Modern Slavery Act 2019/20

2019/20 Modern Slavery Act Transparency Statement (“MSATS”)


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

This statement will update on our work on modern slavery during 2019/20, 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 2020/21. 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 2019/20 progress

2019/20 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 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.

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 93% during 2019/20.

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.

In Belize, a simple tool in the shape of a book of contracts has been developed in consultation with four smallholder associations whose members supply our mill. The concept was piloted during the 2019/20 crop and adjustments made following that experience. A formal launch took place on 1st December 2020 and the contracts books are now in use by smallholders and their workers in the cane fields in Belize. Each reaping group leader has a book, each of which contains blank proforma contracts as well as guidance on employment law and safe working practices.

Additionally we have developed and shared with suppliers, material about the forms forced labour risk can take in the sugar industry to ensure that they understand this serious issue.

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.

When our Freight Coordinator has occasion to fix a ship with one of our preferred suppliers, a series of checks are carried out via Equasisi to ensure that the individual vessel meets international human rights and environmental standards. Additionally all freight operators in our supply chain are now also required to agree to our ethical sourcing policy. This specifically requires respect for fundamental human rights as set forth in The United Nations Universal Declaration of Human Rights as well as all applicable Law regarding forced, bonded or involuntary labor, slavery and human trafficking, wages, benefits, work hours, and employee rights to freedom of association.

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.

We ran a modern slavery event adapted to Covid restrictions at the end of November 2020; with banners in onsite locations and email communication via management briefings for those working remotely.

Additionally ASR Group adopted a Human Rights Statement and a Human Rights Policy in November 2020. These outline our support for fundamental human rights outlined in the United Nations’ International Bill of Human rights and the International Labor Organization’s Core Conventions, as set forth in the Declaration of Fundamental Principles & Rights at Work.

During 2021/22 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

Additionally we will encourage suppliers to take the next step towards managing their own compliance and certify their operations against a reputable sustainability standard.

Our target is that at least 50% of the sugar we buy for the Thames refinery in the 2020/2021 financial year will be certified against an internationally recognised sustainability standard, and the balance will all be verified according to our 4 step sustainability verification process.

Objective three

In November 2020, in addition to our existing policies on ethical souring, ASR Group adopted a Human Rights position statement and a Human Trafficking Policy (see under the tab“Document Downloads”).

This is part of a review of the reach and effectiveness of our sustainability process to ensure that it is consistent with the UN’s Guiding Principles on Business & Human Rights and the Organization for Economic Cooperation & Development’s (OECD) Due Diligence Guidance for Responsible Business Conduct.

The next step in this process is to widen the reach of our employee grievance process to make it accessible to all stakeholders.

Objective four

We will continue to promote awareness of modern slavery among our colleagues in the UK and Europe via internal communication and training.

Gerald Mason


T&L Sugars Limited

This statement was reviewed and approved by the Directors of T&L Sugars Limited on 21 April 2021.


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