MODERN SLAVERY ACT 2015 – TRANSPARENCY IN SUPPLY CHAINS
POLICY AND STATEMENT
- 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.
- 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.
- Tilda Ltd adopts zero tolerance to corruption and bribery and this policy is endorsed by our Board.
- We fully support the UK Government’s objectives to eradicate modern slavery, child labour and human trafficking.
- The main sources of brown rice, the company’s most substantial raw material are India or Pakistan for Basmati, Thailand, North America, Uruguay and Cambodia for other fragrant and long grain rice. We operate a zero tolerance approach to child labour throughout our supply chain.
- The market prices for grains are widely quoted and the system is very transparent.
- Our suppliers will be subject to regular audits to ensure that they maintain the required standards and actions will be determined by risk assessment.
- Our annual statement will provide information to supplement this policy, including details of our activities and supply chains and actions we are taking to support the Government in these objectives.
- We call upon all organisations we engage with to influence their global supply chains by improving transparency and accountability; and together we can help the Government eradicate the injustice and brutality of modern slavery and human trafficking.
Anti Slavery and Human Trafficking Statement 2018
- 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 2018.
- 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
- The main business of the company is the milling of brown (cargo) rice into milled rice; the manufacturing 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, Pakistan and Cambodia.
- Our purchases of rice are governed largely by standard contracts terms of the London Rice Brokers Association (LRBA).
- We expect all suppliers of rice and other ingredients, materials and services to fully comply with the Modern Slavery Act 2015 or its principles and to operate systems that are transparent, accountable and auditable, and free from ethical ambiguity. Our standard terms and conditions of supply include contractual obligations in this regard.
- 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.
- We require all recruitment and employment agencies that we use to hold a Gangmasters Licensing Authority Licence.
Steps taken by Tilda Ltd during the calendar year ending December 2018
A. Management Responsibility and General Awareness
- Reported progress on a regular basis to our senior management and the Board;
- Raised awareness of this published statement by notifying organisations of with which we regularly engage in our supply chain;
- Prepared the latest annual statement.
B. Risk Assessment
- We have undertaken a review exercise of our policy 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.
C. Risk Mitigation
- We have continued to update our compliance risk management process.
- 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 Rice Platform (SRP). This program includes socio-economic elements as part of its sustainable farm assessment tools. Its aim is to achieve constant improvement towards a more sustainable supply chain.
Steps to be taken by Tilda Ltd during the calendar year ending December 2019
- Continue to audit suppliers (new and existing) to ensure compliance;
- Remind our suppliers of our joint responsibilities under the Modern Slavery Act 2015; and
- Report progress on a regular basis to our senior management and the Board.
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.