Slavery and human trafficking statement

SLAVERY AND HUMAN TRAFFICKING STATEMENT
Modern Slavery Act 2015

 

Introduction

The Bartholomews Group of Companies is committed to improving our practices to combat
slavery and human trafficking.

Organisational Structure

Bartholomews (Holdings) Limited, with its head office in United Kingdom, is the ultimate
parent company of the Bartholomews Group, with five trading subsidiaries:
• Bartholomews Agri Food Limited – an agriculturalmerchant
• Shoreham Silo Services Limited – a grain storage and export facility working with
customers of Bartholomews Agri Food Limited
• Ultimate Fertilisers Limited – a deep water import facility importing and bagging
bulk fertiliser for to Bartholomews Agri Food Limited
• Churchill Freight Services Limited – a transport company operating a fleet of HGVsto
service both the Bartholomews Group and third parties
• Bartholomews Specialist Distribution Limited – a storage and distribution company
The Group has over 200 employees and operates in the United Kingdom, although does
export commodities overseas.
The Group has a turnover in excess of the statutory level of £36,000,000 under the Modern
Slavery Act 2015

Our Supply Chains

Our supply chains include:
• Combinable crops purchased from UK farmers
• Services provided by other members of the BartholomewsGroup
• Fuel purchased from multi-national companies
• Fertilizer purchased from both inside and outside the European Union
• Chemicals purchased form multinational companies
• Commodities for use in the Group’s business activities purchased from companies
trading in the European Union

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no Modern Slavery or Human Trafficking in our
supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment
to acting ethically and with integrity in all our business relationships and to implementing
and enforcing effective systems and controls to ensure slavery and human trafficking is not
taking place anywhere in out supply chains.
Due Diligence Processes for Slavery and Human Trafficking
We actively seek to identify and mitigate the risk of slavery and Human Trafficking and have
in place systemsto:
• 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.
• Protect whistle blowers.
The Bartholomews Group considers that its business is at low risk of slavery and human
trafficking.
Parts of our business trade only with other members of the Group. Beyond that the majority
of our suppliers are based in the UK and are either small or medium sized enterprises in the
agricultural sector or multinational companies with extensive governance structures, which
companies operate widely across the European Union under its regulatory regime. The
sector is highly regulated with famers receiving grants from the Rural Payments Agency, an
executive agency of DEFRA which require the provision of extensive information and they
also seek registration with organisations such as Red Tractor Farm Assurance.

Adherence to our values

We have zero tolerance to slavery and human trafficking. As identified we consider the
Group’s business is at low risk of exposure to slavery and human trafficking in our supply
chain.
However, in any areas where we consider there is a greater risk of such exposure we aim to
ensure all those in our supply chain and contractors comply with our values. In circumstances
where we perceive a risk matter will be referred to the relevant departmental manager in
conjunction with the Group Legal Counsel who will consider the steps necessary to prevent
Bartholomews being exposed to or assisting in Modern Slavery or Human Trafficking.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking
in our supply chains and our business, we will highlight risk to our staff who are exposed to
any area of our business where we have identified a higher than low risk of exposure in our
supply chain to modern slavery and human trafficking.
All new members of staff will be made aware of our Policy in this field and will be expected
to adhere to it.

Our Effectiveness in Combating Modern Slavery and Human Trafficking

We are committed to keeping our effectiveness in this area under review to ensure that
slavery and human trafficking is not taking place in any part of our business or supply chains.
Prior to the entry into a new sector of business the risk of exposure will be considered and
appropriate safeguards identified and then implemented. Similarly any adverse concerns
that arise in our activities will be reported to and discussed with the Group’s Legal Counsel.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and
constitutes our slavery and human trafficking statement for the financial year ending 31st
December 2022.