Modern Slavery and Ethical Trading Policy

Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

This Policy has been created to set our position with respect to Human Rights and to detect and prevent instances of Modern Slavery and Human Trafficking within our supply chain. These processes reflect Melon&Co Ltd commitment and proactive approach to these issues. This policy is also intended to help employees understand what Modern Slavery is and how suspected instances should be reported and to raise general awareness amongst staff.

Melon&Co Ltd recognises the responsibility to operate ethically and to monitor suppliers to ensure that they in turn operate ethically. This policy has been created to outline employee responsibilities when it comes to ethical trading and how we ensure our growers meet the ethical standards we require.

Melon&Co Ltd shall not enter business with any organisation, in the UK, or abroad which knowingly supports or is found to be involved in slavery, forced or compulsory labour, human trafficking, or servitude.

Responsibility

The technical team is designated to the review and updating of all Ethical policies as necessary and as a minimum annually. Policy updates shall be issued out to all members of staff. All Melon&Co Ltd employees are responsible for reporting suspected instances of Hidden Labour Exploitation and Modern Slavery if their suspicion is aroused anywhere through the supply chain - grower, transport, third party storage facilities etc. If a member of staff suspects that there is labour exploitation in our supply chain it should be reported to a Senior Manager, Technical Manager or C.E.O. immediately.

1. What is Modern Slavery?

Modern Slavery is a broad term used to encompass the offences of slavery, forced and compulsory labour and human trafficking. The term extends to slavery-like practices such as debt bondage, sale/exploitation of children and individuals being forced to work against their free will, forced and early marriage and descent-based slavery.

Hidden labour exploitation comes under the umbrella term of Modern Slavery. This the exploitation of job applicants and workers by third party individuals or gangs other than a labour provider or employer and without the knowledge of management. This form of slavery is often hidden well by the perpetrators, with victims reluctant to come forward for a variety of reasons.

The Modern Slavery Act 2015 consolidated the previously separated offences such as human trafficking, forced labour and hidden labour exploitation. It also works to effectively fight the offences under the new umbrella term of Modern Slavery. One way the act does this is to require businesses to be transparent about how they tackle potential slavery. This therefore encourages businesses to be more proactive in their deterrence and detection of offences.

Processes in place to deter and detect Modern Slavery in our business and supply chain

Melon&Co Ltd recognises our social responsibility to ensure that Modern Slavery is not active in our supply chain and we therefore follow the principles set out in the ETI (Ethical Trade Initiative) Base Code.

We ensure that our supply chain is following the Base Code by completing Risk Assessments and following these up with risk reducing actions. High Risk countries shall be subject to a third-party ethical audit and results made visible to Melon&Co Ltd technical department.

Risk Assessment

We have a robust system of Risk Assessment (Sedex Analytics) which pinpoints high risk areas so that we can effectively mitigate the risk of labour exploitation in our supply chain and business. Melon&Co Ltd have identified two areas within our supply chain which is at the greatest risk from Modern Slavery and Human Trafficking. These are Labour Providers to our growers and growers in High-Risk Countries.

These two areas have been identified as high risk due to them being out of our direct control and because we are, to a certain extent, reliant on the grower and their labour provider being honest about their ethical views, adherence to the ETI Base Code and adherence to their local employment laws.

In order to mitigate the risk of Modern Slavery and Human Trafficking from growers in high-risk countries Melon&Co Ltd:

• Requests that Supplier Approval Questionnaires are filled out by growers. These are translated into their first language where possible and include questions about Certification, Security and Ethical Management. Suspicious answers are investigated and could affect our use of the grower.
• Request that growers register with Sedex and complete their SAQ to 100%. Suspicious answers are investigated and could affect our use of the grower.
• Maintains good relationships with growers to encourage honesty and transparency.
• Requests that growers are SMETA audited according to their risk rating and when requested by customers.
• Conduct site visits when safe to do so. These are carried out by members of the Technical and Commercial teams.


We believe that these processes mitigate to the best of our ability, the high risk of Modern Slavery and Human Trafficking in these areas and would alert us to any possible instances while deterring possible cases.

3. Ethical Trading

Responsibility

Overall responsibility for Ethical Trade lies with the C.E.O and Technical Department.

The Technical Department have the responsibility to collate and study ethical due diligence of growers using the Supplier Approval Questionnaire, site visits, ethical audits and Sedex. If there is a potential serious ethical non-conformance the Technical Department have a responsibility to inform the C.E.O. and the senior management team.

Employees who procure and supply product must ensure that the ethical standards of the growers are taken into consideration when making business decisions. These will be discussed with the technical team.

5 Specific Supplier Requirements

We expect all our growers to conduct business ethically and to follow local and international labour laws. In order to ensure ethical trade throughout our supply chain we monitor supplier compliance by requiring suppliers:

• Comply with this Ethical Trading Policy which is based on the fundamental conventions of the International Labour Organisation (ILO) and national and international laws.
• Comply with the ETI Base Code, which is an internationally recognised code of labour practices that can be seen in the below “Policy Commitments” section of this Policy.
• Register on Sedex and complete the Sedex Self-Assessment Questionnaire (SAQ) to 100% with satisfactory answers.
• Complete a Melon&Co Ltd Supplier Approval Questionnaire which has a section on Ethical Management and requires disclosure of the labour providers used as well as a signature from the grower/supplier to ensure there is no bribery, corruption or ETI non-compliance.
• Fully engage with requirements we deem necessary, including where necessary third-party ethical audits and possible visits by Technical or Commercial department.

5 Policy Commitments

Melon&Co Ltd requires that all suppliers comply with the ETI Base Code and we commit to monitoring and ensuring that:

1. Employment is freely chosen

1.1 There is no forced, bonded, or involuntary prison labour.
1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

2. Freedom of association and the right to collective bargaining are respected.

2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
2.3 Worker representatives are not discriminated against and have access to carry out their representative functions in the workplace.
2.4 When the right to freedom of association and collective bargaining is restricted under the law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

3. Working conditions are safe and hygienic.

3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
3.2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
3.3 Access to clean toilet facilities and to potable water and, if appropriate, sanitary facilities for food storage shall be provided.
3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
3.5 The company observing the code shall assign responsibility for health and safety to a senior manager representative.

4. Child labour shall not be used.

4.1 There shall be no recruitment of child labour.
4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child.
4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.
4.4 These policies and procedures shall conform to the provisions of the relevant ILO standards.

5. Living wages are paid.

5.1 Wages and benefits paid for a standard working week meet, as a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event, wages should always be enough to meet basic needs and to provide some discretionary income.
5.2 All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time they are paid.
5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages -not provided for by national law- be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

6. Working hours are not excessive.

6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to
6.6 below, whichever affords the greater protection for workers. Sub clauses 6.2 to 6.6 are based on international labour standards.
6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week. * *International standards recommend the progressive reduction of normal hours or work, when appropriate, to 40 hours per week, without any reduction in workers’ wages as hours are reduced.
6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following. The extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay.
6.4 The total hours worked in any 7-day period shall not exceed 60 hours, except where covered by clause 6.5 below.
6.5 Working hours may exceed 60 hours in any 7 days period only in exceptional circumstances where all the following are met: • This is allowed by national law.
• This is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce.
• Appropriate safeguards are taken to protect the workers’ health and safety.
• The employer can demonstrate that exceptional circumstances apply, such as unexpected production peaks, accidents or emergencies.
6.6 Workers shall be provided with at least one day off in every 7-day period or, where allowed by national law, 2 days off in every 14-day period.

7. No discrimination is practised.

7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

8 Regular employment is provided.

8.1 To every extent possible work performed must be based on recognised employment relationship established through national law and practice.
8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour only contracting, sub-contracting, or homeworking arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contacts of employment.

9 No harsh or inhumane treatment is allowed.

9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. The provisions of this code constitute minimum and not maximum standards and this code should not be used to prevent companies from exceeding these standards. Companies applying this code are expected to comply with national and other applicable law and, where the provisions of law and this base code address the same subject, to apply to that provision which affords the greater protection.

Note: We make every effort to ensure that the translations of the ETI Base Code and the Principles of Implementation are as complete and as accurate as possible. However, please note that in both cases it is the English Language documents which should be treated as the official versions.

Justin Szymborski

C.E.O.

Contact numbers:
• The Modern Slavery helpline: Num - 0800 0121 700 (24 hours), Online Contact Form – https://modernslavery.co.uk/contact.html.
• Crimestoppers: Num – 0800 555 111, Online Contact Form – https://crimestoppers-uk.org/give-information/give-information-online/.
• The Salvation Army: Num – 0300 303 8151 (24 hour).
• Migrant Help: Num – 07766 668 781.