MODERN DAY SLAVERY IN THE SUPPLY CHAIN: STATEMENT OF ACTIONS Statement of Actions 2017 The UK Modern Slavery Act of 2015 requires certain organisations to be transparent about their efforts in identifying and eradicating modern slavery and human trafficking in their own operations and supply chains. Fyffes is committed to maintain high ethical business standards across its operations, and as such, does not tolerate any form of modern slavery or human trafficking. Building from the previous year, Fyffes Ltd engaged the services of an internationally renowned consultancy to develop and implement a global sustainability strategy which will encompass all aspects of Modern Day Slavery prevention, detection and eradication. The process included several internal and external stakeholder consultations. Fyffes products are grown on Fyffes owned farms as well as being purchased from various grower partners. The ETI Base Code, which includes a wide range of labour practices with specific provisions not to use forced or child labour, continues to be the base standard for ethical compliance for Fyffes operations. Our Compliance team in Central America doubled in size to eight staff members and continued to conduct and participate in internal and third party audits, including SMETA-type audits throughout the supply chain. Each employee of the department received SMETA training to enable them to conduct such audits and to maximise the information available from the SEDEX website of which an increasing number of our suppliers are now members. In the UK, Fyffes Group Ltd continued to audit its Labour Providers using the Standard developed in 2016. In addition, 75% of Fyffes ripening facilities were subject to unannounced SMETA audits during the year. Non-compliance with the ETI Base Code is taken very seriously by Fyffes. If such non-compliances occur, we take remedial action to contain, address and resolve the situation with the shortest possible delays. Fyffes will always first seek a viable remediation strategy with suppliers, however, such corrective action can lead to the termination of a commercial agreement with Fyffes if deemed necessary. During the year, as a result of our audit process, services from one Labour Provider were discontinued with the affected workers transferred to another Provider. Learnings from that experience led to the trialing of an engagement exercise whereby new recruits from Labour Providers are interviewed after a number of weeks employment to ascertain their views of the recruitment process followed and to ensure it was following the ETI Base Code. These informal meetings include pertinent questions regarding the workers treatment. The exercise will be refined and rolled out to all ripening facilities in the coming year. We understand that the risk associated with slavery and human trafficking is not static, and we will continue our approach to mitigating this risk in the years ahead as we also finalize our CSR strategy and the review of our current policies and practices. This statement was approved by Coen Bos, Chief Operating Officer, on July 5th 2018. Statement of Actions 2016 Fyffes Group Ltd is a wholly owned UK subsidiary of Fyffes Limited, itself a subsidiary of the Sumitomo Corporation. Operating out of five sites it ripens bananas and packages and distributes bananas and pineapples to retail and wholesale customers. 99.9% of this fruit is purchased from Fyffes International, the group procurement company, with the remainder purchased on an ad hoc basis from other fruit handlers often at very short notice. Fruit is sourced from over 2,000 farms, (some of whom have had a relationship with Fyffes for over forty years), across 14 countries in Central & South America and Western Africa. There is potential for Modern Slavery and human trafficking at farm level and in the UK as much of the workforce in these places is made up of immigrant labour. That said, the workforce on the production side is relatively stable due to the weekly cycle of harvesting. All farms packing for Fyffes are known, as are the packaging manufacturers who supply these farms. Fyffes takes its membership of the Ethical Trading Initiative (“ETI”) very seriously and has included compliance with the ETI Base Code* as a contractual obligation when purchasing fruit. In addition 70%+ of the bananas are sourced from growers who hold Fairtrade or Rainforest Alliance certifications. Farms are also audited against the ETI Base Code by Fyffes compliance team, based in San Jose, Costa Rica, and/or by 3rd Party independent auditors, commissioned by either Fyffes or its customers, using the SMETA Measurement Criteria*. Results of these SMETA audits are shared with Fyffes customers through SEDEX. In 2016 Fyffes started the process of Human Rights Risk Assessment and will use the results of this to focus priorities in the forthcoming years, although the process has been severely hampered due to other issues and non-response of international agencies. As a result of internal checks representation has been made to a source country Government to speed up the process of visa applications as workers were left for too long without documentation. Vulnerable persons are those most likely to be exploited and Fyffes is participating in the vulnerable people working group which is part of the ETI’s Food & Farming Programme. Migrant labourers are among the most vulnerable. In 2015 the International Labour Organisation (“ILO”) conducted a study on the Fyffes owned ‘Anexco’ pineapple farm in Costa Rica, the results of which have been published by the ILO as a good Good Practice report. In the UK Fyffes Group Ltd makes use of temporary labour on a weekly basis to manage production peaks. All labour providers are licensed by the Gangmaster Licencing Authority and through active checks Fyffes Group Ltd keeps up-to-date on their licence status. In addition all labour providers are audited each year and their systems to detect Modern Slavery are challenged. In 2016 Fyffes Group Ltd developed an in-house Standard against which labour providers will be evaluated, which will include measures to prevent and detect modern slavery. The lead in this work has obtained a CPD certificate in Investigating Modern Slavery issued by the University of Derby Management representatives from Head Office and the four ripening facilities have attended Stronger Together workshops and, as a result, the ripening centres have adopted policies which aim to detect and prevent hidden labour exploitation. Four of the five ripening centres are Business Partners within Stronger Together and the remaining one is working to this end. The Fyffes Standard for Labour Providers encourages all Labour Providers to become business partners in Stronger Together. * The Base Code explicitly prohibits Modern Slavery while SMETA audits that the clause is being met – “There is no forced, bonded or involuntary prison labour” b Terms and ConditionsContact usDisclaimerFor InvestorsPrivacy Fyffes Limited, 29 North Anne Street, Dublin 7, Ireland. Phone: +3531 887 2700 Registered in Ireland. No:73342.