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Weetabix Limited –
Slavery and Human Trafficking Statement

Weetabix Limited – Slavery and Human Trafficking Statement

1. Introduction

This statement is made by Weetabix Limited (Weetabix) for itself, its subsidiaries and its parent companies, Westminster Acquisition Limited (WAL) and Westminster U.K. Holdings Limited (Holdings) (Weetabix, WAL and Holdings, together defined as Group). It is a statement made in accordance with section 54 of the Modern Slavery Act 2015 (the MSA) and covers the financial year from 1 October 2022 to 30 September 2023 (the Financial Year).

The Group and its trading subsidiaries are companies that strive to do things in the right way and we recognise our responsibility to be aware of the risks of modern slavery and human trafficking within our own Group and supply chain.

2. Background

Our Northamptonshire production units currently export to over 80 countries around the world. We employ around 1,100 staff members internationally, with the majority based within the UK, undertaking a range of roles including marketing, sales, manufacturing, finance, IT, HR, compliance and export. We also have employees undertaking sales and marketing roles based in Spain and UAE and distribution relationships globally.

We use agency labour in our UK manufacturing areas, which is sourced through reputable recruitment agencies. We also have third party suppliers on site who provide contractors. We outsource certain services where specific expertise may be required and a number of non-key activities, such as engineering support, site maintenance and logistics are also outsourced. Appropriate right to work checks are conducted in partnership with those agencies.

All of the wheat for our Weetabix original range is grown within 50 miles of our Burton Latimer production units by our Weetabix Growers Group, which is formed of around 120 approved growers dedicated to best practice and responsible production over 4 million acres of British countryside. Over 80% of our Weetabix Growers Group have been supplying us with wheat for more than five years and we’ve implemented a programme that allows consumers to understand more clearly where the wheat contained within their box of Weetabix original has come from.

Within our contracted direct supply chain, there are 64 different raw material and co-managed suppliers, 31 contracted packaging suppliers and 20 co-manufacturing suppliers. Our indirect supply chain currently consists of 889 active suppliers.

We have carried out a review of our direct supply chain and have concluded that the risks of modern slavery and human trafficking are low. However, we acknowledge that we must remain vigilant to the risks and ensure that our suppliers understand and play their part in ensuring that modern slavery and human trafficking does not take place in our organisation or in our supply chains. This message is reiterated to our suppliers via our supplier assessment and relationship management programme and at the time of publication of our 2023 Sustainability Report 98% of our ingredient suppliers have signed up to our updated procurement standard. This represents an increase of 7% and we will continue to work towards moving that to 100% throughout 2024.

Our fourth published Sustainability Report also contains details of our commitments to responsible production at every step of the journey from farm to spoon. 100% of our packaging is now widely recyclable and over 5 million litres of water are being saved annually by capturing and reusing condensate in our manufacturing process. We continue to donate over 3 million breakfasts to FareShare and Magic Breakfast in the past year to ensure healthy breakfasts for those who need them in support of our wider communities.

As part of our work to encourage people to live healthy lives we have continued our partnership with the English Football Association and the Football Association of Wales which supports a young girls’ football initiative known as the Weetabix Wildcats and the Weetabix Huddle.

We continue to work with other supply chain bodies to ensure our ingredients are supplied to recognised sustainability standards. All cocoa that we source is 100% Rainforest Alliance certified sustainable cocoa. We have also maintained our Roundtable on Responsible Palm Oil (RSPO) certification. We are members of the Round Table for Responsible Soy (RTRS), supporting responsible production of soy through the purchase of RTRS credits. In 2023 we repeated our Wheat Carbon Footprint Study with more growers for the 2022 harvest. This showed, for those that took part in the study, that they use fertilizer very efficiently. This reduces water pollution and improves biodiversity. We’ve also developed a roadmap to source net carbon zero wheat.

To find out more about what we do, please go to https://www.weetabixfoodcompany.co.uk.

3. Relevant Policies and Contracts

To reinforce our commitment to combating slavery and trafficking, we have implemented the following policies, which set out our zero-tolerance approach to modern slavery, both within our own operations and our supply chain:

(a) Our Ethical Trading Policy applies to all our operations and those in our supply chain. This Policy makes specific reference to our zero-tolerance stance on modern slavery. This Policy was updated in 2023.
(b) We have published guidance to our employees through our internal Anti-Slavery Policy available on our intranet, which applies to all those working for us or on our behalf (and which includes contractors and agency workers).
(c) We have a robust supplier set up process when engaging with new suppliers, contractors and business partners to ensure that they are aware of and will adhere to our Ethical Trading Policy and to assess the likelihood of slavery or trafficking existing in those organisations and what measures are already in place to combat those risks. We continuously strive for further process efficiency in pursuit of our “Change for Even Better” strategy.
(d) We have a Whistleblowing Policy in place and a Speak Up Line.
(e) We put in place confidentiality agreements containing Anti-Slavery clauses with potential suppliers prior to working with them.
(f) Our supplier contracts contain comprehensive Anti-Slavery clauses, and we have framework agreements or terms & conditions in place with 98% (measured against spend) of our direct raw materials and packaging suppliers.
(g) Our ultimate parent company launched a global Code of Conduct in 2018 which fits with our principles and values here at Weetabix. This Code provides support to our employees in making day to day ethical decisions in addition to the policies already in place. Our office-based staff in the UK and overseas are required to complete the Ethics and Code of Conduct training annually.
(h) We operate a due diligence tool aimed specifically at combatting money laundering and breach of US trade sanctions. This tool identifies any risks of transacting with a supplier and one measure is the existence of comprehensive Anti-Slavery clauses. This tool is used by all of our subsidiaries.

4. Risk assessment processes

We have considered the risk of modern slavery in our own operations and we have concluded that, on the basis that we are a UK employer subject to UK employment protections and practices and already have well developed checks and balances within our business, we have a low risk of modern slavery occurring in our own operations.

Our suppliers which fall into the following categories adhere to the Weetabix Standards, which include a requirement to abide by the Ethical Trading Terms and Conditions or have equivalent policies in place Policy and they are strongly encouraged to consider membership of Sedex, the global organisation that helps businesses share responsible sourcing data on supply chains:-

• Suppliers of Ingredients to Weetabix
• Suppliers of Packaging Materials to Weetabix
• Those involved in the co-manufacturing, co-packing and licensed manufacture of
Weetabix brands.

We have considered the risk of modern slavery occurring in our use of external labour via employment agencies and our direct suppliers. Given the organisations that we work with and who also have a zero-tolerance approach to modern slavery and the existing checks and balances that we apply in these areas, we have concluded that the risks of modern slavery are low in this area.

5. Due diligence processes

In order to prevent slavery and trafficking in our business and supply chains, we have taken steps to update and improve our supplier due diligence process with terms and conditions in place with suitably robust Anti-Slavery clauses. For certain of our procurement activities, a competitive tender process is required, and which requires at the pre-qualification questionnaire stage that any potential supplier is compliant with the MSA before the organisation can progress to the next stage of the procurement process. Compliance with applicable law is part of our scoring criteria.

Our standard non-disclosure agreement also includes an undertaking that any potential entity with whom we might work will also comply with the MSA.

6. Training

To raise awareness of slavery and trafficking, and of our policies and procedures, we have an established induction and continuous learning approach to training employees in this area using our compliance calendar and our Weetalearn platform.

We have dedicated compliance modules covering key compliance areas, including Anti- Slavery, Anti-bribery, Ethics and Code of Conduct. Our Code of Conduct training runs annually for all graded employees.

7. Measuring effectiveness – performance indicators

In order to monitor the effectiveness of the steps we have taken to stop slavery and trafficking taking place in our business and supply chains, we will use the following performance indicators for the financial year ahead:

• Completion rates for the mandatory Code of Conduct training completed by office-based staff. In 2023 completion rates were 96%.
• We monitor and categorise concerns reported to us (either via our Speak Up line or any other channel). Since inception in 2018, no concerns have been reported in relation to modern slavery and/or human trafficking.
• We will ensure that we continue to have terms and conditions in place with our direct and indirect supply chain that require MSA compliance as a key term.
• We will ensure that we have terms and conditions in place with our co-manufacturing partners.

As referenced in this statement, we will monitor the need for further action to be taken and other key performance indicators to be implemented as we continue our risk assessment and due diligence activities.

This statement has been approved by the Weetabix board of directors who review this statement and update it annually.

Signed on behalf of the Board of Directors by Sally Abbott, Managing Director

January 2024