Modern Slavery Act

Prevention of Labour Exploitation


Labour exploitation is defined as the exploitation of job applicants/workers and can include forced labour, human trafficking, payment for work and work related exploitation.

Policy Statement

Fresh Pak Chilled Foods are committed to preventing slavery and human trafficking within the organisation and throughout its supply chain and will adopt a proactive approach to drive out such acts.

Fresh-Pak Chilled Foods will not knowingly use suppliers or labour providers that exploit job applicants/workers and will report any evidence to the following organisations:

  • Local Police Authority
  • Gang masters Licensing Authority

This statement sets out Fresh-Pak Chilled Foods action plan to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

As part of Food Manufacturing the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Fresh-Pak Chilled Foods are registered members of SEDEX and are audited against the ETI base code.

Organisational structure and supply chains

Fresh-Pak is the producer of fresh sandwich fillings and dips. Based in Barnsley South Yorkshire we supply sandwich fillings/dips for grocery multiples, high-street retailers and food service outlets. We are also a producer of hard-boiled eggs, supplying food manufacturers and other commercial customers nationwide.

Fresh-Pak Chilled Foods suppliers are located throughout the UK and Europe.

  • UK
  • Ireland
  • Germany
  • Spain
  • Netherlands



Overall Responsibility for the organisation’s labour exploitation initiatives lies with the board of directors.

Specific areas of responsibility are outlined below:

  • Policies: HR Department – HR Manager
  • Labour suppliers HR Department – HR Manager
  • Recruitment HR Department – HR Manager
  • Supplier Risk assessments: Procurement Department – Head of Procurement
  • Due diligence in supply chain: HR Department
    • HR Manager – existing supply chain questionnaires.
    • Technical Department – Raw Materials Manager – Auditing of Suppliers.
    • Procurement Department – Head of Procurement – Questionnaires for new suppliers.
  • Training: HR Department – Training Officer – Facilitate internal online training. Organise any external training requirements.
  • Stronger Together Membership HR Department – HR Manager


Relevant Policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations

  • Whistle blowing policy The organisation has a documented policy for reporting any concerns related to the direct activities, or the supply chains of, the organisation. This includes concerns relating to modern slavery. The organisation’s whistle blowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Employee code of conduct The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour.
  • Recruitment/Agency workers The organisation uses only specified, reputable employment agencies. Any new agency is audited and verified prior to commencement. Recruitment agencies are audited twice yearly by the HR department.


Performance indicators

In light of the introduction of the Modern Slavery Act 2015. the organisation has set the following performance indicators in place.

Requiring all front line managers/purchasing department/ on site recruitment agent and HR department to have completed training on modern slavery by the end of 2016.

  • Raise awareness within the organisation, via posters and induction programme by the end of July 2016 • Conduct address checks on employees and agency workers by on going
  • Reviewing its existing 1st tier suppliers by means of a questionnaire by the end of 2017.
  • SEDEX link to all suppliers where applicable by the end of January 2018.
  • The organisation will review and evaluate all completed questionnaires and conduct a risk based analysis by the end of March 2018.
  • Approved membership of Stronger Together by the end of June 2018


This statement has been approved by the organisation’s Managing Director.
KF Sign

Managing Director

Date 10th June 2016

Our Accreditations

BRC Food Certified
The British Sandwich Association
Members of Campden BRI
RSPCA Assured Logo
MSC Certified Sustainable Seafood
British Lion Eggs