2020/21 Modern Slavery Act Transparency Statement (“MSATS”)

Introduction

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

This statement will update on our work on modern slavery during 2020/21 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 2021/22.

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 2020/21 progress

2020/21 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 due diligence process. We committed to aim for suppliers representing 95% of our raw sugar during 2020/21 to undertake independent verification audits or certification under the Proterra or Bonsucro standard.

Travel remained challenging in many places due to COVID. Although we were able to audit some suppliers, we were unable to complete our whole plan due to travel restrictions. This meant that 90% of our raw sugar arrivals during 2020/21 came from suppliers where independent verification audits or certification had taken place. Although this was slightly below our target, given the travel restrictions in place we were pleased to keep the audit coverage this high.

Objective two

– We want to encourage more suppliers to certify their operations against a reputable sustainability standard. We set a target of 50% of the sugar supplied to the Thames refinery in the 2020/2021 financial year to be certified against an internationally recognised sustainability standard.

Whilst we didn’t quite hit our 50% target, we made solid progress on increasing the proportion of certified raw sugar delivered to Thames Refinery. We were able to increase it from 35% to 45% during the period. We expect this number to continue to improve next year, and have set ourselves an ambitious target to keep progress solid.

Objective three

– We committed to widen the reach of our employee grievance process to make it also accessible to stakeholders outside our business, including those in our supply chains.

We have not yet achieved this objective as this is proving technically difficult with our current website design. We are in the process of refreshing our websites, and will incorporate details of the process in the new website design.

Objective four

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

We held an internal event in the last week of November (to mark the International Day for the Abolition of Slavery on 2 December) with displays in staff restaurants and other internal communication channels to highlight the issue to all of our colleagues across all of our sites. This was followed with refresher training, for relevant personnel, provided by Stronger2Gether who are the go-to organisation for modern slavery prevention in the food industry.

In addition, we were proud to showcase our work to formalise hiring and working practices in the smallholder cane farming sector in Belize to colleagues via a range of channels, including celebrating our highly commended award from the Coop’s Treating People Fairly Awards.

During 2021/22 our objectives for preventing modern slavery include:

Objective one

We retain our commitment to audit suppliers representing 95% of our raw Sugar.

Objective two

We will continue to encourage more suppliers to certify their operations against a reputable sustainability standard. Last year we reached 45% of the sugar supplied to the Thames refinery being certified against an internationally recognised sustainability standard. In 2022, our aim is to reach 65% certified sugar as we build towards our longer term goal of 100%

Objective three

We will build on the work conducted in the last two years 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. The objective of this work was to promote good hiring and working practices in a sector that is generally otherwise informal. In the coming year we will extend this work to include additional groups of workers; truck drivers and loader drivers.

Objective four

In the communities around our factories in East London, data shows that there are many workers who aren’t paid the legal minimum wage, and workers at higher risk of modern slavery. In 2020 we became an accredited Living Wage employer. We will work hard with other Living Wage supporters in our part of East London to launch a campaign to make the Royal Docks a Living Wage Place during 2022. This will help improve employment conditions in the communities around us, as well as make people more aware of poor pay and modern slavery in our communities.

This statement was reviewed and approved by the Directors of T&L Sugars Limited on 8 April 2022