Modern Slavery Statement 2019
JESTER CHICKEN (GREAT BRITAIN) LIMITED
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Jesters Chicken and other relevant group companies (“Jester Chicken”) from January to December 2019 prevent modern slavery and human trafficking in its business and supply chains.
OUR ORGANISATION AND OUR BUSINESS
We understand that modern slavery – whether slavery, servitude, trafficking or forced labour, is a continual and growing global issue that can be found especially in the agri-food sector in which we operate. At Jester Chicken, we’re determined to work towards a zero tolerance policy on modern slavery and human trafficking of any kind within our business or our supply chain. We have a responsibility to minimise any risk of this kind in any part of our business operations and in the event of an incident, we will address this promptly with all relevant parties concerned.
 This statement sets out the steps taken by Jesters Chicken Limited and its subsidiary company Jester Chicken (Great Britain) Limited which falls within the scope of section 54(2) of the Modern Slavery Act 2015 and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015.
OUR SUPPLY CHAIN
We are committed to conducting our business with the highest degree of integrity. We assure the quality of our products and the wellbeing of the people working in our restaurants and supply chain by maintaining a close stable relationship with our franchisees and our direct suppliers; managing performance and continuous improvement of quality, service, cost, innovation and risk management.
Direct suppliers means suppliers providing food, drink, non-consumables such as packaging, uniforms, equipment and machinery and construction services.
While we are confident that our internal centralised human resources processes for recruitment minimises the risk of modern slavery or human trafficking taking place within Jesters Chicken itself, our supply chain relies on our suppliers’ good ethical business practices. Open communication with our suppliers is critical for identifying and resolving any supply chain issues so that together we can respond rapidly and fully to ethical issues. Our supply chain teams have a duty to report any suspicions of poor supplier ethical behaviours immediately.
We have processes for the sourcing and management of our suppliers in order to minimise risk to our brand, the environment and the communities that our restaurants and supply chains impact.
We carefully select our direct suppliers, developing long term relationships with them that gives us the confidence that a global brand like Jesters Chicken demands in its supply chain. We are aware that parts of our supply chain are predominately resourced with a seasonal, low paid, unskilled workforce and that these industries can be at risk from the exploitation of workers and modern slavery. Whilst we are confident that our sourcing practices minimise this risk, particularly in relation to our direct suppliers, we know that risk can only be reduced if we are continually vigilant and demanding on our supply chain. In any instances where we feel there is unacceptable risk, we will contact our suppliers in writing, reminding them of our values and ethical standards, and reiterating the expectations we have when working with them. We contractually reserve the right to audit our Direct suppliers if the need arises.
All of our direct suppliers are contractually obliged to be able to trace food, drink and other non-consumables e.g. packaging, uniforms, furniture, print materials and paper products all the way back through the supply chain to the raw material origins. This can often be a complex matrix of multiple tiers of suppliers and facilities but we are confident that our suppliers can trace their products all the way back through every facility employing a work force. We expect them to have full details of each facility within their supply chain and provide us with the details should we wish to engage a third party to perform an ethical audit.
We work with our suppliers to ensure that they provide employment that is freely chosen and that they have in place policies, systems, risk assessment, training and measurement to ensure no forced labour or slavery exists. We also require that our suppliers allow employees the freedom to associate, organise and join a trade union (or collective bargaining group acting for them) in a lawful and peaceful manner without penalty or interference. We also factor this into our pricing strategy to ensure that our suppliers and franchisees are not incentivised to use cheaper, slave or bonded labour.
Ultimately, by working with our suppliers, our goal is to find ways to make a positive difference across our supply chain, from the grower or farmer right up to the team members in our restaurants. This is an ambitious and complex goal but we believe that through our robust policies and procedures and strong supplier relationships we can together drive and deliver a high standard of labour practices.
At Jesters Chicken we have a range of policies that together constitute our Modern Slavery Policy. These policies include our Supplier Code of Conduct and our Anti-Bribery Policy. All direct suppliers are contractually obliged to comply with these policies.
We offer a number of education programmes, such as apprenticeships, so we also have a Safeguarding Policy and Safeguarding Officer whose role is to safeguard our minors and vulnerable adults against any inappropriate behaviour.
Since our last statement we have issued the Sourcing Code of Practice (The “Sourcing Code”) to all of our Direct suppliers. This Code requires a high standard of compliance with internationally agreed standards of labour, applicable national laws and a commitment to work to continually improve workplace and employment standards. It is aligned with the International Labour Organisation (ILO) Convention and the UN Guiding Principles on Business and Human Rights.
It sets out defined social, ethical and environmental standards we require suppliers to follow as part of their agreement to supply Jesters Chicken. The Sourcing Code extends to all employees of those suppliers including contractors, temporary workers and other non-permanent staff, including any agency workers. All direct suppliers must comply with the Sourcing Code wherever they are based.
As part of their contract with us, suppliers are expected to establish management systems for delivering compliance with the Sourcing Code and to maintain records demonstrating this. We expect suppliers to be able to verify that all sub-contractors and companies in their own supply chain, which are in any way involved with Jesters Chicken products, are provided with the Sourcing Code and confirm, in turn, their compliance with it.
DUE DILIGENCE, RISK ASSESSMENT AND MANAGEMENT
We recognise the importance of being fully aware of the ethical and social practices and any associated risks in our supply chain. To ensure this, we undertake independent and third party audits of suppliers’ sites and thorough self-assessment questionnaires. All of our direct suppliers are required to register with SEDEX and complete Self-Assessment Questionnaires (“SAQs”). SEDEX is an ethical data exchange which ensures that ethical standards are monitored and measured, and best practice is shared across the industry.
We then use SEDEX to review the SAQs to enable us to make a risk assessment of suppliers. This risk assessment tool provides a modern slavery risk rating for each supplier facility and over the coming year, we intend to use this to determine whether we need to carry out any third party audits. Third party audits will be able to provide us with a neutral, unbiased and factual report that we then use in conjunction with the SAQs to provide a big picture review of the supplier.
The SAQs collect data across four key pillars:
– Labour Standards: includes questions on wages, working hours, children and young employees, freedom of association, non-discrimination, forced labour and human rights. This forms the basis of the data used for the modern slavery risk assessment rating.
– Health & Safety: includes questions on management, training, emergency and fire safety, and worker health.
– Environment: includes questions on environmental management, waste, raw materials, water, energy and pollution.
Business Ethics: includes questions on bribery and corruption.
The risk assessment tool helps us to prioritise those suppliers who need to make further improvements so we can help them to provide better working rights and conditions as appropriate.
We recognise that team members working for both Jesters Chicken equity and franchise owned restaurants must be treated fairly and with respect. They should be empowered to develop their skills and fulfil their potential. As a business we ensure that we comply with all applicable wages, benefits and hour laws and regulations, including those relating to minimum national legal standards or industry benchmark standards, overtime and maximum hours. We pay fair wages in line with the norms for the industry and market and do not require anyone to work excessive hours, particularly where this might impact personal health or safety; overtime shall be voluntary.
We have a number of general policies and procedures that support our statement and position onf modern slavery and human trafficking throughout the different areas of our business, including the following
– Recruitment Policy;
– Equal Opportunities and Dignity at Work Policy;
– Whistleblowing Policy;
– Anti-bribery and Corruption Policy;
– Business Conduct Policy; and
– Employee Handbook
We intend to implement a modern slavery reporting mechanism, whereby our employees, suppliers, business partners, customers and other interested parties can raise any genuine concerns or suspicions that they may have about our procurement, recruitment or working practices, in complete confidence. The implementation of this reporting mechanism should be completed in the coming financial year.
TRAINING AND CAPACITY BUILDING
We know that our employees are crucial to helping ensure that modern slavery is removed from our operations and supply chain. Each and every one of our employees has a duty to report any practice they’re worried about so that we can take steps to stop it happening. We know that this can be personally challenging so we’ve provided and publicise a completely confidential helpline called “Speak Up” to encourage our employees to whistle-blow in safety. Our employees are expected to report any suspicions or wrong doing in this way and management are expected to act upon such concerns.
Employees are also subject to a Business Conduct & Ethics Policy, including the Business Code of Conduct which includes conduct in relation to
– Fair treatment of customers and suppliers
– Gifts and conflict of interest
Jesters Chicken has an annual compliance training programme in relation to anti-bribery and the Business Code of Conduct. We are proud of our training standards, and we are currently assessing our compliance training programme to see where we can make further improvements and extend Modern Slavery awareness training.
This statement has been approved by the board of directors of Jesters Chicken Limited.
CEO, 1 AHY Limited T/A. Jesters Chicken