This policy is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that John Pointon and Sons Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced or child labour. We strictly prohibit any form of modern slavery and are committed to conducting business ethically and with integrity and have a number of effective policies and internal controls in place to safeguard against any form of modern slavery taking place within our business or supply chain.
We are also committed to ensuring transparency in our business and in our approach to tackling modern slavery throughout our supply chains. We expect our contractors, suppliers and other business partners to adopt the same high standards and as part of our contracting process we prohibit the use of forced, compulsory or trafficked labour, or the holding of anyone in slavery or servitude, whether adult or children, and we expect that our suppliers will require the same high standards from their own suppliers.
This policy applies to all persons working for us in any capacity, including employees at all levels, directors, officers, agency workers, volunteers, contractors, consultants, third party representatives and business partners.
Responsibility for the Policy
The board of directors has the overall responsibility for ensuring this policy complies with our legal and ethical obligations and for ensuring that all those acting for or on behalf of the company comply with the policy.
The HR Manager has day to day responsibility for implementing this policy and monitoring its use and effectiveness, dealing with any queries about the policy and auditing internal control systems to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on the issue of modern slavery in supply chains.
Compliance with the Policy
All employees must ensure they have read and understood the policy so that they can comply with it
The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all persons working for or with us. All persons engaged with us must avoid participating in any activity that may lead to, or suggest a breach of this policy.
Any person who believes that a conflict with this policy has occurred, or may occur in the future should inform the HR Manager immediately
All persons working for or with us are encouraged to raise any concerns or suspicions of modern slavery in any part of our business or supply chain as soon as they arise.
Any employee who believes or suspects that a breach of this policy has occurred or may occur must notify the HR Manager or report it in accordance with our whistleblowing policy.
Any employee who is unsure as to whether the treatment of workers or their working conditions within our supply chain constitutes a form of modern slavery should speak with the HR Manager immediately.
The objective of this policy is to encourage openness and we will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery may be taking place in any part of our business or supply chain. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
Communication and Awareness of the Policy
Training on this policy, and the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all persons who for us, and regular training will be provided as necessary.
Modern Slavery and Human Trafficking Statement
John Pointon & Sons is the largest independent animal by-product and pet food ingredient supplier in the UK. From inception through to today, we are a family owned business which has been providing a first-class service for over 40 years. We offer sanitary collection services to a range of customers including butchers, slaughterhouses, supermarkets and food processors. Since our humble beginnings, we’ve been reclaiming animal by-products from the meat processing industry such as bones, fats, offal, blood & feathers and rendering them to produce high-quality fats/oils, processed animal proteins and biomass fuels.
We are a valued local employer and currently employ over 260 individuals in a variety of roles, ranging from process operatives to electrical engineers. We currently process over 300,000 tonnes of by-products per annum and our annual turnover is now in excess of £35million. We are also an approved and trusted partner of the UK Government by providing logistics, rendering and technical expertise in their contingency operations.
In addition to this policy we also operate a number of other internal policies to ensure that we are conducting business in an ethical and transparent manner, including but not limited to:
- Human Rights Policy. This policy sets out our commitment to the protection of individuals fundamental human rights.
- Recruitment & Selection Policy. We operate a robust recruitment policy which includes pre-employment checks designed to safeguard against human trafficking or employees being forced to work against their will.
- Whistleblowing Policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
We conduct due diligence on all potential suppliers before they can be approved to our preferred supplier list. This requires research into the proposed supplier in order to ascertain whether they have been convicted of offences relating to Modern slavery or Human Trafficking. We also conduct site audits on all proposed suppliers to ensure that their working conditions meet our required standards. This Modern Slavery and Human Trafficking policy forms part of any contract we make with suppliers and they are required to confirm that no part of their business operations contradicts this policy.
We require all suppliers to confirm that:
- They have taken steps to eradicate modern slavery within their business
- They hold their own suppliers to account over modern slavery
- Where our suppliers are UK based we require that they pay their employees at least the national minimum wage/national living wage
- Where a supplier is based internationally we require that they pay their employees any prevailing minimum wage applicable within their country of operation.
- They understand that we will terminate any contract immediately if they are found to be guilty of offences under the Modern Slavery Act 2015
We undertake training with our procurement team so that they are confident in their ability to recognise modern slavery and they know what to do if they suspect that it may be taking place within our supply chain.