MODERN SLAVERY ACT 2015 STATEMENT
MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
This statement is published on behalf of Fuller, Smith & Turner P.L.C. and the other subsidiary companies within the Fuller, Smith & Turner P.L.C. Group (together “Fuller’s”) pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”).
This statement constitutes Fuller’s Modern Slavery and Human Trafficking Statement for the financial year ended1 April 2023. As required by the Act, this statement reports on the steps taken by Fuller’s during the year to ensure that slavery and human trafficking is not taking place in any part of our own business or any of our supply chains.
Our structure and our business
Fuller’s is a premium pubs and hotels business founded in Chiswick, London in 1845 and listed on the premium market of the London Stock Exchange. Fuller’s has 187 managed businesses, with 1,015 boutique bedrooms, and 191 Tenanted Inns. The Fuller’s pub estate stretches from Brighton to Birmingham and from Bristol to the Greenwich Peninsula, including 163 locations within the M25. Our Managed Pubs and Hotels include Cotswold Inns & Hotels – seven stunning hotels in the Cotswolds, and Bel & The Dragon – six exquisite modern English inns located in the Home Counties. Further information can be found in our 2023 Annual Report, which is available on our website www.fullers.co.uk.
Modern slavery and human trafficking
We are committed to conducting our business ethically and with integrity, and striving to ensure that there is no modern slavery or human trafficking in any part of our business or supply chains.
Our supply chains
Our supply chains include the sourcing of raw materials and finished products for the purposes of providing food and drink, goods and equipment used in our pubs and hotels and our support office, construction and maintenance services for our freehold estate, contactors, sub-contractors, and professional service suppliers. In total we have over 1,000 suppliers ranging in size and complexity, with the majority operating in the United Kingdom. In most cases we aim to develop long term relationships with our key suppliers and to rationalise the number of suppliers we partner with, but we do have a large number of smaller contractors who service the day-to-day requirements across our estate. We seek to maintain open communication with our contractors and suppliers regarding our values and expectations.
Prevention of modern slavery and human trafficking
We have policies and procedures in place to reduce the risk of modern slavery in our business, to ensure employees are protected and to promote human rights including:
Right to Work Policy: outlines procedures and responsibilities to ensure Fuller’s complies with all UK employment law and ensures our employees are fully entitled to work in the UK.
Whistleblowing Policy: outlines the procedure for raising concerns regarding suspected wrongdoing by Fuller’s or any of its employees or suppliers, including in confidence through an independent whistleblowing hotline.
Life is too good to waste programme: outlines our commitment to our people, our environment and our communities and includes initiatives to partner with our suppliers on key issues and to support our employees.
Due diligence processes for slavery and human trafficking in our supply chains
As part of our initiatives to identify and mitigate risk we:
- we identify and assess potential risk areas in our supply chains by asking all new key suppliers to provide details of their modern slavery arrangements as part of onboarding;
- we do not engage any new key supplier of goods or services who does not align to our values and does not meet the standards we expect of them;
- we comply with all aspects of UK employment law to mitigate the risk of people in our business being subject to any form of exploitation;
- we have appointed a partner to undertake right to work checks to improve and streamline our onboarding checks;
- we expect all agencies who supply workers for our pubs, hotels and Support Centre to comply with UK employment law; and
- we have procedures in place to allow colleagues to report any wrongdoing whilst offering protection for whistle blowers, including an independent third-party helpline.
During the year we have:
- launched a Responsible Sourcing Statement which outlines our minimum standards and the basic principles of cooperation that we require of all suppliers which has been published on our website and made available as part of all new tender processes;
- continued the roll out of our anti-modern slavery e-learning training module across the business, covering how to spot the signs of modern slavery and how to report it; and
- started discussions with an external third party to seek guidance on preparing a risk map of our supply chain to identify areas where it may be prudent to conduct further due diligence to identify any potential areas of exploitation and to drive best practice; and
- enhanced our contract management depositary so that we have a structured system to track our suppliers’ modern slavery policies and practices.
Fuller’s remains committed to building and strengthening our existing policies and practices to eliminate modern slavery and human rights violations across our business and in our supply chain. We therefore aim to continue to review the effectiveness of our current arrangements and, where necessary, implement additional safeguards and procedures. This will include:
- further development of more interactive and engaging training through a new learning and development platform which is being rolled out in FY 2024, tailored to specific roles and areas of the business, to ensure our teams can minimise the risk of modern slavery within our supply chains, spot the signs relevant to victims of modern slavery and understand how to report it for immediate action;
- reviewing the terms in our standard trading terms and conditions to ensure the expectations and standards set out in our Responsible Sourcing Statement regarding the prevention of modern slavery and promotion of human rights are included;
- launching a Supplier Code of Conduct which will set out how we expect our suppliers to act;
- implementing an annual audit and certification check with our key suppliers to verify, amongst other things, their continued commitment to minimising the risk of modern slavery, including in their supply chain;
- based on the guidance we have sought on supply chain risk mapping, conducting a review of food processing suppliers (ie meat and agriculture) and cleaners to identify any key modern slavery and human trafficking indicators which may require further focus;
- continuing to explore possible partnerships with third-party experts to help target our mitigation and due diligence efforts; and
- continuing to review the use of specialised ESG platforms, to allow us to manage our data more easily within our supply chain and to better manage sustainable sourcing, ESG and modern slavery risk across our supply chain.
This statement has been approved by the Board of Directors on 21 September 2023.
Simon Emeny, Chief Executive on behalf of
Fuller, Smith & Turner P.L.C.
Griffin Catering Services Limited
21 September 2023