MODERN SLAVERY POLICY

1. Policy Statement

Norseland Ltd is committed to preventing modern slavery and human trafficking within its operations and supply chains, following the principles of the Stronger Together initiative. Norseland Ltd also commits to being a member of the Association of Labour Providers (ALP). We recognize that modern slavery is a grave violation of human rights and is inconsistent with our values. This policy outlines our commitment to identifying and eradicating modern slavery in all aspects of our business.

2. Scope

This policy covers Norseland Ltd and applies to all permanent, temporary, and agency employees, as well as our immediate supply chain. The business expects its Ingredients and Packaging Supply Chain to have its own policies, procedures, and processes relating to Human Rights, Child Labour, Modern Slavery, and Labour Exploitation, and are expected to agree to Norseland’s terms in regards to that matter. It is expected that all organizations within the policy also comply with the ETI Base Code.

3. Definitions
  • Modern Slavery: Modern slavery is a term that encompasses slavery, servitude, forced labor, and human trafficking. It involves the exploitation of individuals, often through coercion, deception, or force.
  • Supply Chain: This refers to the network of individuals, organizations, resources, activities, and technology involved in the creation and sale of our products.
4. Responsibilities

4.1. Board of Directors and Senior Management: The Board of Directors and senior management of Norseland Ltd are responsible for ensuring that the organization’s commitment to preventing modern slavery, in line with the Stronger Together initiative and as a member of the Association of Labour Providers, is upheld. They will provide the necessary resources and support to implement and maintain effective measures.

4.2. Employees: All employees of Norseland Ltd, whether permanent, temporary, or agency, are responsible for familiarizing themselves with this policy and reporting any concerns related to modern slavery to their supervisors or the designated point of contact.

4.3. Suppliers and Contractors: Norseland Ltd expects suppliers and contractors to adhere to the principles of this policy, the Stronger Together initiative, and the standards set by the Association of Labour Providers. We will work collaboratively with them to assess and address any identified risks of modern slavery within the supply chain. The Ingredients and Packaging Supply Chain are expected to have their own policies, procedures, and processes related to Human Rights, Child Labour, Modern Slavery, and Labour Exploitation, and must agree to Norseland’s terms in this regard. It is expected that all organizations within the policy also comply with the ETI Base Code.

5. Risk Assessment and Due Diligence

Norseland Ltd will conduct regular risk assessments to identify and evaluate the risk of modern slavery within its operations and supply chains. This includes assessing the risk associated with geographical locations, specific industries, and types of labour.

6. Training and Awareness

Norseland Ltd will provide training to employees and relevant stakeholders to increase awareness of modern slavery issues and to ensure that individuals are equipped to identify and report potential instances of modern slavery, following the guidance provided by the Stronger Together initiative and the Association of Labour Providers.

Policy Commitments

Norseland Ltd shall:

  • Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training.

Entrust them with the responsibility of developing and operating company procedures relevant to modern slavery and labour exploitation.

  • Job Finding Fees: Acknowledge that job finding fees are a business cost and prohibit job applicants from bearing these costs. Ensure that no individual or organization is used to source and supply workers without confirming that workers are not charged work finding fees.
  • Staff Awareness and Compliance: Ensure that all staff involved in direct recruitment are aware of issues around third-party labour exploitation and signs to look for. Have these staff members sign appropriate Compliance Principles.
  • Controlled Processes: Ensure that labour sourcing, recruitment, and worker placement processes are under the control of trusted and competent staff members.
  • Proactive Reporting: Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and the police.
  • Information Dissemination: Provide information on tackling “Hidden Labor Exploitation” to the workforce through workplace posters.
  • Establish a Confidential Concerns link via our Applewood Staff App for anonymous reporting. Include relevant information in induction and regular training sessions.
  • Encourage Worker Reporting: Encourage workers to report cases of hidden third-party labour exploitation. Provide accessible means for reporting and ensure appropriate investigation and action on reported cases.
  • Support and Encouragement: Positively encourage and support employees and agency workers to report exploitation within their communities.
  • Requirements for Supply Chain Partners: Require labour providers and other organizations in the labour supply chain to adopt policies and procedures consistent with the commitments outlined in this policy. This policy will be regularly reviewed and updated as necessary. Approval of any changes will be the responsibility of the [relevant organizational authority].
7. Reporting Mechanism

Norseland Ltd will establish a confidential reporting mechanism for employees and stakeholders to report concerns related to modern slavery. Reports will be thoroughly investigated, and appropriate action will be taken.

8. Continuous Improvement

Norseland Ltd is committed to continuous improvement in preventing modern slavery, aligned with the principles of the Stronger Together initiative and the standards set by the Association of Labour Providers. We will regularly review and update our policies and procedures to ensure their effectiveness.

9. Communication

This policy, in adherence to the Stronger Together initiative and as a member of the Association of Labour Providers, will be communicated to all employees, suppliers, and contractors and made publicly available on Norseland Ltd’s website.

10. Review and Approval

This policy will be reviewed annually and updated as necessary. Approval of any changes to this policy will be the responsibility of the [relevant organizational authority].