MODERN SLAVERY
STATEMENT

COMPANY

This statement applies to Orchard Valley Foods Limited t/a OV: registered in England & Wales Number: 04990639. OV Group is a subsidiary of Orkla ASA, a leading Nordic supplier of consumer branded goods.

OV specialise in the manufacture of sugar-based confectionery, contract packing and blending. Our products include fudge, chocolate decorations, honeycomb, marshmallows, caramelized sugars and powders, complete dry mixes, cereals and ancient grains, sweet decorations and inclusions, as well as cultures, coagulants, reagents and ingredients for cheese and yoghurt makers.

We currently employ around 220 personnel with two manufacturing sites in St Ives, Cornwall and Harrogate, North Yorkshire, a packing facility based in Leominster, Herefordshire, and a small blending operation at Tenbury Wells, Worcestershire which is also our UK Sales office.

The information included in this statement refers to the financial year ending 31 December 2023 when our turnover was £37m.

INTRODUCTION

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

COMMITMENT

The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

No labour provided to the Company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation and in many cases, exceeds those minimums in relation to its employees.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

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 our supply chains. We are committed to the following practices:

• Stringent vetting and investigation of our supply chain (suppliers, contractors, sub-contractors, policies, contracts etc).
• We will continually evaluate and audit the ethical standards of our suppliers within our product supply chains.
• All Suppliers are given a copy of our Code of Conduct.
• We are members of SEDEX and require our suppliers to be members of SEDEX also. Further information can be found on the following link: https://www.sedexglobal.com
• Continually audit and review our practices for checking all supplier’s employees are paid at least the minimum wage and have the right to work.
• Encourage the reporting of concerns and the protection of whistle blowers.
• We will not knowingly support or deal with any business involved in slavery or human trafficking.
• We will continue to conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.
• Conduct annual risk assessment in line with Orkla’s Human Rights and Responsible Employer Policy.
• Continually improve our policies and processes.

Additional policies which provide further information to ensure awareness and to permit any concerns to be raised include:

• Orkla Whistleblowing Policy
• Orkla Code of Conduct
• Orkla Human Rights and Responsible Employer Policy
• Grievance Policy
• Recruitment Policy

DUE DILIGENCE PROCESSES WITH OUR SUPPLIERS

As part of our initiative to identify and mitigate risk wherever possible, we build long term relationships with all our suppliers which enables a clear and deep understanding of our business values and makes clear our expectations of business behaviour and what we expect from our suppliers.

As a business unit of Orkla ASA, our suppliers are required to abide by Orkla’s Supplier Code of Conduct that is based on the Universal Declaration of Human Rights, the ETI Base code, and UN Global Compact’s 10 principles for sustainable development, to which Orkla is committed.

Additionally, Orkla has implemented a mandatory Supplier Portal to ensure that all suppliers go through an approval process that includes a risk evaluation based on the following six risk factors:

• Compliance Risk
• Food Safety and Safe Products
• IT Security
• Financial Risk
• Sustainability Risk
• Privacy

The risk assessment process is supported utilising company information retrieved from Bureau Van Dijk.

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 look to provide training to our staff as required. We will also require our business partners to provide training to their staff and suppliers and providers where there is a perceived risk.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We use the following key performance indicators (KPI’s) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Completion of Supplier Audits.
• Use of labour monitoring and payroll systems
• Annual risk assessment in line with Orkla’s Human Rights and Responsible Employer Policy
• The Company has a recognized HR function, to whom all concerns regarding modern slavery should be addressed and who will then undertake relevant action with regard to the Company’s obligations.

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 31 December 2023.