Introduction

This statement is made pursuant to section 54 (part 6) of the Modern Slavery Act 2015 and constitutes the Modern Slavery Act Transparency Statement for Aunt Bessie’s Limited (“Aunt Bessie’s”) for the financial year ending 31 December 2017.

In July 2018, Aunt Bessie’s was bought by Nomad Foods Limited (“Nomad”), Europe’s biggest frozen food company producing, marketing and distributing branded frozen food products in 10 countries across Europe, employing over 4,200 people in 17 countries, with 12 factories. Core brands include Birds Eye, Findus and Iglo.

Nomad is committed to a corporate social responsibility that fosters a culture with respect for dignity and human rights as well as high ethical standards in the conduct of its businesses. Following the acquisition of Aunt Bessie’s, Nomad is in the process of integrating the business into its compliance and supplier assurance processes and aligning various policies.

This Statement sets out the actions taken to evaluate and understand potential modern slavery risks pertaining to the businesses of Nomad and their respective supply chains as well as measures presently in place to mitigate the possibility of occurrence of slavery and human trafficking in its business and supply chains.

Approach and Policies

Nomad recognises that the supply chain of food production and processing is one of the sectors which may be vulnerable to modern slavery, particularly due to the global nature of suppliers. The broad scope of its suppliers, which varies from small to large multinational companies located in all continents, requires significant efforts and dedication in order to manage business, health and sustainability issues. Although ultimately, it is each supplier’s responsibility to respect human rights and environmental issues, Nomad has made it its goal to take up an active role in ensuring that such responsibility is acted on, in accordance with its standards. Careful profiling enables Nomad to identify supply chains which may require special scrutiny in this regard.

Nomad operates a number of internal policies to ensure that it is conducting business in an ethical and transparent manner. Policies are developed by subject matter experts and signed off by group functional heads and approved at director level.

These policies include:

  1. Supplier Code of Conduct: This Code was launched early 2018 and will be rolled out during the remainder of 2018. It contains the basic principles of what it expects from both direct and indirect suppliers to the Nomad Foods Group and the minimum legal and ethical requirements they need to meet. These obligations require its suppliers to prevent occurrences modern slavery in their supply chain and state the specific human rights, labour and social laws, regulations and international conventions which they must abide by. The Supplier Code of Conduct replaces the existing Ethical Trading Code of Practice which was introduced in 2014. Compliance with its Code of Conduct will be mandatory for its suppliers.

  2. Code of Business Principles: This code was revised and relaunched in March 2018 given the increased size and sophistication of the Nomad group and sets out its ethical standards and the manner in which it behaves as an organisation, its responsibilities, and how it expects its employees and suppliers to act. It can be found on the Nomad website.

  3. Recruitment Policy: Nomad operates a robust recruitment policy and conduct eligibility evaluations, designed to safeguard against human trafficking (or individuals being forced to work against their will) by ensuring applicants are entitled to work in the United Kingdom; and

  4. Whistleblowing Policy: This measure instils a culture whereby all employees should feel free to raise concerns about how colleagues are being treated or in connection with practices within its business or supply chain, without fear of reprisals.

Suppliers

Nomad and Aunt Bessie’s have an ongoing commitment to engaging only those suppliers that uphold the same principles as they do and, where necessary, ensure the implementation of corrective action measures. In the event that a supplier fails to take steps to cease or prevent adverse human rights impacts, Aunt Bessie’s will examine its business relationship with such supplier with a view to remedying the situation.

In 2017, Nomad deployed its own supplier questionnaire, which is used (amongst other things) to review the status of the group’s supplier base’s ethical trading standards. It is Nomad’s goal to collate such data on an annual basis, so that it can be in a position to hold the latest and best information from its supply base. This information is used to contact risk assessments, and focus the efforts of its auditing programme.

To support this, Nomad is an AB member of the Supplier Ethical Data Exchange ("SEDEX"), which is a web-based system that allows us to share and view data on ethical and responsible business practices of other SEDEX member companies, including information on labour standards, health and safety, the environment and business ethics. Nomad sees SEDEX as an important part of its responsible sourcing practices and is working to ensure that all of its suppliers also join SEDEX. Nomad further expects all suppliers to be registered as B members of SEDEX and complete a self-audit questionnaire on the SEDEX database, has made positive strides towards compliance with this recent requirement in 2017, and has the ambition 100% of its direct suppliers will comply with this by the end of 2018.

Using this information, Nomad identify suppliers from whom it consider that an independent ethical audit report (such as SEDEX Members Ethical Trade Audit standard or similar) may be desirable and request its submission for review.

Risk Assessment & Auditing

Nomad’s Group Supplier Assurance team runs an ethical audit programme alongside its consumer safety audit programme. These audits are guided by the information it receives from the SEDEX programme, along with other factors such as geographical risk areas and supplier performance history, which is used to plan and prioritise audits accordingly. Nomad has already funded 27 SEDEX Member Ethical Audits (SMETA) in its supply base within the last 3 years and is looking to proceed with a similar level of auditing in the future.

Training

In order to ensure that all Nomad key staff understand and are aware of the risks of modern slavery and human trafficking and can assist its prevention, training continues to be provided to representatives from the Nomad and Aunt Bessie’s management teams, CSR teams, procurement teams and supply chain assurance teams.

The Nomad Supplier Assurance Team has undertaken internal SEDEX training. In addition, its Supplier Assurance Ethical Team has undertaken an Ethical Training Initiative (ETI) training course and its Procurement team undertook an ethical overview training session in Feb 2017. Further training will be delivered in connection with the Supplier Code of Conduct when it is launched.

Responsibility and Effectiveness

Nomad recognises the importance of maintaining constant vigilance to identify and address any impacts associated with slavery and human trafficking throughout its supply chains. In recognition of these issues, it remains committed to continue upholding human rights and safety in its supply chains and will be reviewing the progress and effectiveness of its programmes in combatting slavery and human trafficking on an annual basis.