MODERN SLAVERY POLICY
This statement applies to Nic Ice Ltd (referred to in this statement as ‘the Company’). Modern slavery is ‘a hidden crime that encompasses slavery, servitude, forced labour and human trafficking’. We take zero tolerance approach to this and are strongly committed to playing a part in eradicating. We understand the importance of transparency within our supply chain in driving collaborative action and the potential impact of the Act on reducing risks and incidence of slavery.
The information included in the statement refers to the financial year ending in April 2022.
Nic UK and its inter-companies supply manufactured food and traded goods into UK retail and trade specialising in the ice cream markets. We currently sell food, syrups, ice cream mixes, emulsifiers and food packaging. Our products are manufactured and packaged within our BRC accredited facilities within the UK and procured from business for trade throughout Europe. Demand for our product is consistently high throughout the year however supports a highly seasonal customer base.
Nic Ice Ltd utilises 5 sites supporting warehousing / distribution, production and administration and contact to numerous B2B and 3rd party supply. The labour supplied to the Company in pursuance of its operation is carried out in the UK with sites in London (Head Office), Glasgow, Bodmin, Witham-St-Hughes and Omagh. The Company is led and managed by Directors of the Company.
We currently employ around 300 personnel over the five sites supporting our manufacturing facilities and delivery to our consumer requirements. Our company and managers reflect this commitment and, as a business, will assist where practically possible, with the eradication of modern slavery.
We believe that the trade and business partnership that we have with our European partners should have a positive impact, creating jobs and opportunities.
Nic Ice Ltd is fully committed to working in partnership with our suppliers, service providers and colleagues to address these challenges and ensure remediation for any victims.
The Company considers that modern slavery encompasses:
- human trafficking
- forced work, through mental or physical threat
- being owned or controlled by an employer through mental or physical abuse of the threat of abuse
- being dehumanised, treated as a commodity or being bought or sold as property
- being physically constrained or to have restriction placed on freedom of movement.
The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.
The Company does not enter into business with any organisation in the United Kingdom or abroad which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
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.
In general, the Company considers its exposure to slavery / human trafficking to be relatively limited. However, it has taken steps to ensure that such practices do not take place within our business.
Impact of COVID-19
During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for the Company, as it did for others across the nation.
The Company welcomed the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.
Unfortunately, the Company assessed that it would need to delay the publication of this statement for the 2019/2020 financial year due to the impact of COVID-19. It was therefore delayed for 5 months until able to review towards the end of the main season. The reason for the delay was high level of activity supporting our employees by focusing attention on ensuring safe onsite working practices throughout COVID whilst maintaining / increasing a high volume of seasonal activity as our customer’s businesses returned to normal.
The Company concludes that the COVID-19 pandemic considered the risk of modern slavery to a level slightly above that which existed before the pandemic, which is as set out under Potential Exposure above.
This was due to a higher requirement for production as customers / businesses opened their doors again and seasonality resumed. Accordingly, the Company engaged additional temporary labour from employment agencies in order to meet the need of its customers. As is our policy, any agencies used provide us with their own Modern Slavery Policy so that we can confidently ensure all our colleagues are treated fairly and appropriately.
During the pandemic, the Company’s employees still had access to the grievance procedure to raise any concerns that they may have had.
In line with emergency legislation passed by the Government, employees have been paid Statutory Sick Pay during periods of COVID self-isolation where it was not possible to agree a temporary period of homeworking. The Company also took the decision from the outset of the pandemic to ensure that all of the workforce who were required to self-isolate in accordance with public health guidelines receive full pay for up to 10 days after which any further self-isolation would revert to COVID SSP. This continues to support self-isolating employees and safeguards remaining onsite colleagues.
The Company’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.
The Company carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its Company.
The Company has not, to its knowledge, conducted any business with another Company which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Company has taken the following steps to ensure that modern slavery is not taking place:
- Commitment to a zero-tolerance policy towards modern slavery
- Training provided to all staff on modern slavery
- HR documentation checks and awareness of potential flags that may identify concerns
- Ensuring Recruitment Agencies provide their Modern Slavery policy in advance of agreements
- Supplier contracts include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
- Whistleblowing Procedure and Modern Slavery information provided at all sites and visible to staff
The Company has the following policies which further provide information to ensure awareness and to permit any concerns to be raised:
- Modern slavery policy
- Supplier code of conduct
- Recruitment policy
- Whistleblowing Policy
- Grievance Policy
The Company has a recognised HR Department, 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 in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.