Slavery and Human Trafficking Statement
This statement is made in accordance with section 54 of the Modern Slavery Act 2015. It sets out the steps taken and progress made by Hovis® Limited during the financial year ending 30 September 2024 to prevent modern slavery and human trafficking in its business and supply chain.
Overview
Hovis® Limited is a baking business, employing 3,000 people in eight bakeries, one flour mill and three distribution centres across the UK. We are proud to be part of a baking heritage that goes back more than 130 years, now delivering more than a million of our much-loved loaves everyday through the UK and Ireland. We pride ourselves on the taste and quality of all our bakery products. Our core brands include Hovis®, Mothers Pride® and Ormo®.
Our core values apply to how we act and do business and are centred on three key principles: Quality; Accountability and Trust. We recognise that we must adhere to the highest possible standards in everything we do. This commitment includes ensuring that people within our business and our supply chain are treated with dignity and respect and we take proactive steps to tackle and prevent slavery, servitude and human trafficking.
Our business and supply chain
Hovis® Limited is the trading entity for the Hovis® Group which is ultimately owned by Endless LLP. The Hovis® group structure is as follows:
Headquartered in High Wycombe, Hovis® Limited (“Hovis®”) employs around 3,000 colleagues in the United Kingdom. We also use agency labour in our business which is sourced through carefully selected, reputable recruitment agencies who are signed up to our terms and conditions for modern slavery.
We recognise and respect the rights of our colleagues to join trade unions, recognising a number of Unions for collective bargaining purposes across our sites and adopting a collaborative working approach.
We work with over 1,200 suppliers across our supply chain. Our suppliers are an integral part of our business, and we work closely with them to build sustainable and trusted business relationships. Our direct suppliers provide ingredients and packaging for our products. The majority of our raw ingredients and packaging materials are sourced from suppliers based in the United Kingdom and Europe; however, they in turn do source some minor and seasonal ingredients from further afield such as Turkey and China. Our indirect suppliers provide us with goods or services to support the day-to-day business operations, such as utilities, maintenance, logistics and bakery equipment.
Our Policies: Slavery and Human Trafficking
Hovis® does not tolerate any form of modern slavery in its business or supply chain and is committed to eradicating such practices and protecting the workforce. We employ a number of policies, systems and controls to ensure that we are conducting our business in an ethical, responsible and transparent manner:
a. Anti-slavery Policy: This policy applies to all colleagues and agency workers of Hovis®. It sets out the roles and responsibilities of colleagues, how slavery may be identified and how to report concerns.
b. Recruitment Procedure: We (and our recruitment partners) operate a robust recruitment procedure, including conducting eligibility to work in the UK checks for all employees and agency workers, to safeguard against human trafficking or individuals being forced to work against their will.
c. Whistleblowing Policy: This policy applies to all colleagues and workers of Hovis®. It sets out how to raise concerns about how people are being treated, or practices within our business or supply chain, without fear of reprisals.
d. Safecall line: Hovis® supports a culture of openness and transparency. In conjunction with the Whistleblowing Policy, Hovis® operates a confidential and externally hosted Whistleblowing line/portal that can be contacted (by telephone and online) 24 hours a day, 365 days a year to allow colleagues and workers to report (anonymously if they wish) concerns of unethical conduct or behaviour. This gives individuals a method of reporting suspected incidents of slavery or servitude in a confidential manner. All complaints and reports are investigated.
e. Code of Conduct: This code aligns with our core values and explains the way Hovis® operates as an organisation and the expectations of our colleagues and workers. It requires all colleagues and workers to ensure that they comply with applicable laws, rules and regulations; to act with honesty and integrity; and to treat people fairly with dignity and respect. Non-compliance with the code may result in disciplinary action being taken.
f. Human Rights Policy: Hovis®’ Human Rights Policy is publicly available on the Hovis® website (www.Hovis.co.uk). It sets out our commitment and the steps we take to meet our responsibility to respect internationally recognised human rights standards. It is guided by the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. It applies to Hovis® colleagues, workers, contractors, suppliers and any other third parties working with us.
Due diligence Processes: Slavery and Human Trafficking
Forced labour, in any form, has no place in Hovis®’ operations and supply chains. Hovis® has an Ethical Trading Policy Statement, which is based around internationally recognised code of labour practices, setting out the minimum standards we expect all of our suppliers and business partners to adhere to. Suppliers are obliged to adhere to our Ethical Trading Policy Statement, as well as our Human Rights Policy, as part of our standard terms and conditions of purchase.
Hovis® continues to be a member of SEDEX (Supplier Ethical Trading Data Exchange), a not for-profit membership organisation dedicated to driving improvements in ethical and responsible business practices in global supply chains. We require all direct ingredients and packaging suppliers to be members of SEDEX to give us visibility of their ethical performance and to aid the assessment of risk in our supply chain. In addition, all our manufacturing sites are SEDEX registered and have completed the self-assessment questionnaire, providing a risk rating. Furthermore, most sites are independently audited to the SMETA standard, which is the world’s most widely used audit. Actions to correct any non-conformances resulting from the audits are detailed by the site in a corrective action plan.
All procurement centrally sourced suppliers must complete a Supplier Due Diligence Questionnaire to enable the business to understand the steps prospective suppliers are taking to prevent modern slavery and human trafficking in their supply chains and to identify and work with them to mitigate any risk. This measure gives Hovis® greater visibility and understanding of its supply chain from the outset and ensures that Hovis® does not appoint or work with any centrally sourced suppliers unless and until it is satisfied that they demonstrate and implement standards that are aligned with our policies, expectations and values.
To ensure that Hovis®’ suppliers comply with the Modern Slavery Act 2015, we continue to include contractual ‘anti-slavery’ provisions in our agreements that require our suppliers to confirm to us that they have and continue to take steps to prevent modern slavery within their business and supply chains and to report any incidents or suspected incidents to us. Where appropriate, we also include a contractual right to conduct audits of suppliers to ensure compliance with all applicable laws, regulations and contractual terms, including the prohibition against forced labour, slavery and human trafficking.
Assessment of Risk
We work in conjunction with our suppliers to assess the risk of slavery and human trafficking in our supply chain. Hovis® purchases a wide range of goods and services, predominantly from suppliers based in the UK and Europe, which are seen as lower risk. Additionally, we procure products from the agriculture sector and a limited range of goods from suppliers outside of Europe, which can pose a greater risk from a modern slavery perspective.
All Technical auditors supporting supplier evaluation have undertaken modern slavery training to support identification of the signs of modern slavery through the supplier assessment process. We work closely with and provide training to key internal stakeholders in our procurement function, who will often visit suppliers’ premises, to enable them to know the signs to look out for during any such visits and they are encouraged to report any concerns.
We continue to work with an independent external compliance organisation to conduct SMETA audits identified by our procurement function as being medium to high risk from a modern slavery perspective based on Stronger Together guidance on assessing supply chain risk, Hovis®’ knowledge, the source of the raw materials and/or the nature of the services and the level of spend.
We also continue our supply chain mapping of our Key Tier 1 suppliers to enable us to have a greater understanding of our supply chain and more easily identify higher risk suppliers based on sector, country of origin of raw material, SEDEX risk rating and a geographical risk index pertaining to human rights. This enables us to identify higher risk tier 2 suppliers and allows us to expand our risk assessment strategy and conduct audit beyond our immediate supply base, thereby further enhancing our compliance.
We have also considered the risk of slavery and human trafficking in our operations via the use of agency labour, and we consider the risk to be low due to the robust recruitment and on boarding processes that we, and our recruitment agencies, abide by. In addition, members of our Human Resources team, who have received modern slavery awareness training, conduct regular audits of the recruitment agencies we use, including selecting a random sample of workers to speak with to identify any concerns or breaches of the applicable legislation and policies. In the 2023/4 financial year, no material non conformances were identified as a result of these audits.
Key Performance Indicators
We monitor and measure for signs of modern slavery through several key indicators including: the number of whistleblowing reports received in relation to modern slavery; the number of non-conformances in audits; the number of non-conformances in ethical audits (SEDEX) and the number of external alerts in relation to modern slavery. Our monitoring was positive with no reports of exploitation, modern slavery or trafficking.
Training & Education
Training within Hovis® is a fundamental way of raising awareness of the issues of modern slavery and labour exploitation. This activity provides our colleagues with the tools to be able to identify any suspected cases and what to do if this were to happen. We utilise both external specialist training from Stronger Together as well as internal tools.
In the 2023/24 financial year, we continued to build on our training programme, ensuring modern slavery is included in our induction programmes.
We ensure all new starters in our Procurement team receive specific modern slavery training through purchasing practices, to enable them to better understand and assess modern slavery risks in our supply chain. This highlights how they play a pivotal role in helping the business to prevent risks at an operation level.
In 2024 we delivered bespoke training for the wider HR team, alongside key operational colleagues, on modern slavery training in practice, identifying signs and associated escalation activity. We also undertook a review of internal ‘red flags’ to review any signs of modern slavery internally.
Future Focus
During the 2024/5 financial year we will continue to raise employee’s awareness of modern slavery through: continued training and awareness for all colleague’s; refresher training for our HR and operational colleagues in relation to spotting the signs of modern slavery; undertaking proactive screening in relation to modern slavery red flags and supporting Anti-Slavery Day.
This statement was approved by the Board of Directors of Hovis® Limited on 6 March 2025.
Jon Jenkins, Hovis® Chief Executive Officer