1
INTRODUCTION FROM THE CHIEF EXECUTIVE OFFICER
Modern slavery is a crime and a violation of
fundamental human rights. It takes various forms, such as slavery, servitude,
forced and compulsory labour and human trafficking, all of which have in common
the deprivation of a person’s liberty by another, in order to exploit them for
personal or commercial gain.
Our commitments:
To act ethically and with integrity in all
our business dealings and relationships and to implement and enforce effective
systems and controls to ensure modern slavery is not taking place anywhere in
our own business or in any of our supply chains.
To ensure transparency in our own business and in
our approach to tackling modern slavery throughout our supply chains,
consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all our contractors, suppliers and other
business partners, and as part of our contracting processes, we include
specific prohibitions against the use of forced, compulsory or trafficked
labour, or anyone held in slavery or servitude, whether adults or children, and
we expect that our suppliers will hold their own suppliers to the same
standards.
To improve our practices to combat slavery and
human trafficking. KellyDeli Company Limited, as the holding group of the ‘KellyDeli
Group’ (defined below), is taking steps to ensure compliance with legislation
relating to Anti-Slavery and Human trafficking, as well as doing its utmost to
go above and beyond these requirements. KellyDeli has taken, and continue to
take, these positive actions to combat these unfortunate trends.
2
OUR STRUCTURE AND SUPPLY CHAINS
We are a global food retail and restaurant group.
We are the parent group of the KellyDeli subsidiaries in the following
countries: France, Belgium, Spain, Italy, United Kingdom, Germany, Netherlands,
Sweden, Denmark, Finland, Portugal and Mexico (“KellyDeli Company Ltd”). As of
December 2021, the Group had 412 employees across the world.
2.1
OUR BUSINESS
KellyDeli is an innovative food group committed
to bringing the best of Asia to the world, through Asian-inspired brands and
over 1000 kiosks across Europe, The United Kingdom and Mexico. KellyDeli is a
franchisor supporting a network of independent kiosk owners preparing and
offering for sale Asian inspired food in supermarkets, hypermarkets and
similar.
2.2
OUR SUPPLY CHAINS
Our supply chains include over 50 suppliers
throughout Europe who supply products to each of our kiosks. These suppliers
range from large scale cross-country suppliers to local small-scale suppliers.
3
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
Our Human Rights Policy and supplier
questionnaire reflects our commitment to acting ethically and with integrity
all our business relationships and to implementing and promoting effective
systems and controls.
Other policies include equality,
whistleblowing, harassment & bullying, and code of business conduct.
In 2021 KellyDely has included as part of their
suppliers contracts several "ethical" obligations. All contracts are
reviewed to ensure consistent ethical obligations are met.
4
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and
mitigate risk we have a free whistleblowing line, available to all employees. The
aim is to:
• Identify and assess potential risk
areas in our supply chains.
• Mitigate the risk of slavery and
human trafficking occurring in our supply chains.
• Monitor potential risk areas in our
supply chains; and
• Protect whistle blowers.
In 2021, KellyDeli joined a global
collaboration platform to improve supply chain transparency. The aim of this
new tools is to allow the group to proactively identify social and
environmental risks and engage their suppliers on this journey.
Where an issue is spotted at suppliers of
partners level, a corrective action plan is requested. If the action plan does
not sufficiently address the issue, the contract will be at risk of
termination.
5 RISK ASSESSMENT
KellyDeli is committed to respecting and
protecting human rights of all those who are in contact with its operations,
including employees, partners and supply chain workers. KellyDeli supports
transparency, to find and resolve problems; to regularly review business
practices; and to collaborate to protect the rights of workers, particularly
those who are most vulnerable and exposed to abuses such as modern
slavery.
A detailed risk assessment is key to help focus
on the areas where we face the greatest risk. The introduction of policies and
training for our people helps identify any signs of modern slavery and empowers
them to act accordingly.
6 MEASURING EFFECTIVENESS
In 2020, we strengthened and
developed the effectiveness of our risk management processes. KellyDeli
appointed a General Counsel reporting directly to the CEO and a head of
employees relations to strengthen further its commitment. Several
new policies were implemented in 2020 spanning equality, whistleblowing,
harassment & bullying, and code of business conduct.
KellyDeli have an ethical
task force, dedicated to plan, assess, and continuously promote best practices
related to human rights, ethics, and equality. The role of the task force is to
actively manage any potential risk linked with human rights breaches and to ensure
continuous improvement in this arena.
A free and completely
independent whistleblowing tool is available to all employees. The whistleblowing
hotline and online reporting allows employees to speak up and report their
concerns to the highest levels of management (a freephone telephone and the
SafeCall website), available to all KellyDeli employees and partners, 24 hours
a day and 365 days per year.
In 2021, KellyDeli joined a
global platform allowing to better assess social and environmental risks by
countries of operations and industries. The system enables KellyDeli to access their
suppliers social and environmental audits and assess their progress against a
set of internationally recognised standards.
7
TRAINING
In 2021, we moved all employee and partners’ training
programs to an online platform, including human rights, responsible
recruitment, diversity and inclusion as well as modern slavery. KellyDeli’s
values are fully integrated in the policies and partners’ practices through
their onboarding programme and online training suite. The group updates and creates
new modules regularly to make sure partners are armed with a strong knowledge
base in all areas relating to fundamental values we believe in.
We are committed to respecting and protecting
human rights of all who come into contact with our operations, including
employees, partners and supply chain workers. We accept our responsibility to
support transparency, to find and resolve problems; to regularly review our
business practices; and to collaborate with others to protect the rights of
workers, particularly those who are most vulnerable to abuses such as modern
slavery.
This statement is made pursuant to section
54(1) of the Modern Slavery Act 2015 and constitutes KellyDeli Company’s
slavery and human trafficking statement for the financial year ending December 2021.
This statement will be presented to the board on 7 July 2022.
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