Modern Slavery Statement & Policy

G.R. Wright & Sons Ltd (“the Company”) is committed to conducting all aspects of its business ethically and responsibly. This policy outlines our zero‑tolerance approach to modern slavery, forced labour, human trafficking, and hidden labour exploitation across our operations and supply chain. It supports our responsibilities under the Modern Slavery Act 2015, which requires commercial organisations to publish an annual slavery and human trafficking statement. This is reinforced by internal compliance findings noting the legal requirement to maintain an up‑to‑date statement.

Our Business

G.R. Wright & Sons Ltd. produces a variety of milled flours together with a range of speciality blends, cake, and bread mixes at our three sites located across Essex and Middlesex.

G.R. Wright & Sons Ltd. has a turnover in excess of £50Mm and currently has over 150 people.

The Board of Directors includes the Managing Director, Commercial Director, Finance Director, Operations Director and Technical Director.

Our supply chains include the sourcing of raw materials principally related to the manufacture of flours, speciality blends, cake, and bread mixes.

We work closely with our main suppliers and customers, with our employees and with other trade bodies such as UK Flour Millers and comply with the SMETA Best Practice Guidance in order to ensure the highest level of compliance with food manufacturing standards and ethical trading initiatives.

 

Policy Scope

This policy applies to:

  • All employees, workers, contractors, and agency staff.

  • All suppliers, service providers, and business partners acting on behalf of the Company.

  • All operations, including procurement, recruitment, and supply chain activities.

 

Our Supply Chains

Our supply chains include the sourcing of raw materials principally related to the manufacture of flours, speciality blends, cake, and bread mixes.

 

Our Commitment

We commit to:

·       Preventing modern slavery and human trafficking in all business activities.

  • Ensuring supply chains are free from forced labour and exploitation.

  • Conducting ongoing due diligence and risk assessments.

  • Training managers and supervisors in identifying and reporting modern slavery risks (as reflected in SAQ and compliance documentation).

  • Continually improving our monitoring and review systems to maintain legal and ethical compliance.

Definitions

Modern slavery includes:

·       Forced or compulsory labour

·       Human trafficking

·       Servitude or exploitation for work

·       Withholding of identity documents
These definitions align with key principles referenced in internal audit and supplier assessment documents.

 

Responsibilities

Management Responsibilities

Managers are responsible for:

·       Implementing this policy and ensuring it is communicated to all staff.

·       Ensuring risk assessments are carried out on suppliers and recruitment channels.

·       Investigating suspected cases of exploitation.

·       Reviewing the policy as part of annual compliance activities.

 

Employee Responsibilities

Employees must:

·       Report concerns regarding potential modern slavery via the Whistleblowing procedure (outlined in the Employee Handbook).

·       Not engage in, enable, or ignore any behaviour that could constitute exploitation.

 

Due Diligence in Supply Chains

Our Suppliers

G.R. Wright & Sons Ltd. operates an approved supplier procedure and maintains an approved supplier list. As part of the due diligence procedures on all key suppliers, prior to granting them approved status, a regular review is conducted on all relevant completed supplier questionnaires, third party certification and audit reports. Also, where deemed necessary an online search will be completed to ensure that particular organisation has never been convicted of offenses relating to modern slavery. Should any instances of modern slavery come to light, either directly or through subcontractors, we will terminate relationships with them.

Training

·       Training is provided to managers, supervisors, and relevant operational staff on recognising signs of exploitation.

·       Updates are included in the Employee Handbook, induction processes  and learning management systems (LMS) training modules.

Awareness-raising programme

As well as training staff, the organisation has raised awareness of modern slavery issues by putting up posters across the organisation's premises.

The posters explain to employees:

·  the basic principles of the Modern Slavery Act 2015.

·  how employers can identify and prevent slavery and human trafficking.

·  what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and

· what external help is available, for example through the Modern Slavery Helpline.

 

Our Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

· Ethical Trading Policy. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

· Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

· Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

 

Reporting Concerns

The Company encourages employees, contractors, customers, and suppliers to report concerns confidentially. Reports may be made through:

·  The Whistleblowing Policy (as outlined in the Employee Handbook).

·  Line managers

·   HR team

·  Anonymous reporting channels where available.

 

We commit to investigating reports promptly and taking necessary action.

Monitoring & Review

· This policy will be reviewed annually, in line with recommendations arising from audit findings that highlight the need for regular updates to the modern slavery statement.

·  Updates will be published on the company website as required under the Modern Slavery Act 2015.

 

Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain, if no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Breaches of This Policy

Any breach may result in:

  • Disciplinary action up to and including dismissal.

  • Termination of supplier contracts

  • Reporting to relevant authorities

Board Approval

This statement has been approved by the organisation's board of directors on 20th January 2026 and will be reviewed and updated on an annual basis.

 

David Wright

Managing Director