Modern Slavery Statement
This is Greencell’s fifth modern slavery statement following the introduction of the Modern Slavery Act 2015. Section 54 of the UK Modern Slavery Act (2015) requires commercial organisations operating in the UK with an annual turnover in excess of £36m to produce a ‘slavery and human trafficking statement for each financial year of the organisation’. The statement refers to our financial year ending 31st December 2020.
2. Our Approach
Greencell is committed to acting under the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the Internal Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. Greencell has developed and embedded a human rights policy framework that addresses human rights, which includes the risk of modern slavery. Greencell are committed to ensuring there is transparency in our approach to tackling modern slavery within our operations and throughout our supply chains. We require that our suppliers comply with our policies and codes to eradicate the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude within their own business and that of their supply chains.
3. Our Business
Greencell is part of the Westfalia Fruit Group which in turn is part of Hans Merensky Holdings which is governed by the Hans Merensky Trust. Greencell operates from two sites in the UK: Kings Hill and Spalding. The ripening, packing and supply of avocados to major high street retailers and the wholesale markets is the predominant business. Westfalia Fruit is recognised as being one of the largest growers of avocados worldwide with the reputation for supplying superior, organic, Fairtrade & conventional quality fruit year-round. Westfalia Fruit is a truly vertically integrated company operating oil and fruit processing plants producing avocado oils, guacamole, and dried fruit. Westfalia Fruit Group sales offices are in the UK, Europe, North America, Latin America, and Southern Africa.
Greencell Managing Director and Senior Management team fully endorse this policy statement and work towards ensuring “Slavery and Human Trafficking is prevented within Greencell and its supply chain. Elizabeth Williams, CSR Manager, is the nominated person responsible for ensuring that efforts are made to investigate and remediate the risk of Modern Slavery in Greencell’s business and supply chains.
5. Supply Chain
Greencell has built long-term relationships, greater than 10 years, with many suppliers throughout the world to include South America, Africa, and Europe. All products are sourced from approved nominated suppliers who pass Greencell’s stringent supplier approval verification process and meet Greencell’s high ethical expectations and standards within their supply chains.
Within our operation in the UK, we source goods and services to operate our business. These range from Labour Providers, Stationery Suppliers, Printing Suppliers, Laundries and Cleaning equipment suppliers. Greencell continually engages with those suppliers deemed to be the highest risk within this group.
6. Policies in relation to Slavery and Human Trafficking
Greencell is committed to ensuring that there is no modern slavery or human trafficking within the supply chains or in any part of the business. Greencell’s modern slavery policies and procedures reflect Greencell’s commitment to acting ethically in all business activities and relationships. The policies and procedures are based on universally recognised standards such as the ETI Base Code, UN Guiding Principles on Human Rights, and the UK Modern Slavery Act (2015).
- Ethical Policy
- Human Rights Policy Statement
- Anti-Bribery and Corruption Policy
- Whistleblowing policy
- Preventing Unseen Labour Exploitation Policy
- Policy on Forced Labour within the supply chain
- Responsible Recruitment Policy
- Child Labour Policy
We believe that the risk of slavery, human trafficking and child labour within our organisation is substantially mitigated by the policies, practices, and training that we have in place.
7. Our Risk Assessment Approach
Greencell has a risk assessment methodology in place for all supply goods for resale which assess ongoing modern slavery risks within our supply chains using a combination of country-level information sources, audit results, SEDEX, Global Slavery Index, ITUC and ILAB.
Greencell uses the SEDEX RADAR Tool which contains risk data based on independent and reputable sources in the SMETA pillars and 14 SEDEX RADAR risk topics (Forced Labour, Freedom of Association, H&S, Children & Young Workers, Regular Employment, Wages, Working Hours, Discrimination, Gender, Business Ethics, Biodiversity, GHG Risk, Water Risk and Waste & Pollution Risk). Radar also includes site data that is based on information uploaded by suppliers in their SSAQ and from 3rd party ethical audit reports. Greencell has incorporated the SEDEX RADAR tool into its risk assessment process which validates whether the risks are occurring in practice which enables us to develop action plans to manage and mitigate these risks.
Greencell high-risk suppliers are ethically audited to grower level by 3rd party auditing bodies. In South Africa suppliers undergo SIZA audits frequency determined by the auditing body, and in other countries, suppliers undertake SMETA, Fair for Life, Rainforest Alliance, and GRASP on an annual basis,
Greencell undertakes 3rd party SMETA audits every 2 years. Our labour providers are Gangmaster & Labour Abuse Authority (GLAA) licenced and are independently 3rd party audited on an annual basis.
Greencell uses The Sedex Forced Labour Indicators tool to assist Greencell in understanding where potential indicators of forced labour have been identified within our supply chain. The tool draws on noncompliance and observations raised during 3rd party SMETA audits at supplier sites that are linked with Greencell on SEDEX. Greencell monitors those definite indicators every quarter and takes action to ensure that all workers within our supply chain are receiving decent work, in line with Sustainable Development Goals (SDGs).
In 2021, we started to use the Stronger Together Progress Monitoring Tool. This is a pioneering online self-assessment supporting companies to measure their progress and to highlight their next steps in addressing modern slavery risks within their businesses and supply chains. This tool forms one of our Modern Slavery KPI for improving yr. on yr. scores.
Greencell has a free, anonymous, and confidential whistleblowing hotline that enables all employees, including agency workers, to raise any potential concerns including those relating to employment standards or ethics. The hotline is available by Freephone, email and online 24 hours per day / 365 days per year.
Greencell is a “Full Member “of the Ethical Trading Initiative (ETI), A&B member of The Supplier Ethical Data Exchange (SEDEX), Members of Assured Labour Providers (ALP), Members of Sustainability Initiative of South Africa (SIZA) and members of the Spanish Ethical Trade Forum.
8. Due Diligence
Greencell’s vision is for workers to be fairly treated and rewarded in working conditions that are safe and secure with the freedom to develop and grow their careers. Greencell aims to achieve this by working in close collaboration with its growing operations, Westfalia Fruit, and long-term partner growers; communicating the ETI base code requirements in a targeted fashion in line with the company’s objectives and targets as described in Greencell’s ethical strategy. Greencell’s ethical strategy has been developed following a thorough risk assessment of its supply base. Informed by our risk assessments, Greencell conducts due diligence across our operations and our supply chains by monitoring for indicators of any form of modern slavery and to ensure that there are sufficient controls in place.
Greencell conduct careful assessments of prospective new supply chain partners to ensure that they meet the obligations set out in the ETI Base Code, UN Guiding Principles on Human Rights, and the Modern Slavery Act., this is done through (SEDEX which gives us visibility of all our sites so we can monitor supplier’s performance yr. on yr., Human Right Action Plans, 3rd Party Ethical Audits, Independent 3rd party audit checks on our UK labour Providers).
Greencell’s ethical, technical, and buying teams meet formally with key suppliers, at least annually, to specifically discuss human trafficking and worker welfare in their supply chain. The CSR Manager, Responsible Sourcing Managers and the Technical Team will visit the supplier’s premises; providing an opportunity to observe “business ethical activities, working conditions, recruitment practices and carry out worker interviews to ensure suppliers are not breaching the ETI Base Code or the Modern Slavery Act.
Supplier scorecards are compiled for each supplier at the end of the season review which includes “compliance to Greencell Ethical Policy”. Ethical KPI’s are reported monthly to the Senior Management Team.
Greencell also participates in collaborative Due Diligence with Non-Governmental Organizations, Customers, stakeholders to make meaning full change. Examples are (Spanish Ethical Trading Forum, ETI working group on Social Dialogue in Peru and &Wider).
9. Supplier Adherence to Our Values and Ethics
Greencell operates a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business activities and operations. Greencell is committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place within its supply chain by exercising strong policies and procedures as part of a robust, developing due diligence framework.
In accordance with section 54(4) of the Modern Slavery Act 2015; Greencell works with first-tier suppliers to ensure slavery and/or human trafficking is not taking place within their own supply chains. Each supplier signs Greencell’s “Policy on Forced Labour within the supply chain” demonstrating their commitment to identifying and eradicating anti-slavery and human trafficking.
Greencell is committed to carrying out business with suppliers who are working to ensure continuous improvements are made within their own operations and that of their supply chain.
10. Key performance indicators to measure effectiveness of steps being taken (KPIs)
Greencell tracks progression against our plans to prevent and tackle modern slavery through several KPI’s in the following areas: (3rd Party SMETA Audits, Whistleblowing Hotlines, Stronger Together Training, Stronger Together Progression Tool, Responsible Recruitment Assessment and Modern Slavery Training etc)
11. Training on modern slavery and trafficking
All Greencell employees receive awareness training concerning Modern Slavery upon induction. Specific e-learning courses on modern slavery themes are also available to our employees via web-based platforms. Employees who have direct responsibility and involvement with the engagement of workers receive comprehensive Modern slavery training. We also require that our UK labour providers undertake Stronger Together Modern Slavery training and deliver modern slavery training to temporary workers upon induction.
12. Next Steps
We continually monitor risks and the working landscape in respect of COVID-19 and acknowledge that we may need to adapt our focus and commitments.
- Greencell will develop guidelines/policies to protect and ensure the recruitment of migrant workers over the next five years.
- Greencell is to develop and roll out training on the focus of modern slavery and forced labour within our supply base.
- Improve reporting on risks of forced labour and indicators of forced labour and measures to assess the effectiveness of our efforts
- Implement &Wider to grower level in high-risk countries.
- Continued development and roll-out of Greencell “Human Right Due Diligence Action Plan
” This statement has been approved by Greencell’s Managing Director and is made in accordance with Section 54(1) of the Modern Slavery Act 2015.