G’s Modern Slavery Statement 2019/20

The statement covers the activities of The Shropshire Group of companies in the UK up to 7th May 2020.

Introduction

G’s is aware of modern slavery risks andacknowledges its responsibility to abideby the Modern Slavery Act 2015. We arecommitted to establishing action plansto prevent slavery and humantrafficking within our own businessesand our supply chain.

We also endeavour to achievetransparency within G’s and with itssuppliers, and to focus on continuousimprovement. Moreover, G’s commits torespecting human rights and will avoidinfringing the human rights of others,addressing any issues that areidentified. This will include takingadequate measures for the prevention,mitigation and, where appropriate,remediation of incidences of modernslavery found in our business and in oursupply chain.

Structure of the Business

The Shropshire Group is a group offarming and food processing businesses,established in 1952. This Statementconcerns all companies within theGroup. These companies are as follows:

Barway Services LimitedCambs Farms Growers LimitedEast Coast Growers LimitedG’s Fresh LimitedG’s Fresh Beetroot LimitedG’s Group HoldingsLittleport Mushrooms LimitedG. S. Shropshire & Sons LimitedJ. B. Shropshire & Sons LimitedSandfields Farms LimitedThe Lettuce Company

Today, we supply all the major UKretailers, and many in Europe, withfresh salads, vegetables and preparedproduce. Across the Group, G’s policiesand management systems are aligned toour common values and to the aims ofethical treatment of those who work onour sites.

In addition to business units within theShropshire Group, this approach isextended across a wider sphere ofinfluence, including key suppliers andlabour providers.

The majority of our products come fromour farms, packhouses and foodpreparation facilities located in the UK,Spain, Czech Republic, Poland, Senegaland the USA. In most of these countries,our seasonal workers are directlyrecruited from abroad. Furthermore,G’s provides accommodation, socialactivities and welfare support on manyof its sites.

Supply Chain

In addition to our own sites, the Groupalso utilises a range of suppliers from 25different sourcing countries to ensureyear-round supply. Our top 10 sourcingcountries by gross sales value during thefinancial year 2019/20 were:

TOP 10 SOURCING COUNTRIES

UK SPAIN

SENEGAL EGYPT

MOROCCOITALY

POLAND GERMANY HOLLAND

PORTUGAL

1. G’s OWN BUSINESSES

The programme of risk reduction withinG’s own businesses can be summarised asfollows:

Firstly, to maintain and improverecruitment/onboarding processes and soreduce the likelihood of third-partiesarranging unofficial and hiddenrecruitment channels.

Secondly, to increase the likelihood ofdetecting any situation of suchexploitation via a programme ofwidespread training, combined withcentral data analysis.

Thirdly, to ensure that should any caseoccur, there is a clear procedure and lineof responsibility regarding immediate andlong-term response, in order both toprotect the victims and not endangerpotential future criminal cases.

Fourthly, to embed ownership of theprogramme at site level, in order toimprove engagement and effective policydevelopment.

Progress with these aims is summarisedbelow, as well as goals for 2019/20.

1.1 Prevention - Recruitment and Awareness

The greatest risk of modern slavery in ourbusiness is the occurrence of hidden third-parties engaged in the exploitation of ourworkers via debt bondage, threat,and housing control outside of G’s.Bearing in mind the general methodsemployed by third-party exploiters,certain procedural updates have beenimplemented to disrupt the efforts of suchindividuals as far as possible.

1.1.1 Awareness and Collaboration

On 31st January 2020, G’s hosted anIndustry Modern Slavery Conference. Withthe theme “Working Together to PreventModern Slavery”, this event gathered morethan 200 stakeholders from the private,public and third sectors. During the day,various breakout sessions were carried outto identify strengths and improvementareas in relation to modern slavery cases.

Further to this conference, G’s heldconversations with retail partners tolaunch a platform to share modern slaveryintelligence. Conversations will continuethroughout 2020/21, involving a widerange of industry stakeholders.

1.1.2 Mapping Recruitment Channels

G’s has formal HR procedures governingonboarding and recruitment to preventunlicensed gangmasters, illegal working,discrimination, and exploitation. Inaddition, these procedures aim to discoverand capture information about informalreferral in order to help identify covertlabour intermediaries.

During the period of labour shortagesproduced by the COVID-19 crisis, additionalefforts have been made to maintaincontrol over any direct recruitment, alsowith the aim of identifying potentialhidden labour intermediaries. Auditprotocols were amended to be appliedremotely.

All UK recruitment streams were riskassessed during 2019/20. Twelve planswere created upon those findings, with thegoal of reducing associated risks.

Control over recruitment fees andassociated costs incurred by job seekersrepresents a strategic goal within ourmodern slavery strategy. After mapping allassociated costs across the highest riskEuropean recruitment streams, we haveproactively shared our methodology withother industry peers and stakeholders, aspart of our collaboration within the FoodNetwork for Ethical Trade (FNET) workstream on recruitment fees.

In 2020/21 , recruitment riskassessments will continue to beexpanded in our non-UK operations.

Additionally, the ResponsibleRecruitment training module will beincluded in the role specific trainingrequirements hosted on the learningmanagement system and will bedelivered to more individuals.

1.2 Detection, Training and Monitoring

A coordinated programme has beenimplemented to detect any hiddenthird-party exploitation affecting thoseworking at our sites or in the areas inwhich we work. The core principles ofthis are to produce data regardingwarning signs and to process this dataeffectively.

1.2.1 Training

G’s delivers an awareness-level trainingmodule to key employees who are inregular contact with individuals whomight be at risk of exploitation.

Primarily, the roles identified includeteam/line leaders and those involved inrecruitment, accommodation, workerrepresentation and other key managerialroles. To date, 568 people havereceived this training.

More substantial ‘Modern Slavery for HRand Managers’ training has also beendelivered, either by the GLAA Academyor the G’s Group Ethics Team. So far,123 people have received this training.

1.2.2 Monitoring and Detection

Regular checks are conducted toidentify indicators that can lead to apotential case of exploitation.Investigations are conducted upon anyrelevant finding.

Our training and capacity buildingprogramme continues to play anessential role, promoting the use of ourreporting lines across our sites. Thisprogramme consciously sets “a low bar”for communicating any concerns to thebusiness. These training modules havenow been rolled out in our subsidiary inSpain.

In addition to our site and Groupgrievance mechanism, G’s provides twochannels to confidentially report anyconcern or suspicion. Internally, workerscan contact the G’s Group Ethics teamvia email or phone call. Externally, a

multilingual anonymous ‘Speak Up’platform is also available for reportingcases.

Significant numbers of ‘flags’ have beenraised in 2019/20.

In 2020/21, further efforts will bemade to continue embedding thissystem across the business in order toimprove the reporting frequency.

Our modern slavery programme will befurther rolled out in non-UKoperations, increasing the number ofindividuals reached.

1.3 Case Management and Victim Support

If a case of exploitation is uncovered orsuspected, it is crucial to manage thesituation effectively in order not toendanger the victim(s) or jeopardise anyfuture criminal case.

1.3.1 Case Management

Clear avenues of reporting any issues ofconcern are effectively advertised.Investigations are independently led byG´s Group Ethics team in coordinationwith the GLAA, and are based onrecognised practices with regard to casepreservation.

1.3.2 Victim Support

Site Champions are issued with guidanceabout how to manage any identified orsuspected victim. This is contained inthe Site Champions Handbook. Thisdetails how to support both potentialvictims who are awaiting support fromthe authorities, and those who havebeen identified and offered referral tothe National Referral Mechanism (NRM).

Individual situations are unique, so theprimary purpose of the procedure is toestablish a specific point of contact inorder to meet with the individual anddiscover their particular needs.

In 2020/21, internal victim supportguidance will be supplemented byformal procedures and case riskassessment tools.

1.4 Embedding

G’s has a Group Ethics team whichoversees the development of policiessuch as the modern slavery strategy.However, the team aims to embed allprocesses relating to ethical labourmanagement within the siteoperations themselves, to improveownership and effective policydevelopment.

1.4.1 Policy Development

In order to ensure that our anti-slaveryprocedures are effective and fullyimplemented, the company formed aModern Slavery Steering Group,composed of Human Resources andEthics teams. This group is consulted onrelevant procedure development and onhow procedures can best beimplemented in all areas of a diversebusiness.

New procedures have been implementedin other European subsidiaries tostandardise our management proceduresacross our international operations.

Regular benchmarking analyses werealso carried out to monitor thesuccessful implementation of ourmodern slavery policy framework in theUK. Each of our business units isbenchmarked against modern slaverycommitments. Improvements wereidentified in the areas set out below:

• Modern slavery training of workerrepresentatives

• Representation of agency workers insite workers committees

• Regular spot surveys of agencyworkers

1.4.2 Site Champions

Site Champions received comprehensivetraining in recognising and supportingvictims, they gained an in-depthunderstanding of the issues concerned.

In addition to providing awareness-leveltraining on their site, they areresponsible for driving forward theimplementation of relevant procedures,and are equipped to react appropriatelyif a case of exploitation is found, bothprotecting the victim and safeguardingany potential criminal case.

Throughout 2019/20, the role of SiteChampion has been reinforced withinthe UK businesses, as well as beingexpanded into non-UK operations Thereare currently 20 trained Site Championsin the Group.

Site Champions are also authorised todeliver our Awareness Level ModernSlavery in-house training, after receivinga one-and-a-half day training coursefrom the GLAA Academy.

In 2020/21 Benchmarking analysis willbe further rolled out in non-UKoperations.

In 2020/21, KPIs will be developed tomonitor and ensure consistentapplication of these procedures acrossthe Group. Further training will bearranged to maintain sufficientnumbers of Site Champions across theGroup.

2. LABOUR PROVIDER MANAGEMENT

Though direct employment is preferred,the G’s Group and some of its keysuppliers do, where necessary, utiliseagencies to supply labour. All of theseagencies are subject to significant duediligence, and steps are continuouslyundertaken to improve monitoring andaudit processes. These are detailedbelow, as well as ambitions for2019/20.

2.1 Audit Methodology and AgencyCapacity Building

In 2019/20, the Ethical team continuedto audit all labour providers delivering aservice to Group operations. The auditincludes a specific framework to riskassess the systems used to preventmodern slavery.

During the COVID-19 crisis, our LabourProvider Ethical Audit Framework wasrapidly adjusted. This has enabled us touphold our due diligence standards,while complying with all safetyguidelines issued by the respectivenational governments. Remote auditprotocols were designed to conduct pre-supply ethical assessments and fullethical audits to any new labourproviders.

All completed assessments feed into theKPI risk score for an agency. The agencyis given feedback in the form of anaction plan on how to reduce their riskscore. Labour users are also informed ofthe risk score of their agency to aidtheir choice of agency, thus promotingthe use of responsible agencies. In2019/20, this system has been expandedfrom the UK into our Spanish operations.

In 2020/21, the modern slaverysystems assessment will continue to beused to leverage improvement and willbe updated with emerging risk/bestpractice.

Specific and useable audit tools andrisk assessment for agencies in non-UKoperations will continue to be refined.

2.2 Agency Worker Voice

Agency workers continue to be targetedas a priority during any ethical duediligence process. These workers arealways interviewed at random while onsite as part of the internal audit cycle.

All sites run multi-language “spotsurveys” every season, which cover allagency workers on site.

During the COVID-19 crisis, existingreporting channels have beenstrengthened to improve their visibilitywithin the agency workforce. Newposters and additional supportingmaterials were developed to improvethe communication of all existingreporting lines.

In 2020/21, further efforts will bemade to improve communication withagency workers.

3. G’s SUPPLY CHAIN

We are primarily a producer business,but do use third party suppliers toensure constant supply throughout theyear. We have taken a number ofmeasures to ensure sufficient duediligence, including a comprehensiverisk assessment of the entire supplychain into the UK, down to growerlevel.

This covers all relevant mattersrelating to ethical labourmanagement, of which modern slaveryis a part. Nevertheless, risk factorsand mitigation strategies relatingspecifically to modern slavery areanalysed and employed, respectively.

3.1 Supplier Approval Procedure

All ethical due diligence requirementsfor suppliers are defined in the G’sFresh Supplier Approval procedure. In2019/20, this procedure was reviewedand strengthened.

As a minimum requirement, allprogrammed suppliers are requested tobe registered in the Supplier EthicalData Exchange (SEDEX) and to have fullycompleted its new Self-AssessmentQuestionnaire (SAQ). Reponses aremonitored and assessed to identifyindicators of risk of modern slavery.

During the first half of 2020, wesuccessfully completed the new SEDEXSAQ, providing greater transparency toour customer base in, among otherareas, supply chain management,monitoring systems or modern slaverymanagement procedures.

In 2020/21, all programmed supplierswill be required to complete a specificmodern slavery SAQ, designed toidentify areas of potential risk oflabour exploitation in our supplychain.

3.2 Supplementary Information regarding Modern Slavery Risks

Programmed fresh produce suppliers arerequested to undertake a specific SAQ,designed to cross-check SEDEX SAQs, aswell as highlight specific risk factors.These include factors relevant tomodern slavery risk factors, such asrecruitment practises.

Emergency/single use suppliers whichdo not have SEDEX are also risk assessedwith the same specific SAQ or by themproviding a GLOBAL G.A.P. RiskAssessment on Social Practice (GRASP)certificate. In 2019/20, 100% of ouremergency supply base conformed withthis requirement.

In 2020/21, additional efforts will bemade to increase transparency in ourGNFR (goods not for resale) supplychain. New risk assessment tools willbe developed upon these findings toflag-up potential indicators of modernslavery.

3.3 Capacity building and training in the supply chain

We have requested that all UKproduction sites in our supply baseundertake modern slavery training withStronger Together or an equivalentprovider. Over 60% of these suppliershave provided evidence of this to date.

We have remained an active contributorto various industry collaborativeinitiatives, sharing our knowledge andexpertise with other suppliers. In theUK, G’s actively participates in FNETwork streams on forced labour and riskassessment. In Spain, we alsoparticipate in the “Spanish Forums forEthical Trade” (SEFT), a stakeholderinitiative launched in our main strategic

sourcing area in the country. Amongother goals, this organisation providestraining and capacity building to a largenumber of suppliers located in SouthernSpain. In 2020, a working group led byG’s published an ethical handbook forethical management of labour providers.This handbook provides practicalguidance on reducing the risk of labourexploitation by responsibly managingemployment agencies within theagricultural sector.

In 2020/21, we will seek to increasethe proportion of suppliers receivingmodern slavery training in the UK. Wewill also seek to increase theawareness in this area in our widernon-UK supply chain.

This statement has been approved by John Shropshire, Chairman of G’s Fresh on 2nd July 2020. It will be reviewed

and updated annually.