Modern Slavery Act
St Pierre Groupe Modern Slavery Statement for Financial Year 2022/23
St Pierre Groupe is an international bakery business, which supplies European bakery products to the UK, USA and Middle East markets. Its suppliers are based within Europe and Canada.
The company is committed to eradicating Modern Slavery throughout its business. This policy outlines the steps that St Pierre Groupe (SPG) has taken and will continue to take, to ensure that modern slavery or human trafficking is not taking place within its business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. St Pierre Groupe has a zero-tolerance approach to any form of modern slavery, acting ethically and with integrity and transparency in all its business dealings. It is also committed to ensuring effective systems and controls are put in place to safeguard against any form of modern slavery taking place within its business or supply chain.
St Pierre Groupe Commitment
The business adheres to a number of policies and operates multiple procedures to ensure it conducts business in an ethical and transparent manner. These include:
- Recruitment Policy. SPG operates a robust recruitment policy, including conducting eligibility-to-work-in-the-UK checks for all employees, to safeguard against human trafficking or individuals being forced to work against their will.
- Public Interest Disclosure Policy. This ensures that employees know that they can raise concerns about how colleagues are being treated, or practices within the business or supply chain, without fear of reprisals.
- Professional Code of Conduct. This code explains the manner in which the organisation behaves and expectations of employees within it.
- Equal Opportunities Policy. This policy is to ensure fair treatment of all employees within the business environment.
- National Living Wage. This ensures that all employees of St Pierre Groupe receive pay in line with or above the national living wage.
- Health & Safety. SPG ensures that appropriate health and safety procedures are in place and training is provided to all, ensuring a safe and clean working environment.
- Gifts, Entertaining, Conflicts of Interests and Bribes Policy. Ethical difficulties can arise when an employee is offered hospitality, gifts or personal services by a supplier or a customer. SPG operates a robust policy to ensure criminal activities, such as bribery, do not occur.
- St Pierre Groupe is a member of SEDEX, which enables the assessment and mapping of its supply chains and ensures responsible sourcing is carried out at every level.
- Supplier Code of Conduct. This policy sets out current and future expectations of any and all suppliers. All SPG suppliers must comply with these guidelines in order to agree business with the company. Suppliers must demonstrate their own policies – including those related to the eradication of modern slavery or trafficking, as part of this agreement.
Our Bakery Partners
St Pierre Groupe operates a supplier Code of Conduct and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search, including use of its SEDEX membership, to ensure that the organisation has never been convicted of offenses relating to modern slavery. The SPG anti-slavery policy forms part of its contract with all suppliers and they are required to confirm that no part of their business operations contradict this policy.
Other due diligence steps include:
- Ensuring new suppliers uphold all standards and requirements in the SPG Supplier Code of Conduct before adding them into the supply chain
- Annual review and mapping of supply chain
- Annual risk assessment of full supply chain including further analysis of how high-risk areas have improved. One way of doing this can be asking them to complete a modern Slavery Act Due Diligence Questionnaire, which covers their governance, policies, training and supply chain
- Staff training on Modern Slavery Act 2015 within 12 months of the Bill being updated
Approval for this statement
This statement was approved by the Board of Directors on 23/11/22
Name: David Wagstaff
Date: 23rd November 2022