MODERN SLAVERY ACT

COOK SERVE ENJOY MODERN SLAVERY ACT COMPANY STATEMENT

For the period 2020 – 2021

This statement is in accordance with the Modern Slavery Act 2015 and sets out the steps the company has taken to ensure that slavery and human trafficking has not taken place in our supply chains or in any part of our business. We welcome this law and we take active steps in order to tackle the issue of forced labour and human trafficking.

We support the promotion of ethical business policies and practices in order to protect workers from any kind of abuse, deprivation of a person’s liberty, or exploitation, in relation to our business and supply chain.

Addressing ethical compliance has become part of our core business practice and we arm the key members of our team, with the knowledge, understanding and awareness of ethical compliance. This enables us to tackle issues of ethical compliance and modern slavery head on, ultimately taking active steps to affect and improve the quality of workers lives. Upskill (through training) those responsible for new supplier selection in order to strengthen their ability to detect and mitigate modern slavery risks in our supply chain.

INTRODUCTION

Modern slavery is a crime and a violation of fundamental human rights. It takes on 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. We have a zero-tolerance approach to Modern Slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls.

POLICY, COMPIANCE & DUE DILIGENCE WITHIN OUR BUSINESS

Cook Serve Enjoy ensures we comply with all applicable employment laws and commit to ensuring fairness in the hiring and advancement of all colleagues without discrimination. We require all staff to comply with the company’s code of conduct and ethics within all business dealings.

As an organisation we are committed to being best in class by operating ethically and responsibly and with a culture of giving back to society, maintaining our strong family values and sense of making a difference.

We are transparent and regularly review our recruitment processes, ensuring full and stringent verification for all labour providers used.

A culture of openness and accountability is essential with a robust and confidential whistle-blowing policy firmly in place. Our zero-tolerance approach extends to all persons working for us or on our behalf in any capacity.

There is annual circulation to all employees of the company code of conduct, code of ethics, whistle-blowing policy and insider trading policy to further reinforce our stance.

All new employees are made aware of our ethical and compliance standards. As part of this process they are made aware of the indicators that would signal human trafficking and forced labour and how to report and deal with such an instance.

Any recruiters who we engage with for the supply of temporary workers must be licensed by the Gangmasters Labour Abuse Authority (GLAA) and will work to the same strict standards as per our own operating procedures.

POLICY, COMPIANCE & DUE DILIGENCE WITHIN OUR SUPPLY BASE

We operate a zero-tolerance approach to slavery and human trafficking and require our suppliers to ensure they do not use forced labour, bonded or involuntary prison labour within their operation.

We have also embarked on a programme to communicate and regulate our policies to existing and new suppliers, as well as our sourcing agents and employees throughout the business where we make it clear from the outset our expectations; insisting on only working with suppliers who share our ethical values. We encourage open transactions and lines of discussions and work through challenges together with suppliers, with a refusal to trade with them should they offer little or no engagement or transparency.

ASSESSING & IDENTIFYING

We understand the key to assessing risk is to build relationships and build capacity with suppliers and providers where we develop a culture where there is mutual respect and trust in order to understand and offer support in the evaluation of risk. We insist on full transparency and visibility throughout all aspects of our Supply Chain.

Aspects of modern slavery can be extremely subtle, with forced labour, labour trafficking and exploitation of workers often being a hidden blight on global society. Therefore, whilst third party ethical and social audits in factories can offer benchmarks and indicators, we go above and beyond by engaging key factory stakeholders; completion of robust Self-Assessment Questionnaires (SAQ); mapping our supply chains; whilst adopting a diligent approach in our selection of new suppliers through factory visits and our rigorous factory evaluation and verification process.

AWARENESS & COLLABORATION

Cook Serve Enjoy recognise that goods we manufacture and import are at risk of slavery and human trafficking – we will commit to working collaboratively with suppliers in order to raise continued awareness and continually review our verification processes to address and eradicate any such risks. We are actively working towards streamlining our supply base through resourcing projects in order to build upon our relationships and ensure we can reinforce our values with all suppliers.

ASSESSMENT OF EFFECTIVENESS

The following Key Performance Indicators will monitor our effectiveness:

• Investigations undertaken into reports of Modern Slavery and remedial actions taken

• Employees knowledge of Modern Slavery spotting the signs and how to report

• Actions taken to improve communication of our expectations to suppliers and customers – Circulate Modern Slavery & Trafficking Policy to our suppliers and customers as well as obtaining copies of their own policy and statement.

• Internal training to improve awareness amongst the senior and operational management teams.

• Implementation of further checks and audits

1. HR undertake monthly checks on duplicate accounts and addresses.

2. Operations to check for common telephone numbers, duplicated emergency contact details.

3. HR view the workers bank card/bank statement to ensure they are named on the account – salary payments will only be made into worker named bank accounts.

4. HR cross-reference bank details and name and ensure the account holder is in possession of his/her bank card.

5. HR request copies of tenancy agreements to identify any common landlord details where duplicated addresses exist.

The Key Performance indicators as indicated above suggest that in 2019-20 there were no issues of Modern Slavery or human trafficking in the Cook Serve Enjoy supply chain. We will continue to apply the indicators and maintain vigilance as to their appropriateness.

COOK SERVE ENJOY’S COMMITMENT

All businesses must play their part in tackling Modern Slavery and combatting it effectively requires improved traceability, increased transparency and through working collaborations. Cook Serve Enjoy will commit to review annually our Modern Slavery policies to ensure its relevance, whilst factoring in social and economic factors and changes. We will continue to maintain our SEDEX membership and continue to strive to assess and improve on all ethical business practices and assessment of risks, current and new. Our policies, procedures and approach to ethical compliance are geared towards what we believe to be balanced, reasonable, effective and practical.

This statement has been approved by the Cook Serve Enjoy board of directors.

Matthew Canwell

Managing Director, Cook Serve Enjoy (wholly owned by Lifetime Brands Europe Ltd)

Extracts taken from:

KCQD11 – Cook Serve Enjoy Policy of compliance within the supply chain document

Quoc Nguyen – UK Quality Manager

May 2016