Lakshmi & Sons T/A Cofresh Modern Slavery Statement

Our Aims and Commitment

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that Lakshmi and Sons T/A Cofresh Snack Foods has taken and is continuing to take, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Lakshmi and Sons have a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically, with integrity and transparency in all business dealings to putting effective systems and controls in place to safeguard against any form of modern slavery.

Our Business and Supply Chains

Lakshmi and Sons T/A Cofresh Snack Foods core business is the production and supply of Asian Snack Foods and supply healthier ‘Eat Real’ range. We have a wide range of products which we distribute both in the UK and Internationally between our two brands and World Foods Frozen range which is traded goods.

In the financial year of 2019, we had an annual turnover in excess of £44m.

We are a member of SEDEX (Supplier Ethical Data Exchange) organisation committed to the improvement of ethical and responsible practice. We review all annual audits and endeavour to ensure that all suppliers are compliant with all local standards and laws of their country.

Policies and Processes

We operate a number of internal policies to ensure that we are conducting our business in an ethical and transparent manner. These include:

• Our Senior Managers are responsible for putting in place and reviewing policies and the process by which they were developed.
• Investigations/due diligence: Our Managing Director is responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
• Whistleblowing policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for employees, customers or others who have concerns to raise disclosures without fear of reprisals.
• Employee code of conduct: The Company's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The Company strives to maintain the highest standards of employee conduct and ethical behaviour regardless of location
• Supplier code of conduct: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the Modern Slavery Act and improve their worker's working conditions. In the event of serious violations of the organisation's supplier code of conduct this will lead to the termination of the business relationship.
• Recruitment policy: We operate a robust recruitment policy, which includes conducting eligibility to work in the UK checks for all employees safeguarding against human trafficking or individuals being forced to work against their will. Our organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due Diligence

TWe undertake due diligence when considering taking on new suppliers and review our existing supply chains on a periodic basis. Our due diligence and reviews include:

• Mapping the supply chain to assess particular product or geographical risks of modern slavery and human trafficking
• Evaluating the modern slavery and human trafficking risks of each new supplier
• Conducting supplier assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified
• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the immediate termination of the business relationship.

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Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified
• No customer complaints are received
• Compliance levels from 3rd Party requirement and our own ethical audit system

Awareness-Raising Programme

As well as training employees, the organisation will raise awareness of modern slavery issues by circulating information to employees.

• The information explained to relevant employees:
• The basic principles of the Modern Slavery Act 2015;
• How employers can identify and prevent slavery and human trafficking;
• What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• What external help is available, for example through the Modern Slavery Helpline (08000 121 700)

This statement has been approved by the Managing Director on 31st December 2019 and will be reviewed annually.