Modern Slavery Act

2018/19 Modern Slavery Act Transparency Statement (“MSATS”)

Introduction

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

This statement will update on our work on modern slavery during 2018/19, 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 2019/20. 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 previous statements, which will remain online for the purpose of full transparency.

Update on 2018/19 progress

2018/19 saw us make continued progress on implementing measures to prevent modern slavery in our business. Below we outline how we performed against each objective we set ourselves.

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 raw sugar suppliers having been audited over the last three years. As stated in our Statement of Business, we have identified that raw sugar is our most material risk.

The percentage of our sugar produced by suppliers that have undergone the independent verification audit or are certified under the Proterra or Bonsucro standard was 98% during 2018/19.

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.

We are working with our mill in Belize, and the four smallholder associations who supply it, to develop a simple contract for use by smallholders and their workers in order to promote good hiring and working practices in a sector that is generally otherwise informal. The next step is to conduct training on good employment protocols and the use of the contracts and to conduct a pilot. The work is being supported by one our customers.

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 their origin to our refinery. 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.

We have spoken to the companies who ship our raw sugar from the countries where it is grown to our refinery. Most of them have shared with us details of good policies and the processes they have in place to reduce the risk of modern slavery on their ships. Our next step will be to further strengthen our processes in this area, particularly with regards to the small number of suppliers with weaker policies and processes.

During 2019/20 our objectives for preventing modern slavery include:

Objective one

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

Objective two

In addition to our current ethical sourcing policy which specifically prohibits forced labour, during this financial year (October 2019 to September 20) we will draw from insights gained from our verification audits and the ILO indicators of forced labour risk to proactively promote robust and responsible practices on farms and in mills.

Objective three

We will continue our dialogue with our freight suppliers, requiring all of them to commit to respect fundamental human rights in their operations and their suppliers’ operations.

Objective four

We will continue to find ways to raise awareness of modern slavery among our colleagues in the UK and Europe. During this financial year (October 2019 to September 20) we will hold a Modern Slavery Awareness day to mark the fifth anniversary of the Modern Slavery Act coming into force.

Gerald Mason
Director 
T&L Sugars Limited
This statement was reviewed and approved by the Directors of T&L Sugars Limited on 21 April 2020.