This statement covers the activities of Bridge Farm Group:

• Bridge Farm Group supplies horticultural products to the UK major multiple retailers. Products include cut flowers, indoor plants and outdoor plants.
• Bridge Farm Group sources materials globally including raw and young plant materials, packaging and decorative hardware for use in it finished products. All materials purchased are shipped to our UK based growing and packing sites.  Bridge Farm Group operates out of three sites based in Spalding, UK.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

• Bridge Farm Group encourages all suppliers to become Sedex registered, and complete the self assessment questionnaire.
• All suppliers to Bridge Farm Group must complete a Supplier Questionnaire, provide evidence of business accreditation and confirm they have committed to the ETI Base Code Standard. This information is assessed using a risk based approach and is reviewed at least annually.
• Stronger Together is utilised by Bridge Farm Group, with key team members attending training courses to learn how to implement the practical guidance and resources available.

High-risk activities

The following activities are considered to be at high risk of slavery or human trafficking:

• Bridge Farm Group utilises local agency labour to support the directly employed workforce during peak season. Annual auditing of each labour provider, worker interviews, and regular Live Checks against the GLAA register form the basis of the Bridge Farm Group due diligence approach.
• The worldwide sourcing required within the business is managed through regional experts, who rely upon third party SMETA reports and their own site visits and worker interviews to ensure the lowest possible risk of modern slavery and or human trafficking within the supply chain.

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows:

• Policies: The Bridge Farm Group Senior Management Team regularly review the suite of company policies that are held in relation to modern slavery and human trafficking.  These policies have been developed in conjunction with business customers, Stronger Together, and other external subject area experts.
• Risk assessments: Bridge Farm Group use the labour provider audits conducted annually, the annual individual supplier risk assessment and information received from audit bodies, government, and customers when assessing the risk of business activity.  This responsibility is held by the senior management team.
• Investigations/due diligence: The HR Manager in conjunction with the Operations Director will investigate any issue raised and be responsible for its management to a satisfactory conclusion.
• Training:  Team members have attended Stronger Together Training, as well as attending customer ethical based seminars and training days.  Sedex and the GLAA also have subscription services for warnings, case development and training opportunities.

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact the confidential reporting line or email.
• Employee code of conduct The organisation’s handbook makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier/Procurement code of conduct The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.
• Anti-bribery policy The organisation does not tolerate, permit, or engage in bribery. We expect all our suppliers of goods, services and anything else to act with honesty and integrity and to comply with our Anti-bribery policy and the law.
• Employment/Agency workers policy The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.  Where concerns are raised during worker interviews these are promptly addressed by the HR Manager with the agency.

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments through third party audit services, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• creating an annual risk profile for each supplier;
• participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular participation in Stronger together;
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship;

The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is:

• requiring key staff to have completed training on modern slavery by July 2023.
• a system for supply chain verification in place.
• reviewing its existing supply chains in place.

The organisation expects HR professionals, and Senior Operational Management within the organisation to complete training, either face to face or online, on modern slavery and human trafficking.

The organisation’s modern slavery practices cover;

• our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;

• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;
• what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.
• any Senior Management attending conferences on ethical compliance

As well as training staff, the organisation has raised awareness of modern slavery issues by publishing the Modern Slavery statement as part of the employee handbook, displaying posters across the organisation’s premises and introducing relevant material into the induction process.

The materials used to explain to staff demonstrate:

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation;
• what external help is available, for example through the Modern Slavery Helpline.