Modern Slavery Act

2016/17 update to our Modern Slavery Act Transparency Statement (“MSATS”)

T&L Sugars Limited published our first MSATS for the financial year 2015/16. That statement will remain on our website. This 2016/17 statement will update on the progress we have made since that first statement. It will also remind users of the statement about our business, our policy to identify and eradicate modern slavery, and outline targets for 2017/18.

During 2016/17 we made good progress on improving the coverage of our core sugar supply chain ethical and environmental programme. This includes key elements aimed at identifying and eradicating modern slavery.

Sugar suppliers completing the SEDEX self-assessment tool rose to 76 percent (72 percent in 2015/16).

Sugar suppliers to T&L Sugars Limited during 2016/17 that were physically and independently audited under an independent ethical and environmental standard over the previous three years year rose to 81 percent (75 percent in 2016/16). Suppliers to our EU cane refineries more generally rose to 75 percent (69 percent in 2015/16).

In our 2015/16 statement we set ourselves a priority to review our non-sugar supply chains. That review found that we have around 1,100 long-standing supply relationships that pre-date the introduction of our 2012 Ethical Sourcing Policy that all sugar suppliers, as well as all new non-sugar suppliers since that date, commit to. Whilst being proud of these long-standing and stable relationships we recognise that we need to upgrade them to also commit to our Ethical Sourcing Policy. That work is now ongoing and we will report back on progress in our 2017/18 statement.

In our 2015/16 statement we also set ourselves the priority to continue to ensure our employees are able to recognise indicators of modern slavery and to know what action to take. We have decided to take that work one step further along our supply chain and are piloting a training session of the workforce in one of our sugar suppliers. This pilot is due to take place in the first half of 2018.

Our 2017/18 priorities for further work on modern slavery are:

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

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

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 do so.

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

Background to our business

T&L Sugars Limited is a leading UK supplier of cane sugars and syrups. These products are produced by us at our cane refinery in East London or, in some cases, purchased directly from suppliers.

Our primary raw material is raw cane sugar. This is purchased from some of the countries with which the European Union (“EU”) has trade agreements. These EU trade agreements cover just 5% of the total amount of sugar that trades globally. Prohibitive EU import tariffs make it uneconomic for us to import from other suppliers.

The majority of our raw cane sugar supply is purchased directly from producers with whom we have long-term relationships. In a small number of cases we purchase from intermediaries.

We believe that the highest risk of modern forms of slavery in our supply chain is in raw cane sugar sourcing. This is because this supply chain includes developing economies and some seasonal work.

Our policy

T&L Sugars Limited recognises that modern slavery is an abhorrent abuse of human rights. We work to ensure any potential form of modern slavery in our own operations or within our supply chain is identified and eradicated.

Any form of forced labour, slavery or human trafficking is specifically prohibited by our Code of Ethics and Business Conduct and our Ethical Sourcing Policy (ESP). We actively police compliance with our code and ESP by a four step process in our raw cane sugar supply chain.

Step 1 requires our suppliers to adhere to our Ethical Sourcing Policy. This is based on International Labour Organisation conventions as well as other internationally recognized standards.

Step 2 asks every raw sugar supplier to complete an annual self-assessment of their social and ethical practices using the Sedex Supplier Engagement platform. The assessment also covers compliance with labour, health & safety, environmental and business integrity standards. 76 percent of our raw sugar suppliers completed this questionnaire in 2016/17 (72 percent in 2015/16).

Step 3 selects specific suppliers to participate in an independent sustainability audit against the ProTerra Standard, an internationally recognized social responsibility and environmental sustainability standard. For our UK operations, 81 percent (76 percent in 2015/16) of our cane sugar suppliers were audited in the 3-year period up to and including 2015/16 against the ProTerra standard, or certified against a comparable standard. These suppliers provided 75 percent of our EU sugar supply during 2016/17 (69 percent in 2015/16).

Step 4 sees us encouraging and supporting our suppliers to improve in areas of non-compliance.

A number of the suppliers from which we source our sugar are Fairtrade certified. Fairtrade certification is based on regular audits of small holder operations against the Fairtrade standard which prohibits forced labour, slavery and human trafficking.

Within our own operations, our workforce is mostly permanent employees. Our use of temporary employees depends on seasonal peaks in demand for our products but has not been higher than 5% of total employees at any point during 2016/17 (5% in 2015/16). Our temporary employees are supplied by labour providers who, like all suppliers, are required to adhere to our Ethical Sourcing Policy which specifically prohibits modern slavery. Further, labour providers must be licensed with the Gangmasters’ Labour Abuse Authority, which aims to ensure employee’s rights are protected. Further, all of our own operations go through a comprehensive annual social audit performed by independent third party firm Accordia. This social audit is performed against the Sedex SMETA 4 Pillars Social Responsibility protocol, which is a formal review of a company's efforts to conduct business in a lawful, humane and ethical manner.

All employees can access an internal whistle blowing line which is advertised around our sites.

Training

T&L Sugars Limited employees who have direct responsibility for supply chain management in both sugar and non-sugar areas have undergone training run by Stronger Together, a multi-stakeholder initiative aiming to reduce hidden forced labour, labour trafficking and other third party exploitation of workers.

Gerald Mason

Director

T&L Sugars Limited

This statement was reviewed and approved by the Directors of T&L Sugars Limited on 03 April 2018.