1. Policy Statement

Met Foods Ltd recognises its obligations under the Modern Slavery Act 2015 and is fully committed to acting ethically and with integrity in all its business dealings and relationships. We adopt a zero-tolerance approach to slavery, servitude, forced or compulsory labour, bonded labour, child labour, and human trafficking.

We will not knowingly support or deal with any business involved in modern slavery. We are committed to implementing and enforcing effective systems, procedures, and controls to ensure that slavery and human trafficking are not taking place in our own operations or in any of our supply chains.

2. Scope of Policy

This policy applies to:

• All persons employed by or engaged to work on behalf of Met Foods Ltd, at all levels (including employees, directors, officers, agency workers, contractors, consultants, volunteers, interns, business partners).
• All suppliers, service providers, and other third parties that form part of our supply chain.

Compliance with this policy is a condition of employment and a contractual requirement for suppliers.

3. Legal and Regulatory Framework

This policy is designed in line with the following legal and ethical frameworks:

• UK Modern Slavery Act 2015
• ILO Conventions on Forced Labour and Child Labour
• United Nations Guiding Principles on Business and Human Rights
• Relevant UK employment law, including the Employment Rights Act 1996, Working Time Regulations 1998, and Equality Act 2010.

4. Definitions

For the purposes of this policy, “modern slavery” encompasses:

• Slavery: ownership or control of a person.
• Servitude: coercion with no freedom to leave.
• Forced or compulsory labour: work exacted under threat or penalty.
• Bonded labour: work to repay a debt or obligation.
• Child labour: work that deprives children of their childhood, dignity, or education.
• Human trafficking: arranging or facilitating the travel of persons for exploitation.

5. Governance and Responsibility

• Board of Directors – has ultimate responsibility for ensuring compliance with the Modern Slavery Act and approving this policy.
• Managing Director – accountable for overall implementation.
• Technical and Procurement Teams – responsible for conducting supplier due diligence and ongoing monitoring.
• HR Department – responsible for ethical recruitment practices and ensuring labour agencies meet legal standards.
• All Employees – have a duty to comply with this policy and to report any concerns.

6. Our Commitments

Met Foods Ltd commits to:

1. Ethical Employment

• Ensuring recruitment is conducted lawfully, transparently, and without exploitation.
• Prohibiting recruitment fees, retention of passports, or withholding of wages.
• Working only with licensed labour providers (in compliance with the Gangmasters and Labour Abuse Authority where applicable).

2. Supply Chain Integrity

• Requiring all suppliers to complete our Supplier Approval Questionnaire.
• Mandating that suppliers maintain their own Anti-Slavery and Human Trafficking Policy and Code of Conduct.
• Taking a risk-based approach to supplier approval and ongoing reviews, with particular attention to high-risk geographies, commodities, and labour-intensive sectors.

3. Due Diligence & Auditing

• Conducting risk assessments across our supply chain annually.
• Requesting supporting evidence of compliance (policies, audits, certifications).
• Undertaking targeted audits or site visits where risks are identified.

4. Training and Awareness

• Providing training to staff involved in recruitment, procurement, and supply chain management.
• Raising awareness among all employees to recognise signs of modern slavery.

5. Reporting and Whistleblowing

• Establishing confidential reporting channels for employees and third parties.
• Guaranteeing that whistle-blowers will not suffer retaliation for reporting concerns in good faith.

6. Remediation and Corrective Action

• Where a breach is identified, Met Foods Ltd will collaborate with the supplier to remediate the issue, prioritising the welfare of affected individuals.
• If remediation is not achieved promptly and effectively, Met Foods Ltd will terminate the business relationship.

7. Monitoring and Review

• This policy will be reviewed annually by the Board of Directors or sooner if legislation changes.
• Compliance will be monitored through internal audits, supplier performance reviews, and employee feedback.
• A Modern Slavery Statement will be published annually (if legally required, based on turnover thresholds), detailing actions taken to combat slavery and human trafficking.

8. Consequences of Breach

• Employees found to be in breach will be subject to disciplinary action, up to and including dismissal.
• Suppliers found to be in breach will be subject to immediate termination of contract unless adequate remediation can be proven.

9. Approval and Ownership

This policy has been approved by the Board of Directors of Met Foods Ltd and will be communicated to all staff and suppliers.