Pensworth Modern Slavery and Human Trafficking Statement and Policy


16 June 2016


Our Policies on Slavery and Human Trafficking

Pensworth are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and control to ensure slavery and human trafficking is not taking place anywhere in our supply chains.


Supply Chain

Supply chain security and integrity is a crucial component of our business. Robust technical and traceability systems ensure that our products are responsibly sourced from suppliers whose values are aligned with our own.

The senior management team work closely with suppliers to build relationships, understand how their organisations operate and how they look after the welfare of their employees.

We continue to monitor, assess and mitigate the potential risks within our business and within our supply chains and will deal with any risk areas identified in line with the Home Office guidelines.

Pensworth’s suppliers are aware that as a Company we are not prepared to accept any form of exploitation.

As a Company Pensworth ensures that we know where our goods come from and can account for each step of the supply chain.


Due Diligence

As part of our initiative to identify and mitigate risk we monitor our ethical recruitment processes across the business and educate our Senior Team, Managers and all employees on the Company policy on ensuring that there is no evidence of modern slavery or human trafficking evident or linked to our business.

We only work with reputable recruitment agencies and ensure all our recruitment practices and procedures are communicated followed and individuals are freely allowed to work in the UK and are in possession of their own right to work documents.

We follow the Ethical Trading Initiatives Base Code in ensuring respect for workers within the organisation.

We audit our suppliers to ensure that they operate ethically and also comply with the ETI Base Code in relation to their workers within their organisations.


Risk Assessment Conclusions

Pensworth recognises the importance of taking action to combat modern slavery and human trafficking. During our financial year to 31st March 2016 we assessed this risk to workers in our business and supply chain and improved supply chain accountability. We are also committed to continuous improvement of our processes to tackle slavery and human trafficking.

We operate within the Milk Processing and Distribution sector, which is not identified as high-risk sector for modern slavery. We operate a strict supplier selection process and have a close knowledge of key suppliers with whom we have long-standing relationships. We source a large majority of our goods and services from the UK, in which regions modern slavery is not prevalent, but we recognise that certain goods/services and the countries from which they are sourced, may carry greater risk.

We have identified that it is necessary to carry out a review of our internal policies and procedures to ensure that there is no risk of slavery or human trafficking taking place.


As part of our ongoing initiative to identify and mitigate potential risk of modern slavery, we have:

  • Set up a team to manage supply chain compliance with anti-slavery values

  • Identified resources and tools to develop processes to tackle slavery/humantrafficking

  • Instigated internal audit of the Company’s employment policies and practices

  • Started a risk assessment of our first-tier supply chains by classifying suppliersaccording to the risk factors set out

  • launched a consultation of suppliers classified as higher risk to assess the modernslavery risk in their business and their standards to ensure it does not take place

  • We have introduced an Anti-Slavery and Human Trafficking Policy

  • We have Whistle-blowing and Grievance Policies in place to protect employees


Where appropriate, we intend to take the following further steps to combat slavery and human trafficking:

  • Put in place appropriately targeted training on the risks the business faces from modern slavery in its supply chains

  • Assess the modern slavery risks in lower tiers of our supply chain

  • Introduce a Supplier Code of Conduct and related supply chain complianceprogramme

  • Use key performance indicators to measure our effectiveness in tackling slavery and human trafficking



The following policies assist the organisation to assess, prevent and mitigate the risk of modern slavery existing in the organisation and its supply chains:

  • Modern Slavery policy

  • Ethical trading policy

  • Recruitment policy

  • Procurement policy

  • Supplier code of conduct

  • Employee code of conduct

  • Grievance and whistle-blowing policies

  • Training policy



As part of our training process we educate our Senior Team, Managers and all employees on the Company policy on ensuring that there is no evidence of modern slavery or human trafficking evident or linked to our business. We include information on eradicating modern slavery within our induction processes and employee handbook.

This statement is made further to comply with the transparency provision of the Modern Slavery Act 2015 (section 54(1)) and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2016.



This Statement has been approved by the company’s Board of Directors.

Managing Director, Arthur Dunne