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This statement is made in accordance with the Modern Slavery Act 2015. It sets out the Group’s actions to understand potential modern slavery risks related to its business and the steps taken to ensure that modern slavery is not taking place. It is the Group's intention to review and update this statement annually. This statement covers the activities of Group companies.
The Group’s business comprises of approximately 200 food, drink and non-consumable suppliers. Our supply chain is diverse and extensive, made up of local, national and international suppliers.
We are developing a number of policies to ensure that we continue to conduct our business in an ethical and transparent manner. Our aim is to ensure that all of our suppliers undergo assessment of their quality and ethical control procedures, including all relevant certifications to provide insight to the risk. Overall responsibility is delegated to our Chief Financial Officer and thereon specific tasks are cascaded to departmental heads for implementation. We are committed to continuously improving our practices to identify and eliminate any slavery or human trafficking and to acting ethically and with integrity in all business relationships. Further external support is provided by our third-party quality assurance company who have expertise in ethical sourcing.
The Group’s commits to taking measures to ensure that there is no slavery or human trafficking within its supply chains or any part of its business. We have implemented the following policies to ensure that our business is conducted in an ethical and transparent manner and to endeavour to achieve these goals: -
1. Recruitment policy. To safeguard against human trafficking or individuals being forced to work against their will, we operate a robust recruitment policy, including checks on eligibility to work in the UK for all employees. Managers are trained on this regularly and we work with specialist lawyers to ensure all employees have the proper documentation. On the rare occasions when we require temporary/contract workers, we will only work with agencies who assure us that they do not outsource the selection and management of their employees. We have written commitments from all agencies who provide temporary workers that they will not outsource to third parties.
2. Whistleblowing policy. We operate a confidential whistleblowing policy so that all employees can raise concerns about treatment of colleagues, or practices within our business or supply chain, without fear of retribution.
3. Code of Business Conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
We are in the process of developing and updating the process of developing other policies including: -
1. Anti-slavery policy. Alongside publishing this statement to all employees we will also explain how employees can identify instances and where they can go for help.
2. Supply Chain Charter. This will include our social responsible values, commitment to conduct business ethically with integrity and without slavery, and child labour policy. It will set out our stance and requirement with respect to modern slavery and the pro-active measures we require our suppliers to comply with.
In order to measure our effectiveness in tackling modern slavery, the Group continues to monitor relevant key performance indicators including those suppliers with Modern Slavery Act statements. We recognise that our biggest exposure to modern slavery lies within our product supply chain and for this reason we have a number of initiatives under way. These include: -
1. Supplier risk assessment of quality and ethical control procedures, certifications and policies.
2. Industry/sector risk mapping to take account of country location and highlight the greatest risks and prioritise attention.
3. Supply Chain Charter - to define, implement and monitor the application of our ethical values and principles. Our aim is to prioritise the implementation of our Supply Chain Charter and provide transparency.
Our supply chain charter will also include a preferred supplier list which includes:
• Online/desktop vetting of the organisation to assure compliance.
• Site audit verification of working conditions and the provision of decent work.
We will require all of our suppliers to confirm acceptance of our Supply Chain Charter terms and conditions with the expectation that they take ownership by implementing their own policies and systems to monitor their suppliers.
In addition, suppliers will be required to confirm that:
1. They have taken steps to eradicate modern slavery within their business.
2. They hold their own suppliers to account.
3. UK based suppliers pay their employees at least the national minimum wage / national living wage.
4. International suppliers pay their employees the minimum wage applicable to local and national law.
For those suppliers identified as high risk, we will either source alternative products from a low risk source, or our third-party auditors will be requested to conduct supplier assessments, monitor improvements and progress towards the required standard. Audit scope will include a review of working conditions, sub-contracting, the application of policies, procedures and assessment of supplier operations
We will make it known that should a breach come to light, we reserve the right terminate the contract.
All policies are approved by the Gordon Ramsay Restaurants Limited board of directors and reviewed at least on an annual basis.
Overall responsibility for compliance is delegated to the Chief Financial Officer and relevant tasks are cascaded to department heads including IT, HR, Marketing, PR and Operations who have responsibility for suppliers within the business.
The Group will conduct regular training for all procurement team members and relevant staff, so that they are aware and alert to the signs of modern slavery and to enable them to take appropriate remedial action if they suspect that it is taking place. Guidance and support are offered to our suppliers to ensure that they fully understand the significance of the issues outlined in our policies. We will continue to provide training to leaders in the business as appropriate.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group slavery and human trafficking statement for the financial year ending 31 August 2021.
This statement has been formally approved by the Directors of Gordon Ramsay Restaurants Limited.