Modern Slavery Act 2015 – Policy and Statement




Tilda Ltd – Policy


  1. The principal business activities of Tilda Ltd are: the purchase of rice; the milling of brown (cargo) rice into milled rice; the manufacturing of ‘ready-to-heat’ flavoured rice pouches and the sale of broken rice and other by-products of the milling process.
  2. Tilda Ltd is committed to the highest level of ethical standards and sound governance arrangements, and sets high standards of impartiality, integrity and objectivity in relation to the management of its activities.
  3. Tilda Ltd adopts zero tolerance to corruption and bribery and this policy is endorsed by our Board.
  4. We fully support the UK Government’s objectives to eradicate modern slavery, child labour and human trafficking.
  5. The main sources of brown rice, the company’s most substantial raw material are India or Pakistan for Basmati, Thailand, North America, Uruguay, Vietnam, and Cambodia for fragrant and long grain rice. We operate a zero tolerance approach to modern slavery.
  6. The market prices for grains are widely quoted and the process is very transparent.
  7. Our suppliers will be subject to regular audits to ensure that they maintain the required standards and actions will be determined by risk assessments.
  8. Our annual statement will provide information to supplement this policy, including details of our activities, supply chains and other actions we are taking.
  9. We call upon all organisations we engage with to influence their global supply chains by improving transparency and accountability; and together we can help eradicate the injustice and brutality of modern slavery and human trafficking.


Tilda Ltd

Anti-Slavery and Human Trafficking Statement 2016


  1. This statement sets out the actions taken by Tilda Ltd to understand 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 taken during the calendar year ending December 2016.
  2. As part of the UK Rice Association (RA), the Federation of European Rice Millers (FERM) and a member of the All India Rice Exporters’ Association (AIREA), the company recognises that it has a responsibility to take a robust approach to slavery and human trafficking. It is absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.


Supply Chain Policy

  1. The main business of the company is the milling of brown (cargo) rice into milled rice, which is then sold into various customers; the manufacturing and sale of ‘ready-to-heat’ recipe rice pouches and the sale of broken rice and other by-products of the milling process. The main sources of our rice are India, Uruguay, Thailand, Vietnam, Pakistan and Cambodia.
  2. Our purchases of rice are governed largely by standard contracts terms of the London Rice Brokers Association.
  3. We expect all suppliers of rice and other materials to operate systems that are transparent, accountable and auditable, and free from ethical ambiguity.
  4. Individuals with evidence of non-compliance with the Modern Slavery Act in connection with our supply chains are encouraged to report either to us or to the national authorities.


Steps taken by Tilda Ltd during the calendar year ending December 2016

  1. Management Responsibility and General Awareness

We have:

  • Agreed management responsibility for this policy and statement and received unanimous endorsement from our senior management and Board;
  • Raised general organisational awareness by briefing this policy and statement to key staff and suppliers and providing training to key staff on the Modern Slavery Act.
  1. Risk Assessment

We have:

  • Undertaken an assessment using our professional legal, technical and procurement teams to determine our risk exposure;
  • Established that our primary risk is association with suppliers in higher risk countries and service sectors;
  • We require all recruitment and employment agencies that we use to hold a Gangmasters Licensing Authority Licence.
  1. Risk Mitigation
  • Tilda Ltd is a full buyer/supplier (AB) member of the SEDEX ethical supply-chain auditing database. Sedex stores information on ethical and responsible practices covered by ILO Conventions, ETI Base Code, SA8000, ISO14001 and industry specific codes of conduct.
  • Tilda Ltd uses the information on the system to evaluate suppliers (who are required to become members of SEDEX) against these codes and the labour standards provisions in our corporate ethical code. In addition, physical audits are carried out from time to time.
  • Tilda Ltd is a member of the Sustainable Agriculture Initiative (SAI) Platform for European sourcing and the Sustainable Rice Platform (SRP) for the Asian region. Both of these programs include socio-economic elements as part of their sustainable farm assessment tools. Their common aim is to achieve constant improvement towards a more sustainable supply chain.


Steps to be taken by Tilda Ltd during 2017

  1. Management Responsibility and General Awareness

We will:

  • Report progress to our senior management and Board;
  • Raise awareness of this published statement by notifying organisations with which we regularly engage in our supply chain.
  1. Risk Assessment

We will:

  • Commence a review exercise of this statement against our activities to establish whether the approach we have taken follows emerging best practice by:
    • Assessing and interpreting any recent or emerging case law and best practice;
    • Benchmarking our activities against statements and action plans undertaken by similar public and private organisations;
    • Re-evaluating the risk of non-compliance as part of our progressive enrolment of suppliers into SEDEX and our ongoing audits of suppliers;
  • Introduce contractual provisions in our contracts with our suppliers, obliging them to adhere to anti-modern slavery principles and to accept our right to audit their activities and (where practicable) relationships.
  1. Risk Mitigation

We will:

  • Act promptly if and when a compliance breach has been identified or flagged. This could include terminating our relationship with the relevant supplier;
  • Continue to feedback lessons learned into the compliance risk management process.


This statement has been put together as part of our commitment to section 54(1) of the Modern Slavery Act 2015. It has been approved by the board of directors of Tilda Ltd, who will review and update it annually.