Modern Slavery Statement

Modern Slavery Statement 2023 – 2024

This statement sets out the steps that Suma Wholefoods has taken to ensure that modern slavery or human trafficking does not take place within our business or supply chain during the period from October 2023 to September 2024. This year has seen some good progress which will be discussed in greater detail below. To summarise; Suma’s Buying Policy was reviewed and updated, Our Supplier Ethical Questionnaire (SEQ) was reviewed and updated, updating our SEQs on file (98.8% of stock suppliers on file), Action plan in process to support our long-term strategy and overarching business objectives.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Forced or unfree labour is when a person is forced into undertaking work for little or no money. 28 million people are in forced labour worldwide and more than 122,000 people are in modern slavery in the UK – although the figures are most likely much higher (Unseen, 2024). This is a 22% increase to last years’ figures. Suma has a zero-tolerance approach to any form of modern slavery. We are committed to acting with integrity and transparency in all business dealings and maintaining effective systems and controls to safeguard against modern slavery and other human rights violations within our business and supply chain.

Our structure, governance and supply chains

Suma is a fully democratic worker co-operative compromising of a blended workforce; members, trial members (TMs) and fixed term workers. All co-operative members and employees receive the same gross hourly rate of pay, no matter what their job or responsibilities. We also often deal with external organisations and contractors for various services both onsite and offsite. We have had a Bakers, Food and Allied Workers Union branch for over 30 years.

We operate from three linked sites – our base, in Elland, West Yorkshire, a hub in London and a hub in Bristol. All workers are based in the UK at one or more of these sites. Suma is the UK’s largest independent wholefood wholesaler/distributor, specialising in vegetarian, fairly traded, organic, ethical and natural products from all around the world. Meaning that our supply chains are complex and require a lot of attention.

Suma brand products

Suma have three brands, Suma for our food range including our organic products, Ecoleaf by Suma which is our household cleaning products, and Alter/native by Suma which is our body care range.

Our policies relating to slavery and human trafficking

We continue to be guided by our internal Modern Slavery policy which was implemented and signed off by the Board in July 2022. One of the foundations of our internal policy is that of continuous improvement and that has catalyzed Suma to re-visit and fortify our Buying Statement (completed) and our Recruitment Policy (still in review stage). The planned work on reviewing and updating our Buying Policy was agreed by an all work consultation and was signed off by the Board July 2024. The reviewed Buying Policy was a marked improvement, was more holistic and comprehensive – providing clarity for Suma workers specifically the Buyers. Emphasising what we expect from our suppliers and what sets us apart from our competitors. To compliment this work the SEQ was also updated to ensure that they aligned with one another and made sure it served more as a preventative control to mitigate the risk of onboarding a supplier which did not align with our values. Of course, there is still largely an element of trust between Suma and our Suppliers as we accept that what is shared with us is accurate.

The measures we take to protect our workforce

We continue to operate a number of related policies to ensure that we are conducting business in an ethical and transparent manner. These include our:

1. Recruitment policy. We operate a 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.
2. Whistleblowing. All new starters are issued with an induction pack stating that ‘whistleblowing’ (as defined by the Public Interest (Disclosure) Act 1998) will not be deemed a ‘serious breach of Confidence’ under the terms of our Disciplinary and Dismissal procedures.

We continue to align ourselves to the Ethical Trading Initiative Base Code which consists of the following criteria:

1. Employment is freely chosen
2. Freedom of association and the right to collective bargaining are respected
3. Working conditions are safe and hygienic
4. Child labour shall not be used
5. Living wages are paid
6. Working hours are not excessive
7. No discrimination is practised
8. Regular employment is provided
9. No harsh or inhumane treatment is allowed
10. Our new supplier approval process is built around ensuring that suppliers are fully compliant with this code.

Our due diligence processes

In line with our plans set out last year we risk assessed our supply chain based on data that we had on our systems. What this work uncovered was the requirement for firstly, more granular data, and a bespoke approach depending on the supplier, product and industry (Food, Household Cleaning products, Bodycare, Household). Based on the UN guiding principles on human rights there is a framework to identify whether Suma ‘owes remediation’ ie needs to act to avoid negative impacts based on three definitions: ‘cause’, ‘contribution’ and ‘directly linked to’. To determine in which category the activity falls into a worksheet was developed that would ask a business to take the following questions in to account:

Questions to ask ourselves to establish Suma’s contribution to adverse impacts

1. Did Suma’s actions on their own cause the human rights violation?
2. Did Suma facilitate, enable or incentivize other parties to cause harm?
3. Could Suma have known about or foreseen the potential harm?
4. How specific was the connection between Suma’s operations and the harm?
5. Did Suma take steps that likely could have prevented the harm from occurring?
6. Did Suma directly benefit from the negative impact?
7. Do stakeholders and rightsholders believe that Suma caused, contributed or was directly linked to the harm, or that the company should otherwise provide or contribute to remedy?

Stronger Together Training

1. Commit – As an organization Suma has gone beyond legislative obligations. We have an internal Modern Slavery Policy embedding this work throughout our business. Our Vision, Mission and Sustainability Strategy all guide Suma towards a fair and transparent supply chain.
2. Assess – We have devised a methodology on how to assess the risk in our supply chain, we hope to improve it.
3. Implement – Towards the end of our business year the ESCWG met for reflection session and to plan the next few years of actions and projects.
4. Remedy – We are yet to propose and commit to specific solutions
5. Monitor – We actively try to monitor our progress, we hope to improve it.
6. Communicate – via this statement and other communication channels we try to be transparent and honest regarding our efforts. We still are yet to devise an appropriate method of communicating our work effectively internally.

Key indicators:

1. Suma have not been notified or uncovered any issues regarding worker welfare in our supply chain to date.
2. None of our suppliers are featured in campaigns or articles from pressure groups and publications such as The Food Empowerment Project, Ethical Consumer etc.
3. No reports have been received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Steps taken to assess risk in our supply chain

Our supply chains are global and complex. We operate a predominantly food-based business and the agricultural industry carries a lot of risk. We continue to use historical methods and always strive for continuous improvement despite the complexity and challenges in our supply chains.

Supplier Ethical Questionnaire & Supplier Code of Conduct declaration

We continue to use our SEQs on the onboarding process. Our SEQ was reviewed and updated to be a more comprehensive and helpful document, the SEQ and Code of Conduct were combined into one document. The year 23/24 was almost entirely dedicated to the Buying Policy Revision and SEQ revision and required mass data collection. We now, only have 6 outstanding SEQs out of approximately 450 suppliers.

Supply Chain working group

This cross-departmental group meet monthly (sometimes every 2 months based on availability) to discuss and act on our supply chain risks and opportunities. A valuable piece of work of updating our terms of reference had to occur in the first instance as there were new members and new objectives. An important distinction was highlighted during this work that the groups sole focus would be on stock and not non-stock. This inevitably creates a gap on non-stock, which will be covered in the non-stock Procurement policy. As mentioned above the groups efforts year 2023/2024 was to ensure we adhered to our internal modern slavery policy by ensuring we had an SEQ and Code of Conduct declaration from every single one of our stock suppliers The Buyers were fully engaged and after many months of hard work, by the end of Suma’s financial year 2024 we had 98.8% of the updated Supplier Ethical Questionnaires on file.

Sedex membership

We have renewed our membership to Sedex which allows us to have support to gain better insight of our supply chains, assess our risks, report any negative impacts and comply with legislation. We try to advise some of our relevant suppliers to have a membership, or at least sign up to similar accreditation schemes that serve a similar function.

Update on last year’s plans and commitments

Buying Policy

Reviewed and Completed

Supplier Ethical Questionnaire

98.8% on file for stock suppliers, there needs to be an assessment on how to deal with outstanding SEQs

Delisting Process

In progress, finalised by end of Q1.

Recruitment Policy

In progress, about to go out for all work consultation.

Contractors Process

In progress, implementation planned end of Q4 – September 2025

Non- stock Procurement Process

In progress, initial consultation complete, trialling planned for the start of 2025, completion planned end of Q4 – September 2025

Supply Chain Risk Assessment

The ESCWG undertook risk assessments based on various global indices: Vulnerability Index, GINI co-efficient and Corruption Perception Index. Many factors impact the likelihood of modern slavery and broader human rights abuses. Environmental and Climate change range risks were also included but that was to analyse different forms of overall supply chain risks.

What the future holds

To align with our current strategy and overarching business objectives the ESWG have set up a long-term plan which will include focusing on: Cocoa, Tomatoes and Top 50 Suma brand food products, Top 50 Suma non-food products, which is entirely Ecoleaf and Alter/native and based on the information collected carry out risk assessments in each category. We will focus on Cocoa in the first instance, the response rate has already been positive which is encouraging.

Within with the Contractor work, there will be an incorporation of trying to signpost visitors on the Elland site to local and national organisations that try to combat Modern Slavery, generally raising awareness in our local area.

We still acknowledge our duty as an organization to contribute to the universal Sustainable Development Goals. Paying particular attention to Target 8.7 and 8.8 which state:

Target 8.7: Take immediate and effective measures to eradicate forced labour, end modern slavery and human trafficking and secure the prohibition and elimination of the worst forms of child labour, including recruitment and use of child soldiers, and by 2025 end child labour in all its forms.

Target 8.8: Protect labour rights and promote safe and secure working environments for all workers, including migrant workers, in particular women migrants, and those in precarious employment.

Modern Slavery training will be mandatory to employees who fulfil specific roles and functions within the business.

If you have any further questions or want more detail on the work Suma is undertaking please don’t hesitate to get in touch: [email protected]

References

unseenuk.org, About Modern Slavery/

Modern Slavery Statement 2022 – 2023

This statement sets out the steps that Suma Wholefoods has taken to ensure that modern slavery or human trafficking does not take place within our business or supply chain during the period from October 2022 to September 2023. This year has not been filled with as much progress as we had hoped. It was a challenging business year for Suma due to lack of resources and gaps in our teams. However, towards the end of this period we were able to fill key roles, and the Supply Chain Working Group was restarted which has enabled this body of work to be revisited and prioritized.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Forced or unfree labour is when a person is forced into undertaking work for little or no money. 28 million people are in forced labour worldwide and more than 100,000 people are in modern slavery in the UK – although the figures are most likely much higher (Unseen, 2023). Suma has a zero-tolerance approach to any form of modern slavery. We are committed to acting with integrity and transparency in all business dealings and maintaining effective systems and controls to safeguard against modern slavery and other human rights violations within our business and supply chain.

Our structure, governance and supply chains

Suma is a fully democratic worker co-operative compromising of a blended workforce; members, trial members (TMs) and fixed term workers. All co-operative members and employees receive the same gross hourly rate of pay, no matter what their job or responsibilities. We also often deal with external organisations and contractors for various services both onsite and offsite. We have had a Bakers, Food and Allied Workers Union branch for over 30 years.

We operate from three linked sites – our base, in Elland, West Yorkshire, a hub in London and a hub in Bristol. All workers are based in the UK at one or more of these sites. Suma is the UK’s largest independent wholefood wholesaler/distributor, specialising in vegetarian, fairly traded, organic, ethical and natural products from all around the world. Meaning that our supply chains are complex and require a lot of attention.

Suma brand products

Suma have three brands, Suma for our food range including our organic products, Ecoleaf by Suma which is our household cleaning products, and Alter/native by Suma which is our body care range.

Our policies relating to slavery and human trafficking

We continue to be guided by our internal Modern Slavery policy which was implemented and signed off by the board in July 2022. One of the foundations of our internal policy is that of continuous improvement and that has catalyzed Suma to re-visit and fortify our Buying Statement and our Recruitment Policy. Although we still adhere to our current Buying Statement – there is ongoing work to try to make it more robust and more comprehensive. We want to embed Suma’s principles to our buying practices by creating a Buying Policy. By the same token, work has also begun to strengthen our supplier approval process and risk management system.

The measures we take to protect our workforce

We continue to operate a number of related policies to ensure that we are conducting business in an ethical and transparent manner. These include our:

1. Recruitment policy. We operate a 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.
2. Whistleblowing. All new starters are issued with an induction pack stating that ‘whistleblowing’ (as defined by the Public Interest (Disclosure) Act 1998) will not be deemed a ‘serious breach of Confidence’ under the terms of our Disciplinary and Dismissal procedures.

We continue to be committed to the Ethical Trading Initiative Base Code which consists of the following criteria:

1. Employment is freely chosen
2. Freedom of association and the right to collective bargaining are respected
3. Working conditions are safe and hygienic
4. Child labour shall not be used
5. Living wages are paid
6. Working hours are not excessive
7. No discrimination is practised
8. Regular employment is provided
9. No harsh or inhumane treatment is allowed
10. Our new supplier approval process is built around ensuring that suppliers are fully compliant with this code.

Our due diligence processes

We have committed to reviewing our supply chain annually to identify high-risk regions, industries and goods. Further research and investigation have been prioritised according to the highest risk areas, and we are in an ongoing process of trying to surmise an affective supplier-level information gathering method and action plan to address areas of concern

Based on the UN guiding principles on human rights there is a framework to identify whether Suma ‘owes remediation’ ie needs to act to avoid negative impacts based on three definitions: ‘cause’, ‘contribution’ and ‘directly linked to’. To determine in which category the activity falls into a worksheet was developed that would ask a business to take the following questions in to account:

Questions to ask ourselves to establish Suma’s contribution to adverse impacts

1. Did Suma’s actions on their own cause the human rights violation?
2. Did Suma facilitate, enable or incentivize other parties to cause harm?
3. Could Suma have known about or foreseen the potential harm?
4. How specific was the connection between Suma’s operations and the harm?
5. Did Suma take steps that likely could have prevented the harm from occurring?
6. Did Suma directly benefit from the negative impact?
7. Do stakeholders and rightsholders believe that Suma caused, contributed or was directly linked to the harm, or that the company should otherwise provide or contribute to remedy?

Stronger Together Training

1. Commit – As an organization Suma has gone beyond legislative obligations. We have an internal Modern Slavery Policy embedding this work throughout our business. Our Vision, Mission and Sustainability Strategy all guide Suma towards a fair and transparent supply chain. It is important to mention that due to lack of resource and gaps in our team, progress this year has been slower than hoped.
2. Assess – We have devised a methodology on how to assess the risk in our supply chain, we hope to improve it.
3. Implement – We are yet to devise an action plan
4. Remedy – We are yet to propose and commit to specific solutions
5. Monitor – We actively try to monitor our progress, we hope to improve it.
6. Communicate – via this statement and other communication channels we try to be transparent and honest regarding our efforts

Key indicators:

1. Suma have not been notified or uncovered any issues regarding worker welfare in our supply chain to date.
2. None of our suppliers are featured in campaigns or articles from pressure groups and publications such as The Food Empowerment Project, Ethical Consumer etc.
3. No reports have been received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Steps taken to assess risk in our supply chain

As our supply chains are global and complex, we operate e predominantly food-based business and the agricultural industry carries a lot of risk. We continue to use historical methods, as well always striving for continuous improvement.

Supplier Ethical Questionnaire

We continue to use our SEQs on the onboarding process

Supplier Code of Conduct declaration

As with our SEQs, we require all our new suppliers to complete, sign and date this declaration.

Supply Chain working group

This cross-departmental group meets monthly to discuss and act on our supply chain risks and opportunities. We have realized based on last years and this year’s efforts that we need a more methodological approach to how we deal with our ‘high risk’ suppliers. It involves a lot of key teams and this work is ongoing. We will report next year on our findings and key outcomes.

Sedex membership

We have renewed our membership to Sedex which allows us to have support to gain better insight of our supply chains, assess our risks, report any negative impacts and comply with legislation. We try to advise some of our relevant suppliers to have a membership, or at least sign up to similar accreditation schemes that serve a similar function.

Supply Chain Risk Assessment – see above.

Building on from the work undertaken last year (2021/2022) of highlighting our potentially high-risk suppliers based on their country of operations – we have come to understand that we needed to incorporate other potential risks such as corruption and climate change. We have altered our methodology to encompass other factors that could pose to be a modern slavery risk. The addition of this work has made our focuses clearer and we hope to devise our next steps.

What the future holds

We acknowledge our duty as an organization to contribute to the universal Sustainable Development Goals. Paying particular attention to Target 8.7 and 8.8 which state:

Target 8.7: Take immediate and effective measures to eradicate forced labour, end modern slavery and human trafficking and secure the prohibition and elimination of the worst forms of child labour, including recruitment and use of child soldiers, and by 2025 end child labour in all its forms.
Target 8.8: Protect labour rights and promote safe and secure working environments for all workers, including migrant workers, in particular women migrants, and those in precarious employment.

We appreciate there is still significant progress to be made, and Suma will focus our efforts to contribute in positive ways to try to mitigate human rights abuses in our supply chain.

We intend to share our findings on the ongoing supplier risk assessment work, which includes a detailed outline of our methodologies, justification for methods used and highlighting our shortcomings.

The Supply Chain Working Group have certain objectives and Suma wide goals, we hope to share this progress with you next year. Keep your eye on other communication channels for updates. The group will also investigate potential partnerships with organizations that are on the ground in our high-risk countries.

As mentioned previously Suma is currently reformulating it’s Buying Policy, Recruitment Policy and Contractors Policy. Suma have also identified gaps in our efforts and hope to include Non-stock in the new Procurement Policy work that is underway. Examples of non-stock would include things such as computers, paper and banking.

Modern Slavery training will be mandatory to employees who fulfil specific roles and functions within the business.

References

ungpreporting.org
business-humanrights.org
media.business-humanrights.org
bsr.org

Our structure, business and supply chains

Suma is a fully democratic worker co-operative. All co-operative members and employees receive the same gross hourly rate of pay, no matter what their job or responsibilities. We have had a Bakers, Food and Allied Workers Union branch for over 30 years.

We operate from two linked sites in West Yorkshire, and a small hub in London. All workers are based in the UK at one or more of these sites. Suma is the UK’s largest independent wholefood wholesaler/distributor, specialising in vegetarian, fairly traded, organic, ethical and natural products.

Our policies relating to slavery and human trafficking

In July 2022 we introduced a Modern Slavery Policy. This lays out our detailed commitments to protecting the people in our supply chain. It sets in stone a commitment to continual improvement in managing social issues, through strengthening our supplier approval and risk management and introducing a formal supplier Code of Conduct.

We operate a number of related policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Recruitment policy. We operate 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.
2. Whistleblowing. All new starters are issued with an induction pack stating that ‘whistleblowing’ (as defined by the Public Interest (Disclosure) Act 1998) will not be deemed a ‘serious breach of Confidence’ under the terms of our Disciplinary and Dismissal procedures.
3. Buying Policy. read our buying policy

We are committed to compliance with the Ethical Trading Initiative Base Code which consists of the following criteria:

1. Employment is freely chosen
2. Freedom of association and the right to collective bargaining are respected
3. Working conditions are safe and hygienic
4. Child labour shall not be used
5. Living wages are paid
6. Working hours are not excessive
7. No discrimination is practised
8. Regular employment is provided
9. No harsh or inhumane treatment is allowed

Our new supplier approval process is built around ensuring that suppliers are fully compliant with this code.

Due diligence processes

All our suppliers are asked to complete a supplier ethical questionnaire. Our Modern Slavery Policy forms part of our agreement with brand suppliers and they are required to confirm that no part of their business operations contradict this policy.

Where we identify problems with the quality or practices of suppliers we take appropriate action. This could be working more closely with them to help solve the problem, sharing resources, collaborating to improve capacity, investing financially to help with training or equipment, or in some cases ending our relationship with suppliers.

We have committed to reviewing our supply chain annually to identify high-risk regions, industries and goods. Further research and investigation has been prioritised according to the highest risk areas, and we have enacted supplier-level information gathering to address areas of concern.

Steps taken to manage risk in our business and supply chain

1. We created a supply chain map to give an overview of which Suma products are sourced from countries with a high risk of modern slavery
2. Developed supplier prioritisation criteria, to determine which suppliers to focus on in risk assessments
3. Developed resources for internal teams involved in supplier management, including guidance documents on complying with modern slavery principles
4. Developed, consulted on and agreed a business-wide Modern Slavery Policy

Effectiveness in ensuring that slavery and trafficking is not taking place, with
performance indicators.

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

1. No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
2. We discover no issues in our due diligence checks around new and existing suppliers.
3. None of our suppliers are featured in campaigns or articles from pressure groups and publications such as The Food Empowerment Project, Ethical Consumer etc.

Training on slavery and human trafficking that we provide

This year we partnered with Stronger Together to introduce modern slavery awareness training for all workers involved in selecting and approving suppliers (our Buying Team, Product Developers and Quality Control Team). We have put processes in place to ensure that all new team members receive this training in future.

Approval for this statement

This statement was approved by the Suma Board.

Organisation and supply chain structure

Suma is the UK’s largest independent wholefood wholesaler/distributor, specialising in vegetarian, fairly traded, organic, ethical and natural products. We buy products from across the globe. About a quarter of these are sold under our own Suma Wholefoods brand. The rest are products from other brands and bulk food products.

We are a fully democratic worker co-operative. All co-operative members and employees receive the same gross hourly rate of pay, no matter what their job or responsibilities. We have been a Bakers, Food and Allied Workers Union branch for over 30 years. We operate from two linked sites in West Yorkshire, and a small hub in London. All workers are based in the UK at one or more of these sites.

As a worker co-operative, we are guided by the co-operative values and principles. We are committed to equality, democracy, transparency and wellbeing in our business, and members of our co-op collectively take responsibility for upholding these values. You can find out more about what this means for our workers and our supply chain on our values page.

Policies and commitments on modern slavery

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Recruitment policy. We operate 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.
2. Whistleblowing. We have a ‘speak up, listen up’ approach to whistleblowing concerns, in line with CIPD best practice. We want people to feel empowered to raise concerns without fear of reprisal
3. Buying Statement that outlines our product listing criteria.
4. Code of business conduct. We are committed to compliance with the Ethical Trading Initiative Base Code which consists of the following criteria:
   1. Employment is freely chosen
   2. Freedom of association and the right to collective bargaining are respected
   3. Working conditions are safe and hygienic
   4. Child labour shall not be used
   5. Living wages are paid
   6. Working hours are not excessive
   7. No discrimination is practised
   8. Regular employment is provided
   9. No harsh or inhumane treatment is allowed

Due diligence processes

We select partners and suppliers based on their environmental and human rights record. Suppliers are required to complete an ethical supplier questionnaire, and provide us with information such as minimum age requirements for employees, measures taken to prevent human trafficking, assurance that no forced or bonded labour is used.

We require suppliers to adhere to the ETI base code, and in turn to hold their suppliers to the same standards. When we have problems with the quality or practices of suppliers we will take appropriate action. This could be working more closely with them to help solve the problem, investing financially to help with training or equipment, visiting them ourselves, sending an independent auditor, or delisting the supplier.

Staff training

Several of our buyers have attained CIPS Level 6 Professional Diploma Procurement and Supply, and are CIPS members. CIPS have a strong position on Modern Slavery, which remains a key theme for this global organisation. For 2021/22 we have planned in training for all workers that are involved in approving suppliers and managing supplier relationships.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

1. No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
2. We discover no issues in due diligence checks around new and existing suppliers.
3. None of our suppliers are featured in campaigns or articles from pressure groups and publications such as The Food Empowerment Project, Ethical Consumer etc.

Approval for this statement

This statement was approved by the Suma Board.

Statement for 2019/2020

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Suma Wholefoods 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.

Our business

Suma is a fully democratic worker co-operative. All co-operative members and employees receive the same gross hourly rate of pay, no matter what their job or responsibilities. We have had a Bakers, Food and Allied Workers Union branch for over 30 years.

We operate from two linked sites in West Yorkshire, and a small hub in London. All workers are based in the UK at one or more of these sites.

Suma is the UK’s largest independent wholefood wholesaler/distributor, specialising in vegetarian, fairly traded, organic, ethical and natural products.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Our recruitment policy. We operate 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.
2. Whistleblowing. All new starters are issued with an induction pack stating that ‘whistleblowing’ (as defined by the Public Interest (Disclosure) Act 1998) will not be deemed a ‘Serious breach of Confidence’ under the terms of our Disciplinary and Dismissal procedures.
3. Buying Policy
4. Code of business conduct. Suma Wholefoods is committed to compliance with the Ethical Trading Initiative Base Code which consists of the following criteria:
   1. Employment is freely chosen
   2. Freedom of association and the right to collective bargaining are respected
   3. Working conditions are safe and hygienic
   4. Child labour shall not be used
   5. Living wages are paid
   6. Working hours are not excessive
   7. No discrimination is practised
   8. Regular employment is provided
   9. No harsh or inhumane treatment is allowed

Our suppliers

Suma operates a product supplier policy and maintains an approved brand supplier list. All Suma product suppliers are asked to complete an ethical questionnaire. Our anti-slavery policy forms part of our agreement with brand suppliers and they are required to confirm that no part of their business operations contradict this policy.

In addition to the above we require Suma brand suppliers to confirm that:

1. They hold their own suppliers to account over modern slavery
2. They do not employ children under the age of 15
3. They pay their employees any prevailing minimum wage applicable within their country of operations

When we have problems with the quality or practices of Suma brand suppliers we take appropriate action. This could be working more closely with them to help solve the problem, investing financially to help with training or equipment, visiting them ourselves, sending an independent auditor, or delisting the supplier.

Several of our buyers are CIPS members. CIPS have a strong position on Modern Slavery, which remains a key theme for this global organisation. Members of the team have completed online courses on understanding the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

1. No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
2. We discover no contra-indications in our due diligence checks around new and existing suppliers.
3. None of our suppliers are featured in campaigns or articles from pressure groups and publications such as The Food Empowerment Project, Ethical Consumer etc.

Approval for this statement

This statement was approved by the Suma Board.

Anti slavery statement for financial year 2018/19

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Suma Wholefoods 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 labour. Suma Wholefoods has a zero tolerance approach to any form of modern slavery . We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery within the business or our supply chain.

Our business

Suma is a fully democratic worker co-operative. All co-operative members and employees receive the same gross hourly rate of pay, no matter what their job or responsibilities. We have had a Bakers, Food and Allied Workers Union branch for over 30 years.

We operate from two linked sites in West Yorkshire, and a small hub in London. All workers are based in the UK at one or more of these sites.

Suma is the UK’s largest independent wholefood wholesaler/distributor, specialising in vegetarian, fairly traded, organic, ethical and natural products.

High risk areas for Suma brand products

Having assessed our structures and the supply chain of Suma branded goods, we believe that the areas at highest risk of modern slavery are the growing and harvesting of raw materials. This year we have focused on cocoa as a high risk commodity. Working with our suppliers, and taking guidance from the Food Empowerment Project, we do not currently source any cocoa from West Africa. This presents challenges as around 70% of all cocoa originates from this area, however current advice is that the risk of slavery is too great unless the product is produced by a co-op.
We have been reviewing our tomato suppliers, and conducting traceability on the raw materials that go into our packaging, to make sure that the tinplate in our cans is not sourced from conflict zones.
We have also looked at our coffee supply chain, and are proud to say that all Suma brand coffee is Fairtrade certified, organic, and produced by co-operatives.
We have updated our Ethical Supplier questionnaire, which is sent to all brand suppliers on a yearly basis. We have also started to send this to prospective new suppliers of non-Suma branded goods and services. When we have problems with the quality or practices of Suma

brand suppliers we will take appropriate action. This could be working more closely with them to help solve the problem, investing financially to help with training or equipment, visiting them ourselves, sending an independent auditor, or delisting the supplier.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Modern Slavery Statement. This sets out our stance on modern slavery and explains how members can identify any instances of this and where they can go for help.
2. Recruitment policy. We operate 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.
3. Whistleblowing. All new starters are issued with an induction pack stating that ‘whistleblowing’ (as defined by the Public Interest (Disclosure) Act 1998) will not be deemed a ‘Serious breach of Confidence’ under the terms of our Disciplinary and Dismissal procedures.
4. Buying Policy
5. Code of business conduct. Suma Wholefoods is committed to compliance with the Ethical Trading Initiative Base Code which consists of the following criteria:
   1. Employment is freely chosen
   2. Freedom of association and the right to collective bargaining are respected
   3. Working conditions are safe and hygienic
   4. Child labour shall not be used
   5. Living wages are paid
   6. Working hours are not excessive
   7. No discrimination is practised
   8. Regular employment is provided
   9. No harsh or inhumane treatment is allowed

Our suppliers

Suma operates a supplier policy and maintains an approved brand supplier list. We conduct due diligence on all suppliers before allowing them to become an approved supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery, and onsite audits where feasible. All Suma brand suppliers are asked to complete an ethical questionnaire. Our anti-slavery policy forms part of our agreement with brand suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above we require Suma brand suppliers to confirm that:

1. They have taken steps to eradicate modern slavery within their business
2. They hold their own suppliers to account over modern slavery
3. They do not employ children under the age of 15
4. They pay their employees any prevailing minimum wage applicable within their country of operations
5. We may terminate the contract at any time should any instances of modern slavery come to light

Several of our buyers have attained, or are signed up for CIPS Level 6 Professional Diploma Procurement and Supply, and are CIPS members. CIPS have a strong position on Modern Slavery, which remains a key theme for this global organisation. Members of the team have completed online courses on understanding the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain. A member of the Suma Risk / Compliance team is doing a 5 week course on Ending Slavery, delivered by the University Of Nottingham. This training is ongoing, and we are committed to furthering this development.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

1. No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
2. We discover no contra-indications in our due diligence checks around new and existing suppliers.
3. None of our suppliers are featured in campaigns or articles from pressure groups and publications such as The Food Empowerment Project, Ethical Consumer etc.

Approval for this statement

This statement was approved by the Management Committee