Richardson Milling UK

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Human Rights Policy

Modern Slavery Act Policy

ORGANISATION STRUCTURE AND SUPPLY CHAINS
Established in 1980, we remain an independently-owned business that supports 130 staff in and around the Bedford area. With truly global reach, we trade across more than 50 countries around the world, which has enabled us to become the largest industrial oat miller in Europe. Our current expansion plans will see this output grow significantly to ensure our business continues to diversify and flourish.

We are members of the Ethical Training Initiative (ETI) and we are regularly audited by third parties who publish our results on the Supplier Ethical Data Exchange (Sedex). This is a web-based database where suppliers post labour standards information and self-assessments in addition to all site audit reports.

We internally review our supply chain to evaluate human trafficking risks and slavery risks and we conduct supplier self-assessments and audits which review all aspects of the supply chain including safety, human trafficking, child labour and other legal requirements.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure slavery and human trafficking does not take place anywhere within our supply chain.

Any concerns from any member of our staff regarding a likely risk of, or actual, breach of our policy or the legislation must be raised to the board of directors at the earliest opportunity.

RELEVANT POLICIES
In keeping with our commitment to act with integrity in all our business dealings, many of our existing policies ensure that there is no slavery or human trafficking in any part of our business or supply chains.

Our relevant policies include:

  • Code of Conduct;
  • Employment Policy;
  • Health Protection and Wellbeing Policy;
  • Public Interest Disclosure Policy

In our Code of Conduct, relevant sections cover; discrimination and harassment, human rights, responsible procurement and supplier partnerships and anti-illicit trade.

Our Code of Conduct sets out the behaviours we expect from employees in their dealings with colleagues, customers, consumers, suppliers, agents, intermediaries, advisers, governments and competitors. All employees and suppliers are expected to act with integrity in accordance with the standards of behaviour set out in the Code of Conduct.

We provide guidance and training to support employee understanding of expected behaviour, particularly in respect of their business decisions and the Code of Conduct. We encourage employees to raise concerns and we have a Public Interest Disclosure Policy.

We believe in business benefits brought about by diversity and equal opportunity. We therefore support collective bargaining for our own employees and through our supplier standards.

We actively support employee engagement, representation, dialogue and the ability of an employee to raise potential concerns or grievances. Freedom of association and the right to collective bargaining is a core labour standard that we respect as guided by the International Labour Organisation (ILO). We apply our employment practices in line with, and in certain aspects exceeding the requirements of, local legislation.

We recognise that we operate in a number of countries where human rights are an issue of particular concern. Following periods of new acquisition and before our employment practices and monitoring are embedded, we use trained social auditors as a basis for evaluation of performance improvement based on risk assessment.

We are guided by the SA8000 standard to cover a variety of potential issues including child labour, forced labour, health and safety, freedom of association, the right to collective bargaining, discrimination, disciplinary practices, working hours, remuneration, and management systems.

RISK ASSESSMENT AND DUE DILIGENCE
The risk of slavery and human trafficking within our own organisation is substantially avoided and mitigated as a result of strict policies and procedures as well as the oversight built into our business operations, and the knowledge and skills of our staff. We assess risk based on a number of factors such as geographical risk indices pertaining to human rights, the level of supply chain control, external governance factors and levels of political stability.

We consider that the greatest risk of slavery and human trafficking is in our supply chain where we undertake procurement activities and where operations and managerial oversight are out of our direct control. In addition to the training and awareness provided by our Code of Conduct, we also have supplier standards and specific supplier programmes.

We undertake due diligence when considering new suppliers, and regularly review our existing suppliers. Our due diligence and reviews include;

  • Mapping the supply chain broadly to assess particular products or geographical risks of modern slavery and human trafficking.
  • Evaluating the modern slavery and human trafficking risks of each new supplier. This is achieved through supplier self-assessment processes and auditing.
  • Conducting supplier audits using accredited third party supplier auditors.
  • Invoking sanctions against suppliers that fail to improve their performance in-line with an action plan. Serious violations of our supplier code of conduct, lead to the termination of our business relationship.

TRAINING AND AWARENESS
We ensure that we have competency within our organisation, through training relating to human rights and the awareness of the social accountability standard SA8000. We use accredited third party supplier auditors who are trained social compliance auditors to work and advise our management team and employees.

Human rights awareness training has been further directed to personnel who work in human resources and corporate affairs. Specific supplier standards training is directed at procurement personnel. More general awareness is available throughout the wider organisation through our Code of Conduct.

We further provide guidance and training to support employees understanding of expected behavior, particularly in respect of their business decisions and the Code of Conduct.

BOARD OF DIRECTORS APPROVAL
This statement has been approved by our Board of Directors, who review and update it annually and assure compliance is followed.

Anti-Bribery Policy for Suppliers

Introduction

One of our core values is to uphold responsible and fair business practices. We’re committed to promoting and maintaining the highest level of ethical standards in relation to all of our business activities. Our reputation for maintaining lawful business practices is of paramount importance and this policy is designed to preserve these values.

We have a zero tolerance policy towards bribery and corruption and are committed to acting fairly and with integrity in all of our business dealings and relationships. We also implement and enforce effective systems to counter bribery.

Purpose and Scope of Policy

This policy sets out our position on any form of bribery and corruption and provides guidelines aimed at:

  • Ensuring compliance with anti-bribery laws, rules and regulations; not just within the UK but in any other country where we may carry out business or where our business may be connected.
  • Ensuring that any supplier, vendor, service provider or contractor to Richardson Milling (UK) Ltd understands the risks associated with bribery, and to encourage them to follow our policies regarding these matters.
  • Creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption.

Legal Obligations

The UK legislation on which this policy is based is the Bribery Act 2010 and it applies to the conduct of Richardson Milling (UK) Ltd both in the UK and abroad. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is an offence in the UK to:

  • Offer, promise or give a financial or other advantage to another person (i.e. bribe a person), whether within the UK or abroad, with the intention of inducing or rewarding improper conduct.
  • Request, agree to receive, or accept a financial or other advantage (i.e. receive a bribe) for or in relation to improper conduct.

Policy Statement

We expect all our suppliers, contractors, vendors and service providers to:

  • Comply with anti-bribery and anti-corruption legislation that applies in any jurisdiction in which they might be expected to conduct business with Richardson Milling (UK) Ltd.
  • Act honestly, responsibly and with integrity when dealing with Richardson Milling (UK) Ltd.
  • Help to safeguard and uphold the our core values by operating in an ethical, professional and lawful manner at all times.

Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside, or accounts created for the purposes of facilitating the payment or receipt of a bribe.

We recognise that industry practices may vary depending on a country and its culture. What is considered unacceptable in one place, may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this policy is expected of all our employees and therefore it is requested that all our suppliers, vendors, service suppliers and contractors help us to ensure no unlawful or unethical transactions or acts take place. If in doubt as to what might amount to bribery or what might constitute a breach of this policy please feel free to contact the Managing Director, Finance Director or Head of HR of Richardson Milling (UK) Ltd The giving of business gifts from clients, customers, contractors and suppliers is not prohibited provided the following requirements are met:

The gift is not made with the intention of influencing a staff member to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage.

  • It complies with local law.
  • It is given in the company’s name, not in the giver’s personal name.
  • It does not include cash or a cash equivalent (such as gift vouchers).
  • It is of an appropriate and reasonable type and value and given at an appropriate time.
  • It is given openly, not secretly.
  • It is approved in advance by a director of the Richardson Milling (UK) Ltd

In summary, it is not acceptable to give, promise to give or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given, or to provide a payment, gift or hospitality to a specific Richardson Milling (UK) Ltd staff member with the expectation that it will obtain a business advantage to your business. We ask our suppliers to study the rules we request all our staff to follow regarding gifts, hospitality and entertainment to avoid any embarrassing situations.

Responsibilities and Reporting Procedure

We encourage all employees, associated persons, suppliers, vendor service providers and contractors to be vigilant and to report any unlawful conduct, suspicions or concerns promptly and without undue delay, so that an investigation may proceed and any action can be taken expeditiously. In the event that you wish to report an instance or suspected instance of a request to make an undue payment or gift to a staff member (bribery) we request you disclose that to the Managing Director, Finance Director or Head of HR of Richardson Milling (UK) Ltd immediately.

Confidentiality will be maintained during the investigation to the extent that this is practical and appropriate in the circumstances. We are committed to taking appropriate action against bribery and corruption. This could include either reporting the matter to an appropriate external government department, regulatory agency, or the police and/or taking internal disciplinary action against relevant employees and/or terminating contracts with associated persons.

We will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that actual or potential bribery or corruption has taken place or may take place in the future.

Record Keeping

All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept off the record to facilitate or conceal improper payments.

Sanctions for Breach

A breach of any of the provisions of this policy will constitute a disciplinary offence and will be dealt with in accordance with our disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render an employee liable to summary dismissal.

As far as associated persons are concerned, a breach of this policy could lead to the suspension or termination of any relevant contract, sub-contract or other agreement.

Monitoring Compliance

Our Managing Director, Finance Director and Head of HR all have responsibility for ensuring compliance with this policy and will review its contents on a regular basis. They will be responsible for monitoring its effectiveness and will provide regular reports in this regard to the directors of the company who have overall responsibility for ensuring this policy complies with the company’s legal and ethical obligations.

Training

We will provide training to all employees to help them understand their duties and responsibilities under this policy. Our zero-tolerance approach to bribery will also be communicated to all business partners at the outset of the business relationship with them and as appropriate thereafter.

Examples of Potential Risks

The following is a non-exhaustive list of possible issues which raise bribery concerns and which you should report in accordance with the reporting procedure set out above:

  • A third party insists on receiving a commission or fee before committing to signing a contract with Richardson Milling (UK) Ltd, or carrying out a government function or process for Richardson Milling (UK) Ltd
  • A third-party requests payment in cash, or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made.
  • A third party requests an unexpected additional commission or fee to facilitate a service.
  • A third party demands lavish, extraordinary or excessive gifts or hospitality before commencing or continuing contractual negotiations or provision of services.
  • You are offered an unusually lavish, extraordinary or excessive gift or hospitality by a third party.
  • You receive an invoice from a third party that appears to be non-standard or extraordinary.
  • Richardson Milling (UK) Ltd is invoiced for a commission or fee payment that appears large given the service stated to have been provided.