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 Company Ltd’ (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 2022, the Group had 493 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
Asianinspired 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. KellyDeli also has a presence in UAE via a franchisor
agreement.
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 KellyDeli 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.
In 2022 two Managers from
KellDeli were trained to use Radar - a risk Management tool - allowing us to
better scope and assess potential risks across our operations and supply chain.
We conducted a risk assessment of our supply chain by product and country of
operations and were able to flag higher risk suppliers (prawn farming /
fisheries) and from a location perspective, two countries (Mexico and UAE) of
operations being flagged as medium risks.
6 MEASURING
EFFECTIVENES
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. They are regularly reviewed.
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, 24 hours a day and 365 days per
year.
In 2022, we also set up an
internal confidential email address allowing our partners and their employees
to report or raise concerns. In 2022 no complaint was raised.
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.
In 2022, 87% of all employees
completed the anti-modern slavery training and 89% completed the diversity and
inclusion e-learning module.
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 2022. This statement has been presented to the board on 25 July 2023.