Natures Way Foods (NWF) is a leading manufacturer of fresh convenient food. We supply prepared salads, coleslaw and potato salad, and fresh food to go products to some of the UK's largest supermarket and foodservice companies. NWF's financial year ends on the 31st March 2023. NWF is committed to preventing modern slavery and human trafficking in all its activities; and ensuring that its supply chains are free from modern slavery and human trafficking.
NWF operates and manufactures in the UK and sources raw material from a world-wide supply base.
Natures Ways Foods plays a proactive role in the eradication of modern slavery and all its related practices, actively supporting the “Stronger Together” initiative, ensuring compliance with the ETI base code, SEDEX and promoting best practice within both our organisation and that of our suppliers. We are building on this strong foundation by incorporating our policies and procedures into everything we do. We aim to work with our suppliers to build effective and transparent supply chains. We have a rigorous supplier approval process, operated by our Compliance team.
We expect our suppliers to operate to the same ethical standards that we employ ourselves. NWF is a member of Supplier Ethical Data Exchange (SEDEX) and we have been building SEDEX membership progressively across our supply base. We encourage all our suppliers, growers, manufacturers, and service providers to have:
Below are the essential requirements for all suppliers, growers, manufactures and service providers:
All suppliers are managed through the NWF Risk Assessment, which includes an Ethical Risk Assessment. We reserve the right to terminate our relationship with a supplier if issues of noncompliance with our policies are discovered and/or noncompliance is not addressed in a timely manner.
NWF policies clearly state that we will not tolerate forced labour (including human trafficking) or child labour in our operations or operations related to supply to NWF. We conduct internal and external audits to ensure compliance and operate the following policies that describe our approach to the identification of modern slavery risks, together with the steps to be taken to prevent slavery and human trafficking in our operations:
NWF will knowingly not use any individual or organisation to source and supply workers using practices of forced labour or human trafficking for labour exploitation. The Company will report any evidence or suspicion of cases of hidden third-party labour exploitation to the GLAA immediately. Failure by managers and leaders of the Company, third party labour providers or organisations in the labour supply chain to act upon concerns of worker maltreatment, coercion or harassment will be regarded as a gross misconduct offence or breach of contract and will be managed accordingly through the relevant disciplinary or contractual termination processes.
NWF encourages all its employees to report any concerns that raise suspicions related to human trafficking, both inside our organisation and through the supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. NWF's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees who have concerns can use our confidential helpline, which is managed by an independent thirty party organisation.
NWF will ensure that all staff responsible for directly recruiting workers are aware of issues around third-party labour exploitation and know how to identify the behaviour of victims. We ensure these staff have signed the Recruiter Compliance Document.
NWF will not use any individual or organisation to source and supply workers using practices of forced labour, human trafficking for labour exploitation, payment for work-finding services or any work-related exploitation such as forced use of accommodation. All employment agencies must be a member of the GLAA and have procedures in place to manage potential human trafficking issues.
NWF will confirm (through their own recruiting processes or through the recruiting processes of third-party agencies) that workers are not subject to any of the above practices and will report any evidence or suspicion of cases of hidden third-party labour exploitation to the GLAA immediately.
NWF 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. Regular audits of a random selection of agency workers, regular audits of each agency as well as audits of new agencies beginning to supply NWF are part of the processes by which risks of slavery and human trafficking are addressed in relation to agency workers.
Organisations may have other relevant policies to which they can refer, for example a corporate social responsibility policy, which should be accompanied by the steps taken to implement the policy and any examples where it has been used to address slavery and human trafficking risks.
NWF's Code of Conduct clearly communicates to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
NWF is committed to ensuring that our 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. NWF works with suppliers to ensure that they meet the standards of the code. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.
NWF Supplier Risk Assessments are required for all suppliers, regardless of their risk category. Where these assessments highlight a significant risk or breach of our requirements, an ethical audit will be required at the suppliers or growers' sites. This will either be conducted by an NWF representative or by a third party assigned by NWF. Failure to comply with these requirements or the principles of our ethical polices will result in the supplier being removed from the NWF approved supplier list and therefore no longer able to supply any materials to the company.
NWF undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:
NWF have an expectation that our suppliers will have systems in place to effectively monitor working hours, overtime and the number of seasonal workers returning or number of people leaving the company each year.
The organisation has and will continue to review its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015.
As a result, NWF:
Chief Executive Officer