Our Modern Slavery Act Compliance Statement

HAYWOOD & PADGETT LTD MODERN SLAVERY ACT

COMPLIANCE STATEMENT 2022/2023

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This statement is published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps which Haywood & Padgett Ltd have taken during the financial year ending 31^st October 2023 to prevent modern slavery and human trafficking in its operation and its supply chains.

Haywood & Padgett Business and Supply Chains – An Overview

We are the largest scone supplier in Britain, selling scones and a variety of other bakery goods. We are based in Barnsley, England. We employ over 120 people, and we work with numerous suppliers across our supply chain. We supply most of the major UK supermarkets along with convenience stores and other discount retailers in the UK. Whilst we do export our products, the majority of our business and our operations are in the UK.

Whilst we have a significant number of suppliers, the majority of our expenditure is with companies in the UK or European Union. These countries are inherently lower risk from a modern slavery perspective.

As might be expected from a business like Haywood & Padgett, the supply chain is diverse. In order to manufacture and distribute our products we rely on a wide range of suppliers including: –

• Agency labour to cover sick leave and other absence
• Utilities to help fuel our ovens and keep our bakery running
• Flour and other raw materials to make our products
• Packaging to package our products
• Hauliers to get our products to store
• Laundry services for our workwear and cleaners for our bakery
• Software and IT equipment to keep a record of what we do and to help receive orders from customers
• Professional advisors to help us meet our legal duties and to keep on top of our engineering requirements

We recognise that the nature of modern slavery risks will be different for each of these types of suppliers. We describe below some of the steps we take to ensure there is no modern slavery either within our own business or the supply chain. However, due to our systems and processes we consider our own employed workforce to be at low risk and we also consider our direct suppliers of utilities, professional services, software and technology, engineering parts and similar suppliers to also all be low risk. Many of our other suppliers are also low risk because they are either U.K. or EU based, and they are not within sectors which are known for being exposed to modern slavery.

As a long-standing company, many of our suppliers are well known to us and they have worked with the business for a long period of time.

Our procurement and technical team work collaboratively to ensure that we buy products with ethical sourcing as one of the key pillars of our approach.

Policies in relation to Slavery and Human Trafficking

We build our business on the basis of five core values – integrity, accountability, passion, humility and simplicity – which shape everything we do, both inside and outside the company. As such, we are committed to achieving the objectives and requirements of the Modern Slavery Act. Through our policies and procedures, we strive to ensure that there is no place in our operation or our supply chain for modern slavery.

With regard to our own operations, we have a structured HR function and a range of policies and procedures that are designed to ensure we comply with legal requirements for our workforce. New employees are required to prove that they have a right to work in the UK. All employees are paid directly to their nominated bank account. We are satisfied that our existing employment practices and procedures continue to comply with legal requirements including in relation to modern slavery and human trafficking. The checks that we have in place have revealed no issues during the financial year.

We also operate a whistleblowing helpline which allows people to raise any concerns they might have regarding our operations and compliance with the law. No concerns have been raised through the helpline in relation to slavery or human trafficking.

We have a Supplier Code of Conduct, and this requires suppliers to comply with standards based on the ETI base code. Compliance with our Supplier Code of Conduct (or standards at least equivalent to them) is a material term of our contracts. There are no direct suppliers that have either refused to adopt our Code of Conduct or failed to demonstrate that they have a Code to at least the same standards. No supplier has reported any breaches of the Supplier Code of Conduct in the last 12 months and no supplier has raised any related concerns.

There has therefore been no requirement to undertake any investigations in the last financial year regarding any modern slavery concerns (none having been raised).

Finally, we include the Supplier Code of Conduct within our on-boarding process for direct suppliers. We are continuing to develop our on-boarding process and will continue to take a multi-faceted risk-based approach to supplier selection and review.

Due Diligence Process in relation to Human Trafficking in our Business and our Supply Chain and steps taken to manage and assess risk

In addition to our Supplier Code of Conduct, we use Sedex to assess our own business practices and those of certain suppliers in our supply chain.

As part of our Ethical Sourcing approach, we regularly review our supply chain to assess for any potential risks. Where potential risks are identified, measures are put in place to mitigate these risks.

None of our suppliers fall into a high-risk category.

Regular checks and audits of our agency labour providers have been carried out based on Gangmasters & Labour Abuse Authority guidelines.

Training on modern slavery and trafficking

Our HR department have received ‘Stronger Together’ training on ‘Tackling Modern Slavery in UK and Irish Businesses’ and ‘Introduction to Responsible Recruitment’

Our Purchasing department have received external training on ‘Product Defence for Procurement’ to enable them to identify and assess vulnerabilities in the supply chain.

Our Technical team have received external training to enable them to identify and assess vulnerabilities in the supply chain and the measures required to protect vulnerable threats

All employees and agency personnel watch the ‘Stronger Together Modern Slavery’ video at induction.

Future Improvements

In relation to our own business, checks have recently been introduced to provide additional reassurance that there are no signs of modern slavery within our own workforce. These checks include a search on whether there are any duplicate bank accounts for different employees or duplicate addresses for different employees.

We will also be focusing on continuing to embed our due diligence and risk assessment processes and having ongoing engagement with key suppliers in the areas of highest risk. We will consider bespoke training for relevant employees.

This statement has been approved by the Managing Director.

Wayne Padgett

Managing Director

Date: 23/10/2024