Navara Oat Milling Ltd is a company formed from a joint venture between Frontier Agriculture Limited, and Camgrain Stores Limited, both of which have their head offices in and operate from England and Wales.
We are an oat milling and processing manufacturer in the agricultural sector.
Our supply chains
Navara Oat Milling Ltd is based in the United Kingdom; the primary supply chain and end user market are UK based, however supply can also be made to overseas clients. Simple supply chains exist both in supply to, and distribution from, its UK base. Any changes to these arrangements will be addressed in subsequent policy revisions.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. This Modern Slavery Act statement 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 own business, or knowingly in any of our supply chains. This statement applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we assess on the basis of the following risk areas:
- Country risk – we identify countries where our suppliers operate that are vulnerable to slavery and human trafficking.
- Sector or industry risk – we identify what parts of the business may be vulnerable to slavery and human trafficking.
- Business or transaction risk – we assess whether particular relationships or transactions are susceptible to slavery and human trafficking.
- Product or raw materials risk – we assess where raw materials are sourced or farmed.
We have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
We encourage an open culture in all our dealings between employees and people with whom we come into contact. Honest communication is essential if malpractice and wrongdoing are to be dealt with effectively. Our Whistleblowing Policy sets out guidelines for individuals who wish to raise issues in confidence; these could include forced labour concerns.
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a Supplier Code of Conduct. This consists of the values and standards we expect of our suppliers, representatives and other people we deal with. It is based on the eight code conventions (which cover collective bargaining, forced labour, child labour and discrimination) of the ILO and the Ethical Trade Initiative (ETI) Base Code. It clearly outlines our intolerance of forced or bonded labour.
If we uncover situations of modern slavery or other serious violations, we will seek to verify and investigate immediately. Where cases are identified amongst our suppliers who are found not to be meeting our expectations and standards, we will endeavour to work with them, offering training and support to help them improve. Termination of commercial relationships with non-conforming suppliers will only take place if they do not show any improvement over an agreed timeframe.
Suppliers are expected to sign and abide by our values.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will form part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication and by refresher training on an ongoing basis. This education will also form part of the company’s Whistleblowing Policy.
Our effectiveness in combating slavery and human trafficking
We know that how we measure progress is dictated by the type of progress and change we are seeking to generate. Some of the KPIs we are currently tracking:
- Internal staff and supplier training, and awareness of forced and trafficked labour issues;
- Actions taken as part of collaborative initiatives to address modern slavery;
- Our policies relating to forced and trafficked labour, and advocacy efforts we have undertaken to draw awareness to or address these risks;
- Supplier Code of Conduct non-compliances relating to employment being freely chosen;
- Registered grievances in our supply chain relating to any form of forced labour; and
- Investigative and remedial actions taken in response to any perceived instance of forced labour in our supply chain.
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 current financial year.