Introduction

This statement sets out the actions undertaken by e-foods to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 2024/2025.

As part of the Procurement sector, e-foods recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

E-foods is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensure that its supply chains are free from slavery and human trafficking.

Organisation Structure and Supply Chains

This statement covers the activities of e-foods.

  • The principal activity of EF-group is that of organising the supply and distribution of goods within but not limited to the following categories: food and beverages, workwear, cleaning/hygiene supplies, building and hardware supplies, electrical goods, tools, catering/plant equipment, print and technology solutions, recycling services and supply chain management
  • Our operations are currently taken up within the UK and Europe and across all industry sectors working with organisations who have single or multiple outlets, who require flexible delivery and invoicing options with the benefit of standardised pricing.

Using the following processes e-foods assesses whether particular activities undertaken are high risk in relation to slavery or human trafficking:

  • We complete a review of this policy and statement against our activities to establish if the approach we have taken follows best practice.
  • Assessing and interpreting any recent or emerging case law and best practice.
  • Benchmarking our activities against statements and actions plans undertaken by similar organisations.
  • Undertaking a second risk assessment using professional, legal, risk, procurement, and regulation teams to determine our risk exposure.

Where do we consider there to be a risk?

The principal categories which are considered to carry a risk are our suppliers whom we encourage to operate to the same ethical standards we employ ourselves.

Our Policies

e-foods operates the following policies that outlays its approach to the identification of modern slavery risks and steps to be taken to prevent human trafficking in its operations:

  • Whistleblowing Policy:  e-foods encourages all its stakeholders to report any concerns related to the direct activities of the company or its supply chain to e-foods HR. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. e-foods whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Employee Code of Conduct: e-foods code of conduct makes clear to employees the actions and behaviour expected of them when representing the company. e-foods strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.
  • Supplier Code of Conduct: e-foods are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. e-foods works with suppliers to ensure that they meet the standards of the code. Serious violations of e-foods supplier code of conduct could lead to the termination of the business relationship.
  • Supplier Terms and Conditions:
  • Recruitment and Selection Policy: Employment agencies are used, and e-foods will only use reputable employment agencies to source labour and will always verify the practices of any new agency it is using before accepting workers from that agency.

Due Diligence

e-foods undertakes due diligence when considering taking on new suppliers and customers and regularly reviews its existing suppliers and customers.  It embraces a range of actions which undertake to mitigate the risk of non-adherence to the Modern Slavery Act 2015:

  • All employees have received modern slavery training.
  • All employees are required to comply with e-foods policies and procedures in relation to their interactions with customers and suppliers.
  • All suppliers and contractors who contract with us under our standard terms and conditions must comply with our policies and procedures with specific contractual terms relating to compliance with the Modern Slavery Act 2015.
  • Due diligence completed during our tender exercises, Customer take on and supplier take on is recorded.

Training

e-foods intend to provide further training to our Compliance and Purchasing teams to ensure a high level of understanding of the risks of modern slavery and human trafficking within our supply chains.

As well as the training of key employees, e-foods will raise the awareness of modern slavery issues by conducting annual communication of the reviewed policy statement by email and notification boards both online and hard copy to all employees.

Approved by e-foods Ltd 13/11/24