Modern Slavery Act

2017/18 Modern Slavery Act Transparency Statement (“MSATS”)

Introduction

This is the third MSATS made by T&L Sugars Limited.

This statement will update on our work on modern slavery during 2017/18, particularly in the context of the objectives we set ourselves for the year in our last statement. The statement also sets further objectives for our work on modern slavery during 2018/19. For brevity we will not re-state the statement about our business or the detail of our policies to identify and eradicate modern slavery. These remain unchanged and can be found in our 2015/16 and 2016/17 statements, which will remain online for the purpose of full transparency.

Update on 2017/18 progress

2017/18 saw us make further solid progress on implementing measures to prevent modern slavery in our business. Below we outline the objectives we set ourselves and how we performed against each.

Objective 1 – We will aim to grow the percentage of our sugar supplies that have undergone an independent and physical ethical and environmental audit over the previous three years to over 95% during 2017/18.

We were on target to hit the 95% objective until business needs meant we had to purchase raw cane sugar from a new supplier during the year. The new supplier committed to our ethical sourcing policy but we have not yet been able to conduct an independent audit of that supplier. This meant that the percentage of our sugar produced by suppliers that have undergone the independent audit remained unchanged at 81% during 2017/18. Although the new supplier is yet to be audited we know that the supplier is working on projects to prevent forced labour within their own farmer supply chains.

Objective 2 – We will aim to encourage 25% of our sugar suppliers to run modern slavery training for their workforce during 2017/18.

2017/18 was the first year that we had undertaken this. We were able to encourage one supplier that accounts for 17% of our supply to run the training. Our experience was positive. It was difficult and complicated to organise, but we learnt a lot from it. We were extremely pleased to be able to secure two expert trainers from the International Labour Organisation (“ILO”) who travelled internationally to lead the 2-day training workshops at an independent location in the supplying country. We trained 82 members of the industry from the farming community, the sugar mill and Government officials in the country that supplies us. The key learning for us was how well engaged attendees were but, also, that it generated a responsibility to follow up with the issues that were identified.

Objective 3 – We will work towards ensuring any of our long-standing non-sugar suppliers that have not yet actively committed to our ethical sourcing policy to do so.

In our 2015/16 statement we explained that we had 1,100 long-standing non-sugar supply relationships that pre-date the introduction of our 2012 Ethical Sourcing Policy that all new suppliers are required to commit to. Our work during 2016/17 and 2017/18 means that we have just 79 of these suppliers left to engage with on committing to the policy.

Objective 4 – We will include modern slavery training for new starters in the business who will be in positions with the potential to recognise indicators of modern slavery.

We conducted a number of training sessions with relevant staff, delivered by Stronger Together, in 2015 and 2016. During 2017/18 we have also taken steps to incorporate modern slavery training as a systematic part of our regular training programme. This will be through a training module provided by Stronger Together that relevant employees will be required to take on an annual basis. We have also developed a protection protocol that sets out how to protect potential victims, the evidence and other colleagues in the event that there is suspicion of this crime within our business and its supply chains.

Our 2018/19 objectives

During 2018/19 our objectives for preventing modern slavery include:

Objective 1 – Independent and physical ethical and environmental audits are part of our regular duty of care. We will continue to aim for 95% of our suppliers having been audited over the last three years.

Objective 2 – We would like to move the 2017/18 work on supplier training one step forward by introducing a whole value-chain approach. Our target is to run one meaningful project on modern slavery prevention involving not only a supplier, but a customer as well, to enable us all to learn from each other about modern slavery prevention.

Objective 3 – We have a comprehensive procedure to minimise the risk of modern slavery on the bulk shipping vessels that transport our raw cane sugars from origin. This includes chartering vessels exclusively from a small pool of high quality vessel owners. During 2018/19 we will engage directly with these owners to understand what progress they are making to further reduce the risk of modern slavery in their fleets.

Gerald Mason

Director

T&L Sugars Limited

This statement was reviewed and approved by the Directors of T&L Sugars Limited on 29 March 2019.