UK Modern Slavery Act

From the very start, we have sought to run our business in ways that make a genuine contribution to global equality, decrease poverty and to protect the environment.

It’s no surprise then that we support the requirements of Section 54 of the UK Modern Slavery Act. We applaud the transparency it encourages because it matches our approach and our continued commitment to work in ways that always respect human rights.

We understand well and fully acknowledge the risk of forced labour and poor working practices within a core global supply chain. It’s why through our partnership with Fair for Life, we have opened our core tea supply chain to independent scrutiny and publish our audit results to make it as transparent as we can. It’s also why Fair for Life is the gold standard of fair practises – because
it independently certifies our core supplier processes to ensure that every worker within the certified chain receives at least the local minimum wage and enjoys decent and fair conditions. It certifies in every country – both developing and developed - and for everyone, from those in Pukka’s Herb House itself to those that work in the fields where we grow our herbs.

Our support of Fair for Life and Fair Wild means we financially contribute to funds that are used not only to improve the health and welfare of the agricultural communities who grow our herbs but also to encourage practices that support wider sustainability.

Of course, no responsible business stands still and Pukka is committed to continuous improvement. We recognise that there is more we can do to reduce the risk of unacceptable working practices within both our core supply chain and wider value chain. It’s why we will continue to work as hard as we can with both our partners in our business and more widely to create the positive change we all need.

Karel Vandamme, CEO Pukka Herbs

Outline and business structure

Although Pukka Herbs is a a member of the Unilever Group, we operate our own supply chain.

We are a manufacturer of organic herbal teas and supplements and source a wide range of organic herbs from across the world from countries such as: India, Kazakhstan, Hungary, Spain and Georgia.

The history of our company is rooted in our environmental and ethical principles. We adhere to the principles of fair trade both in developing countries and at home in the UK.

Our policies and approach

As a sustainable ethical business, we operate a number of policies and procedures that support our approach to achieving the goals of the Modern Slavery Act.
Core to our ethical sourcing policy is our partnership with Fair for Life. Fair for Life promotes an approach of Fair Trade that allows all producers and workers who are at a socio-economic disadvantage to access a wider range of social and economic benefits. We share with them, and continue to work towards achieving, the following commitments:

• To commit to fairness by orienting the business model to fair practices based on a fair pricing policy and a respectful dialogue with suppliers

• To respect human rights and to offer decent working conditions to improve the living conditions and well-being of workers and their families

• To respect the environment, biodiversity and climate by taking responsibility for one’s environmental impacts and progressively implementing sustainable agricultural practices encouraging conversion to organic farming

• To act for sustainable local development through collectively identifying challenges and creating development projects adapted to local contexts

• To provide producers and workers with democratic representation and collective bargaining capacity to develop their economic opportunities

• To enable informed purchase decisions through transparent communication which guarantees consumers physical traceability of certified ingredients


Due Diligence and compliance

The Fair for Life programme forms a key part of our due diligence approach within our core supply chain.
Our core tea supply chain has been independently audited under the Fair for Life – Social and Fair Trade Certification programme. Fair for Life state that their certification assures that:
“human rights are safeguarded at any stage of production, workers enjoy good and fair working conditions and smallholder farmers receive a fair share…”
The programme assesses the requirements for the fundamental rights of workers against the core conventions of the International Labour Organisation.

The certification programme covers:

• Fair Trade sourcing
• Support and promotion of Fair Trade producers
• Traceability and product handling
• Partnership and favourable trading terms
• Fair for life pricing and fair trade development premiums

Under each of the above, we have been ranked higher than the average normal ranking.

We recognise that we cannot rely solely on this certification. We will therefore work within our core supply chain and wider value chain to measure, improve and adopt best practice.

Supplier visits and contractual terms
In addition to the independent due diligence undertaken above, members of our sourcing team visit core suppliers with reasonable frequency. Any such visit will include team members spending time with suppliers and in the fields. It means that as well as independent certification, we can see for ourselves the working conditions and ethical practises that are so important to Pukka.
Each order placed with a supplier contains a requirement to comply with our organic certified statement which includes a requirement to ensure good working conditions and fair treatment and pay.
We are putting in place new framework arrangements with core suppliers under which the obligation to comply with the requirements of the Modern Slavery Act will be formally enshrined.

Assessing risk areas

Hired labour

We have identified the need to protect vulnerable workers – including temporary and agency workers within our own company.

We have worked with the independent auditors at Fair for Life to obtain a separate certification for hired labour. The scope of the certification includes:

• No forced labour
• Freedom of association and right to collective bargaining
• No child labour and protection of young workers
• Transparent and human disciplinary practices
• Equal treatment and opportunities
• Health and safety
• Contracts and good relations between employer and workforce
• Wages
• Social security and social benefits
• Working hours and paid leave
• Regular employment
• Commitment and management of social responsibility
• Community relations

We have equalled or exceeded the average normal ranking under each of the above headings.

Agriculture

We are aware of the challenges of the agricultural sector, particularly in developing countries.
As a supporter of environmental sustainability, we directly support the natural partnership we believe exists between supporting our growers and the environment at the same time. Through the FairWild premium, we pay a premium price for our herbs in return for growers managing the crops and environment in a more sustainable manner.
As a contributor to the Fair Trade Fund via Fair for Life, we provide funds to directly benefit the agricultural communities that we source from. Pukka donations have been used to fund dental care for workers as well as to fund the purchase of caravans to provide shelter from the weather for workers in the fields.
We will continue to work with third party experts to help us to manage and monitor the risks and to protect the rights of workers.

Training

We are developing training programmes within the company and with key partners to ensure that all employees are equipped to recognise the signs of human trafficking and slavery. We are committed to this supporting our wider sustainability and ethical goals.