W.B. Chambers Ltd. Modern Slavery and Human Trafficking statement for the Financial Year 2023.
In line with the UK Modern Slavery Act 2015, this statement has been published and produced with regard to the business activities and the company supply chains; these are reviewed annually alongside the annual financial reporting, last reviewed on 29th March 2024. This is our 7th Annual Statement and contains a summary of progress undertaken during the calendar year of 2023.
This statement covers the joint operating of W.B. Chambers Farms Ltd & WBC Imports Ltd, and all trading companies associated and linked with these operating companies.
The business operates across a number of UK farming sites, and also works with a global supply base which allows for an annual business model to operate during the calendar year. Allowing for seasonal fluctuations in each country due to weather conditions.
The importing, growing and retailing of the produce it grows and procures is done with key strategic partner growers, all have a desire to eliminate modern slavery, and produce the best quality produce.
The collective business in the past 12 months has been taking steps to eliminate the opportunity for slavery and human trafficking in any of the supply chains that it has, and within the specialist business units that it operates which is reflected in W.B. Chambers Farms Ltd and W.B.C. Imports Ltd. business and linked companies.
The business has a ‘zero tolerance’ for any modern slavery . This can take many forms, including forced labour, child labour, human trafficking and bonded labour. We are strongly committed to eradicating modern slavery and recognise the importance of transparency in Supply Chains in driving collaborative action to help eliminate the incidence of modern slavery.
To prevent modern slavery in our business or our supply chains, we need to make our own Directors and employees aware of the issues and provide them with the tools to tackle it.
We have the policies covering the procedural guidance, training, and business commitments. Policies cover direct and indirect obligations to reducing Modern Slavery and Human Trafficking. Directors, Managers and employees are instructed allowing them to highlight and tackle potential issues.
Policies covering a multitude of aspects including: –
- Emergency Procedure Plan / Policy
- Children under 18 and Young Workers
- Equal Opportunities Policy.
- Ethical Trade policy (ETI Base code).
- Induction Policy and procedures.
- Eligibility to Work in the UK.
- Welfare Policy.
- Health & Safety policy.
- Safeguarding policy.
- Labour Exploitation policy.
The business has attended some ALP ( Association of Labour Providers ) workshops and Stronger 2gether (Tackling Modern Slavery) which help knowledge on recruitment practices. The Initiative aims to reduce human trafficking, forced labour and exploitation or workers for the prevention of modern slavery.
W.B. Chambers is a member of SEDEX Information Exchange (SEDEX), which is a not-for-profit membership association, a collaborative platform for buyers, suppliers and auditors to store, share and report on information.
W.B. Chambers also recognises and works towards the ETI Base code (Ethical Trade Initiative), which is founded on the conventions of the Internationals Labour Organisation (ILO), and is an Internationally recognised code of labour practice.
The business has various ways of working with its key partners and growers based around the globe. As the business is changing and growing, these methods of engagement are key to the growth of the business which will underline the knowledge base of the supply chain.
Communication – All of the companies that we work with can speak to key individuals within the company. Often these routes to conservations will be via telephone / web video calling / and or email, through the commercial, procurement and technical teams.
Hand in Hand – Many of the sites and growers we work with have been visited on a number of occasions by the management team. This has been in the form of checks, audits, growing advise or commercial negotiations. Work to improve this visibility of information about the growers is ongoing. We will support and assist any of the sites that require advice or information. (second party auditing will increasingly be an important part of the supply chain understanding). Risk Assessment highlighting the areas of Modern Slavery will change for the country and complexity of the supply chain. Worker surveys and suggestion tools are an important method of understanding. Use of media such as Facebook, Electronic surveys are an increasingly easy method to gather data, trends and feedback. Some of the these during 2022 have been sponsored by the retailers we work with.
2nd & 3rd Party Verifications – All of the sites that we work have 3rd certification for various farming standards. Increasingly growers are required to have 3rd party Ethical Audits in a number of countries, and these have been conducted on announced or semi-unannounced basis.
If the business needs to use an external employment agency, then a 2nd Party verification check is made to that company, checking key principles are being followed.
These audits are based on the Ethical Trade Initiative base code, and typically are SMETA (SEDEX Members Ethical Trade Audit) Pillar 2. This allows for collaboration of the audit findings and improves ways of working, and encourages business improvement, that helps the overall supply chain. We are also working with growers, who via GlobalGAP have added the GRASP module to the third-party audits, (GRASP – Global G.A.P. Risk Assessment on Social Practice), which is committed to social aspects, including worker health & safety and welfare. In certain countries we also work with the recognised local schemes too, this would be in South Africa ( SIZA – Sustainability Initiative of South Africa ) where the platform monitors care for the environment and compliance with labour legislation.
W.B. Chambers Farms Ltd., also has a third-party verification process once every two years, which is against the SMETA audit Pillar 2, on a semi-announced basis, to verify and indicate any key aspects of ethical welfare of it’s workers including the SMETA methodology using the ETI Code and local laws as the measurement tool, it includes Health & Safety and Labour Standards. This was last conducted in 2022 with the next audit mid 2024.
The business employs a significant number of seasonal staff for the main farming activity during the UK Summer months; and increasingly across the winter months. Numbers of these staff come from the European Union, and countries listed in accordance to VISA and Home Office guidelines. Since 2020, the company has been part of the new ‘Visa’ scheme, known as SWS’s (Seasonal Worker Scheme). From the start of the scheme a number of workers had travelled from Ukraine and Moldova, but with the conflict that started in the Spring 2022 in Ukraine, this resulted in a wider list of newer countries where VISA’s could be issued and used. The countries that had been included in the scheme were Kazakhstan, Moldova, Tajikistan and Uzbekistan. Other countries have been included in the SWS scheme included South Africa.
Checks are carried out prior to, and during the recruitment process, and then during the period of employment. As the business has worked with many of the same countries for numbers of years, a good reputation has been established and the exit procedures of the company are just as important.
The business operates to the following aspects: –
- Designated managers who have attended “Tackling Hidden Labour Exploitation” training and have responsibility for developing and operating company procedures relevant to this issue.
- W.B. Chambers works with a non-profit organisation that has a strong reputation for recruiting seasonal workers, this company does not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee. These businesses are registered on the Gangmasters Licensing Authority (GLAA – Gangmasters Licensing Abuse Authority).
- Numbers of staff via word of mouth or previous employees recommend the business to families and friends; the managers responsible for directly recruiting workers are aware of issues around third-party labour exploitation and signs to look for during the recruitment process.
- Labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members with a clear hierarchy and areas of responsibility.
- Proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and local authorities is encouraged.
- “Hidden Labour Exploitation” information and notices are available around all the key farming sites and communal staff areas, in multiple languages to our workforce. This is supported by ‘Just GoodApp’ in association with the main recruitment provider.
- Workers are encouraged to report cases of hidden third-party labour exploitation or other grievances to the site wardens, support teams, or anonymously, which means that swift actions can be taken. Reporting mechanisms can be via the seasonal site wardens and other site wardens, alongside whistleblowing retailer services and comments boxes. Concordia open line 24 hrs per day / emergency phone
- A monthly check of personnel records identifying any duplicate bank accounts, as alert flags that may indicate potential worker exploitation. Printing passport / VISA checks plus EUSS workers (EU Settlement Scheme) and Electronic VISA (EU Countries ) must be kept since April 2023.
Any suspicious duplicates (i.e. not joint accounts for two related workers) are investigated and remedial action is taken as appropriate. New digital banking methods were setup in 2019 and all workers receive their wages via Electronic banking methods such as OnePay and Bank onsite, alongside direct bank transfers. A main High Bank, also sent up an onsite account / and banking workshop. All workers are helped to join one of the payment schemes.
- In 2023 a selected third party company, conducted direct worker reporting survey. This service gathers feedback directly from workers, via their mobile phones, and then summarises the data in an easy-to-understand format. The core questions in the survey are based on SEDEX (and ETI) standards.
- The Home Office and Defra need specific data to be collected on each pilot scheme worker that is placed at Chambers farms. There is a comprehensive list of questions that is required to be completed on a frequent basis, which are checked by the Home Office. The Home Office carried out an audit in September 2023, looking at paperwork, worker interviews and accommodation.
- During 2023, we were audited by our recruitment / introduction companies, by their field officers who check all aspects of workers well-being (Health and Safety, work, pay and accommodation). They interview participants and visit their accommodation, summarizing all the points in a report.
- We have also been working with our employees; and where possible giving guidance / support on ‘Settled and Pre-Settled Status’ so they understand the changes of UK legislation. Proof of return documentation must be provided. This will be submitted via the Government’s website. ‘Pre-settled’ status workers have been granted 2 more years of VISA, following Government guidelines.
In 2023, we continue employing workers on the Biometric Residence Permit for a number of workers with special circumstances issued by the Government.
CEO
Vicky Rye
Business Owner
Tim Chambers