Modern Slavery Statement

Thomas Tunnock

Introduction

At Thomas Tunnock Ltd we conduct our business with integrity, transparency and fairness. We are committed to the prevention of slavery and human trafficking both in our business and in our supply chains as part of maintaining our reputation and the confidence of our clients and business partners. We undertake to procure goods and services in a sustainable and ethical manner in compliance with our values, relevant law and policy and the Modern Slavery Act 2015.

We do not accept slavery or human trafficking in our business and we will not work with others who do not share our commitment to preventing slavery and human trafficking. If you have any concerns or suspicions we should know about then please contact our Company Secretary (Bruce Reidford) on 01698 813551.

Our business and supply chains

Thomas Tunnock Ltd is a manufacturer of Chocolate Biscuits and Bakery Products of the highest quality to all sectors of the retail trade.  Our clients include big companies, small and medium enterprises, entrepreneurs, business people and individuals from all backgrounds including large supermarkets and independent traders who are active in almost every sector of the Scottish economy.

Our Head Office is in Scotland and we have a Sales Manager situated in Manchester. Further information about our business can be found at: http://www.sales@tunnock.co.uk

Our supply chains include providers of raw and packing materials, utilities, services which include stationery supplies, maintenance and IT services.

Compliance

  • Since the Modern Slavery Act 2015 (“MSA 2015”) came into force, we have built on our existing compliance framework by: 
  • consulting with our Public Law & Regulatory team on our compliance approach
  • conducting a risk assessment of our business and our supply chains
  • holding discussions within the Company to ensure compliance
  • producing a specific Anti-slavery Policy, to be approved by the Directors.
  • identifying Bruce Reidford as the Anti-slavery Compliance Partner with overall responsibility for implementing this policy
  • identifying Key Performance Indicators against which to assess our progress on slavery and human trafficking issues

Our Anti-slavery Policy reflects our commitment to conducting our business with integrity, transparency and fairness and to ensuring that slavery and human trafficking is not prevalent in our supply chains. The policy applies to all staff and to our suppliers, including those who work for or on our behalf in any capacity.

The firm’s Anti-slavery Policy includes guidance to our staff with examples of unusual behaviour displayed by workers which may be indicative of someone experiencing slavery or human trafficking. It also makes it clear that our legal advisors will support anyone who raises a genuine concern in good faith, even in circumstances where it transpires that those concerns are mistaken.

Our Anti-slavery Policy builds on existing policies covering Procurement, (Suppliers), (Agency Staff), Equality, Diversity, Dignity at Work, Grievances, the Employee Handbook and Training.

Due diligence in our supply chains

We have conducted a risk assessment of our supply chains based on annual spend, invoice frequency and a combination of these factors.  We have also reviewed our supplier list to sense-check the results.

We will shortly be writing to the suppliers we have identified to communicate to them our commitment to complying with the requirements of the MSA 2015 and our responsibility to ensure, as far as possible, that slavery and human trafficking is not occurring in any part of our supply chains. The letter asks these suppliers to confirm the steps they have taken both internally and in their supply chains to ensure that slavery and human trafficking is not occurring

Training

All relevant members of staff will be required to certify that they have read and understood our Anti-Slavery Policy. After receiving tailored training, provided to staff, within our firm who have responsibility for managing supplier contracts and for making purchasing decisions.

Key Performance Indicators

We will use the following Key Performance Indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • All staff have confirmed that they have read and understood our Legal Advisors’ Anti-  slavery Policy
  • Any policy breaches are reported to the Anti-slavery Compliance Officer within a reasonable time of occurring
  • Any policy breaches are assessed within a reasonable time of being reported and further investigations concluded as soon as possible thereafter  
  • Future steps

Over the course of the next year, we intend to take the following further steps to combat slavery and human trafficking:

  • Include specific slavery and human trafficking obligations in supplier terms and conditions
  • Ensure that material new firm suppliers receive a copy of our Anti-Slavery Policy
  • Review and, as appropriate, update our supplier take on processes

We will continue to monitor the effectiveness of our compliance regime and take necessary steps to address any instances of slavery and human trafficking.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.