Modern Slavery Statement

Modern Slavery and Human Trafficking Statement 2021/22

This statement is published in accordance with Section 54 of the Modern Slavery Act 2015,
extending to England and Wales. This statement aims to demonstrate the steps Keeling’s
International Limited (company number 01628818) has undertaken to prevent modern slavery and
human trafficking taking place within the business and supply chain for the company’s financial year
ending 24 th November 2022.

Modern slavery encompasses slavery, servitude and forced or compulsory labour. Human trafficking
is the arranging or facilitating travel of another person with a view to that person being exploited.

Structure and Supply Chains

Keeling’s International Ltd is the UK-based part of the Keeling’s Group, a family-owned company
based in County Dublin, Ireland. Keeling’s International includes an office and fresh produce packing
facility in Finedon, Northamptonshire with further offices in Essex and Cambridgeshire. The
company employs around 150 permanent workers with a peak of up to 80 agency staff.

The company’s main corporate activities include the sourcing, packing and supply of fresh and
prepared fruits, vegetables and salads to retail and wholesale markets in the UK. During the
2021/22 financial year, Keeling’s International sourced fresh produce from over a hundred suppliers
and grower groups. It is estimated that more than two thousand farmers and growers across twenty
countries supplied goods into the Keeling’s International supply chain during the year.

Policies on Modern Slavery

Keeling’s Company Values are set as People Matter, Integrity, Teamwork and Passion for
Achievement. These four pillars are central to all business activities. As such, Keeling’s International
has a range of policies designed to ensure the fair treatment of workers. These include the
following: Ethical Trading, Human Rights, Dignity in the Workplace, Grievance, Business Ethics,
Prevention of Hidden Labour Exploitation, Ethical Responsibility for Suppliers, Equal Opportunities,
Anti-Bribery and Fraud, Harassment, Personal Relationships at Work, Recruitment, Whistleblowing.
These policies are issued to all employees during induction and are available electronically at any
time on company servers.

Due Diligence Processes

Recruitment practices ensure all staff are legitimate and have the right to work. We ensure no
recruitment fees are accepted, original documents are not held by the company or any third party
and payments to directly-employed personnel are by bank transfer to their own accounts.

Posters are displayed around the Finedon site to remind staff of the ETI Base Code and detailing
whistleblower numbers to use in cases of suspected modern slavery.

Labour providers used are registered with the Gangmasters and Labour Abuse Authority (GLAA) and
regularly receive audits from them. The GLAA Active Check system is used to monitor the labour
provider’s compliance to GLAA rules. In addition, Keeling’s International conducts annual audits of
labour providers’ activities and holds interviews with agency workers at other times.

Suppliers are asked to sign and return a copy of our Ethical Responsibility for Suppliers policy. This
requires suppliers follow the ETI Base Code and become members of Sedex (Supplier Ethical Data
Exchange) unless based in the Republic of South Africa where SIZA (Sustainability Initiative of South
Africa) may be accepted. As members of Sedex, suppliers are required to link and share information
with Keeling’s International including responses to a self-assessment questionnaire based upon the
ETi Base Code, which should by updated twice annually. Depending on risk and customer
requirements, suppliers’ sites may be required to have second or third-party ethical audits. As an AB
member of Sedex, Keeling’s International is granted visibility of suppliers’ self-assessments and
third-party ethical audits, complete its own self-assessment and share information with retail and
food service customers. Additional background checks on new suppliers are carried out, including
web searches for records of current and historic malpractice in matters relating to human rights.

Packing operations at Finedon undergo a bi-annual third-party Sedex Members Ethical Trade Audit
(SMETA) against the ETI Base Code. The latest audit, completed in 2022, has no outstanding non-
conformances. In addition, a worker forum allows representatives across the business to be able to
voice concerns and play an active role in the welfare of their colleagues.

Keeling’s International engages with Stronger Together, a multi-stakeholder initiative aiming to
reduce modern slavery by providing guidance, resources, training and a network to employers,
labour providers, workers and their representatives.

Keeling’s International is a sponsor of the Spanish Ethical Trade Forum for Suppliers, a collaborative
initiative in the Spanish fresh food sector, encompassing suppliers, retailers and NGOs to address
commonly perceived labour issues such as managing migrant labour, sexual harassment and modern
slavery in a key sourcing region.

In 2019, Keelings International joined the Food Network for Ethical Trade (FNET) a multi-stakeholder
organization sharing best practice and working collaboratively to make changes in supply chains.
Particular involvement is within working groups looking at ethical engagement and risk assessment
and mitigation.

Keeling’s International is a member of the Fresh Produce Consortium which, together with Sedex
membership, interaction with consultants, peers, industry press and the GLAA, provide a level of
horizon scanning for issues occurring in the fresh produce industry.

Risk Assessment

Suppliers are risk assessed using the Sedex Risk Assessment Tool on a monthly basis and through use
of further risk assessment tools taking into account their global region, known historical issues and
length and size of the supply to the business. Based on the results of the risk assessment, suppliers
may be asked to undertake SMETA audits, receive second-party social audits, provide evidence of
compliance to social standards or mitigate for any risks identified.

Measuring Effectiveness

During the 2021/22 year, no known incidents of modern slavery were confirmed within the business
or its supply chain. There were no incidents of clandestine travelers found in vehicles supplying the
Finedon site with produce from the continent.

Keeling’s International are participating in the Stronger Together Progress Reporting Tool. This is an
online self-assessment tool designed to help businesses highlight progress made and identify next
steps in addressing modern slavery risks. It also allows businesses to benchmark against their peers.

Training of Staff

All permanent and agency staff are made aware of the risks of modern slavery during their induction

Within the senior management team, one person is a trained social systems auditor. A further three
members of the senior team have received external training in tackling modern slavery through
Stronger Together.

In November 2019, directors, buyers, technical managers, human resources and operational
management received Introduction to Ethical Trading Training provided by FNET. Further and
refresher training is planned during 2023.

Members of the management team regularly attend local and national forums run by retailers and
third parties to share good practice and learn from the practical experiences of peers in managing
modern slavery and trafficking in their supply chains.

The above is an accurate account of the activities undertaken by Keelings International Limited to
combat modern slavery in the 2021-22 year.

David Chalk, Technical Director
13 th December 2022