant issues in the most vulnerable downstream applications, such as infant formulae and medical/meal replacements applications.

Prinova has taken important steps to map its supply chain and prevent risks of forced labour where high-risk sourcing areas / countries were identified.

High-risk suppliers have completed Prinova due diligence during the approval process as well as additional controls implemented since the beginning of 2021.

• Completing our comprehensive paperwork including our suppliers & manufacturers self-assessment questionnaire section 18
  
  
• Signing our Quality T&C as well as our Prinova Code of Conduct
   

• Suppliers are members of Sedex
   

• Suppliers have undergone SMETA 4-pillar audit conducted by a 3rd party certification body. Their full reports are published on the Sedex platform. The audits reported suitable use of independent workers' interviews and no breach of policies were observed with regards to human rights or forced labour. Any NC identified during the audits (mostly H&S matters) were addressed and closed.

Prinova will continue to monitor its supply chain closely and promote best practices across its supply chain with regards to workers’ rights. Any indication of malpractice would result in the termination of our contracts with the supplier.

As well as training key supply chain staff, Prinova Europe has continued 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.

• Improve and raise awareness on the whistleblowing practices in the company

• Build a 3-year sustainability strategy incorporating human rights considerations

• Build a number of the UN Sustainability Development Goals into our corporate strategy

• Complete our 1^st SMETA 4-pillar audit for our distribution activity in Europe

• Upgrade our Sedex membership to Supplier/Buyer profile to allow more effective use of the tool to risk assess our manufacturers

• Align Sedex membership at group level

• Increase our supplier engagement in Sedex
       -   Target 75% of manufacturers onboarded into the system by end June 2022
       -   Complete risk assessment on manufacturers by end August 2022   
       -   Target high risk manufacturers ato have completed a SMETA-4 pillar audit by end 2022

This statement was approved on 29/10/2021 by the following company Directors:

Nic Dam, Managing Director for Prinova Europe.

Director’s signature:

Thomas Gill – HR Director EMEA & APAC

Director’s signature:

Louise James, Director of Operations for Prinova Europe.

Director's signature: