Modern Slavery Statement
In order to address the requirements of the Modern Slavery Act 2015, MM Flowers Limited has produced this statement to detail the controls in place and actions taken to identify and eradicate Modern Slavery and Human Trafficking within its operations and supply chain.
At MM Flowers Limited we believe that everyone should be treated with respect and dignity and that a workplace should be safe and fair. These principles are rights that should also be respected throughout our supply chains. We are constantly seeking to work with suppliers and customers that share our principles.
We supply leading supermarkets across the UK and Europe with a range of cut flower products into both retail stores and online platforms. In addition, our R&D activity is at the cutting edge of scientific and varietal developments which facilitates strategic relationships with our supply base.
Our raw materials are sourced from around the world, predominantly Europe, Africa and The Americas. Raw material sourcing strategies are based upon supplier risk, within which ethical standards are fundamental, along with quality and service.
Across our supply base, we broadly procure from three sources:
Directly Owned: The majority of our supply comes from farms which are directly owned and managed by our shareholders. We have a very close working relationship with the management teams and an increased understanding of the way in which people are managed. In many cases, these businesses have their own directly employed harvest teams which minimise the risks associated with temporary or transient labour sourcing.
Joint Ventures: Our shareholders have facilitated joint ventures with several large agribusinesses around the world. One benefit of these joint ventures is a better understanding of the partner’s business and a collaborative approach to mitigating risk.
Known Sources: The remainder of our raw materials come from other known sources and suppliers with whom we have chosen to develop strong relationships.
Our sourcing models and close commercial relationships ensure that we maintain a strong knowledge of how our suppliers operate their businesses. Further to this our directly employed technologists and commercial teams visit our growers throughout the year. When visiting our growers, they not only check on quality but take a proactive approach in identifying indicators of potential labour issues. This also means we are able to advise growers on best practice and help them make positive changes to their labour management practices.
Due Diligence & Monitoring
Our UK sites undergo independent third party Supplier Ethical Data Exchange (Sedex) Members Ethical Trade Audits (SMETA) every two years. Our agency labour provider is Gangmasters and Labour Abuse Authority (GLAA) licensed and is audited every six months by our People Team.
At all times, we remain alert to the risk of Modern Slavery within our supply chain. We encourage suppliers to identify risk within their own business. Should there be instances of Modern Slavery within our supply chain which we ought to know about, we have the following controls in place identify it:
- Sedex: we ensure that as a minimum all supplying sites are registered on Sedex and have completed the Self-Assessment Questionnaire (SAQ). We monitor responses to key questions within this which are indicators of risk.
- Supplier Due Diligence Packs: these set out the standards that we require of our suppliers. These packs detail what we require of our suppliers to ensure that any cases of Modern Slavery are identified and reported to us to help resolve.
- Sedex Members Ethical Trade Audits (SMETA): We carry out supplier risk assessments to identify SMETA audit requirements. Should non-compliances be raised during audits our team works closely with the supplier to take action. We share best practices to resolve issues as quickly and effectively as possible.
- These methods of highlighting and resolving issues have proven to be effective and strengthen our relationship with our supply base. In many instances, we will gain a better understanding of our supplier’s issues and help to develop their management system.
We conduct annual risk assessments for all supplying sites. This determines where SMETA audits are required and at what frequency. This risk assessment focuses on 5 key areas:
- 1. Management systems
- Any accreditations & knowledge from historic site visits
- 2. Length of relationship
- 3. Country
- Based on independently identified high, medium and low risk countries
- 4. Labour
- Provision of worker accommodation
- Use of agencies/labour providers
- Existence of worker committees and/or unions
- Any previous issues raised related to worker welfare
- 5. Previous ethical history
- Audits already visible on Sedex
To ensure accuracy, this risk assessment is carried out by a member of the Sustainability team in conjunction with Technical colleagues. This is to ensure that there is knowledge from an ethical perspective coupled with the knowledge of a colleague who has visited the site and worked with the management teams at the sites.
Policies and practices
Our approach on ethical issues is aligned with that of our customers and their policies and codes of practice. More specifically, issues of modern slavery and trafficking are addressed through our implementation of the Ethical Trade Initiative (ETI) Base Code and requirements of Sedex or Sustainability Initiative South Africa (SIZA).
MM Flowers Limited internal policies include Terms and Conditions of Supply. In these suppliers are required to comply with all applicable laws and policies as a minimum. If any suppliers do not meet these terms they would be delisted and supply terminated.
Our policies and practices include:
- Ethical Requirements which state suppliers must comply with the ETI Base Code. Suppliers are required to declare conformance and ability to provide evidence of compliance to this requirement
- Ethical Sourcing Principles
- Whistleblowing Policy for our UK employees
- Employee Assistance Program
- A pro-active approach to Ethical audit non-conformances
- Use of a single agency within our UK businesses
- Use of GLAA registered agency labour provider in the UK
- Bi-annual audit of UK labour providers using Complyer audit tool
Key members of MM Flowers Limited HR and Sustainability teams have attended the Stronger Together UK Modern Slavery workshop. Further to this, a sister company hosted a bespoke Stronger Together workshop on tackling modern slavery in the supply chain. Colleagues, including Board members from UK and international parent and fellow businesses, came together to further understand the issue of Modern Slavery and discuss current and future plans to address these issues.
Within our UK businesses, each employee’s induction includes a section on understanding Modern Slavery and Human Trafficking issues.
Assessment of Modern Slavery risk within our supply chain
We have not identified areas of significant risk or instances of Modern Slavery within our supply chain. However, we recognise the possibility of risks developing due to the impact of external factors such as armed conflict, migration and climate change impacts on people.
The use of labour providers throughout our supply chain is an area we will seek to understand more in the coming years, given the potential risk of modern slavery and labour exploitation.
To maintain knowledge of current and developing global issues the Sustainability Team conduct horizon scanning. This includes inputs from several professional bodies, charities and NGO’s. Notably, these include:
- Human Rights watch
- Stronger Together
- Ethical Corp
- UN SDG News
Where sourcing takes place from countries with identified risks, we have collaborated with other suppliers, customers, growers, NGO’s and local government to help identify and support new ways of working.
We are founding members of The Global Cut Flowers Production Network Project which was launched by Coventry University in 2017. Our work is to investigate how the promotion of ethical flowers can contribute to improving working conditions in supply chains.
Given the complex nature of Human Rights issues, we see the following actions as key to our ongoing commitment to eradicating Modern Slavery from our supply chain.
- Utilise existing data and insight channels to identify hot spots in which to focus attention and activity to the greatest effect
- Identifying opportunities for pre-competitive collaboration on country, regional and sector wide challenges to labour standards
- Work to further understand our supplier’s ability to detect and act on instances of Modern Slavery, sharing best practice and developing knowledge.
- Formalise specific training requirements for key roles within the business related to Human Rights and Labour standards
- Developing MM Flowers Limited Global Sourcing Principles taking account of Modern Slavery and Human Trafficking issues.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of the Company on 27 June 2019
MM Flowers Limited