Modern Slavery

Modern Slavery and Human Trafficking
Period covering April 2022 – March 2023

Policy Statement
John Thompson & Sons Limited is a trading subsidiary of BHH Limited. John Thompson & Sons Limited acknowledges its responsibilities in relation to ethical business activity and in tackling modern slavery within our supply chain or in any other part of our business.  Our policies and our interaction with colleagues, as well as suppliers, reflects our commitment to acting ethically in all our operational matters.  We strive to ensure that we, and our supply chain, act in compliance with the Modern Slavery Act 2015, and have continued to monitor such compliance.

Our Business
John Thompson & Sons Limited is a trading company, the principal activities of which are the manufacture and sale of compound animal feeds and the sale and distribution of fertilisers.  John Thompson & Sons Limited’s main raw material suppliers, are W&R Barnett Trading Ltd and R&H Hall Trading Limited, which are group companies within the wider W&R Barnett group who provide a Modern Slavery Report independently.

Due Dilligence
We have:

1. undertaken a risk assessment of areas within our businesses and our supply chains identified by the legislation, with particular focus on child labour, forced labour, health and safety, workers’ rights, diversity and minimum pay; and
2. taken steps to assess and manage the risks identified including:
   
   a. auditing our supply chain and recruitment agencies we use (as outlined below);
   b. providing training to members of the team, management and board members;
   c. complying with our Slavery and Human Trafficking Statement; and
   d. adhering to our Anti-Slavery and Human Trafficking policy.
   

Assessing and managing risk
Through our risk assessment, we consider that recruitment (direct and indirect) and supply chains are key areas which our business must control in order to limit risk of slavery and human trafficking.

In relation to our supply chain, we have used the 2018 Global Index Data to identify high risk countries in which our suppliers currently operate. We audit our suppliers to identify whether they present any concerns regarding modern slavery. To manage this risk and to ensure those within our supply chain are also aware of their obligations, we have rolled out an ongoing compliance initiative as part of our Quality Assurance programme whereby an audit sample of raw material suppliers are asked to confirm compliance and to supply copies of relevant policies or action plans. We have ensured that W&R Barnett Trading Ltd and R&H Hall Trading Limited (as our main commodity suppliers) have completed the necessary due diligence and training and published their respective Modern Slavery Statements.

In relation to recruitment, we complete thorough checks on recruitment agencies we use and on prospective employees. These checks are designed to identify any concerns relating to modern slavery and/or human trafficking and such processes are more specifically outlined in our Anti-Slavery and Human Trafficking Policy.

Training
We have initiated a comprehensive training programme for all our staff to raise awareness of the Modern Slavery legislation and their and our obligations in regard thereto.

Policies
We are committed to addressing modern slavery and ensuring ethical compliance, and have developed policies which reflect the values we adhere to as a business, including our Anti-Slavery and Human Trafficking Policy. These policies have been made available within our staff handbook, and include a provision to address a safe mechanism for whistleblowing.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015, constitutes our modern slavery and human trafficking statement for period ending 31st March 2023 and was approved by the Board of Directors on 27th June 2023.

Declan Billington
Chief Executive
John Thompson & Sons Ltd

Modern Slavery and Human Trafficking Policy Statement (2023) - click here