Modern Slavery Statement

Modern Slavery Statement 2025

Introduction

PROPER and Eat Real came together in 2021 with a shared mission - to make snacks that taste great and do good. Today, two brands power one company: PROPER SNACKS. Built by founders who knew snacks could be better, we became the UK’s first B Corp snacks brand. Now, as the largest B Corp snacks manufacturer, the belief that you don’t have to sacrifice flavour for health, or planet for profit, still fuels us every day. 

It takes a lot of people across our business and supply chain to make our snacks. We want to do everything we can to make sure all those people are working in safe, healthy and fair environments. As a business, we recognise that the food industry and its links to agriculture are high risk for the issue of modern slavery and human trafficking, and that’s why we’re working to put the right structures and principles in place to protect the people who support our business.

We think that protecting people is the right way to do business. That’s why it’s not any one person’s job to look after modern slavery, it’s the responsibility of multiple people and teams across the business. Our people team have responsibility to protect everyone who works within our business. Our supply chain and procurement teams are responsible for making sure those working within our extended supply chain are protected, by choosing suppliers who are aligned with our values and meet our due diligence requirements. Our sustainability team are responsible for setting our strategy on human rights, supporting the business to assess our suppliers against these standards and collaborating externally to ensure people are protected across our whole value chain. Ultimate accountability for protecting the people who make our snacks sits with our senior management team and our CEO, Alex – so that’s why this statement is signed by him.

About us

• 363 permanent employees

• 2 sites (1 office in London 1 office and factory in Nuneaton)

• 19 Material suppliers (ingredients, packaging, co-manufacturing) 

• 2 Third-Party manufacturers (across the UK and Continental Europe) 

• 4 PROPER product ranges (ready to eat popcorn, microwave popcorn, lentil chips, chickpea chips) 

• 4 Eat Real product ranges (lentil, hummus & quinoa chips, veggie straws) 

• 4 co-manufactured product ranges (lentil chips, hummus chips, veggie straws & lentil straws)

Policies on modern slavery 

Our people policies:

To make sure we are protecting the people who work at any PROPER SNACKS site, we have a Modern Slavery Statement, a Whistleblowing policy, an Equal Opportunities policy and grievance procedures for all employees. These are accessible to all staff through our People Perks platform where all our policies and procedures are stored.

Our employee Code of Conduct lays how we expect people to work with and treat each other, our suppliers, our customers and the wider community. This is part of our induction programme.

Our supplier policies:

We have a PROPER SNACKS Supplier Code. This Code of Conduct outlines how we want to do business, our ambition to protect people and the environment across our value chain, and within this our specific commitment to do all we can to protect people from human rights abuses and slavery.  This code is incorporated in all PROPER SNACKS Supply contracts.

Through 2024 and ongoing into 2025 we are using the Sedex radar tool to highlight any areas on which we need to specifically focus. Ethical audits, non-compliances and action plans are contained in this shared database. It is a requirement for all new direct suppliers to PROPER SNACKS to have membership. We check compliance and progress annually. If a supplier is found through this survey to be in breach of basic legal, social or environmental standards, PROPER SNACKS will work with our suppliers to build timebound action plans to close any non-conformance within a 12-month period. If the supplier continues to fail to meet the required standard, PROPER SNACKS will discontinue the supply relationship. 

Risk assessment & due diligence processes 

This year, we’ve continued our focus on some key due diligence processes within our operations and supply chain.

At our Factory, we aim to work to an operational model of 60-70% permanent staff with 40-30% agency staff depending on production requirements. We purposely engage with only one agency to establish a long-term relationship of joint values. The recent selection of this agency was as a result of a comprehensive tendering process, against a standardised set of criteria which included a review of modern slavery awareness and practices.

From a supply chain perspective, we are Sedex members. This is a world-leading ethical trade membership organisation. The platform provides businesses like PROPER SNACKS with online tools and data to understand risks in our supply chain and to identify where we need to focus and work with suppliers to improve working conditions. We’re using the tool to understand the ethical performance of facilities in our supply chain, starting with our direct material suppliers (those who we buy from directly).

As part of our ongoing commitment to preventing modern slavery and promoting ethical labour practices across our supply chain, we have recently engaged with a new third-party logistics (3PL) provider. In doing so, we are actively assessing their operations and policies to ensure alignment with our own ethical standards. We require all 3PL partners to adhere to the highest standards of labour practice, including robust safeguards against forced labour, human trafficking, and worker exploitation. Our due diligence process includes risk assessments, policy reviews, and contractual commitments to ethical conduct, reinforcing our zero-tolerance approach to modern slavery in any form.

Last year, we connected with 91% of our direct suppliers (including ingredients, packaging, logistics partners and co-manufacturing sites). In 2025, our aim is to review and re-assess all current suppliers and ensure our risk assessments are updated with additional areas of focus. In 2022 we used the Sedex Supplier Risk Assessment Tool Radar to map inherent risks in our ingredient supply chain. We will update this in 2025 and expand it to include third-party manufacturers.  We applied a country of origin risk rating to our newly launched Product Impact Score. This impact score is now used to review all New Product Development, to ensure we’re focusing on sourcing new and existing ingredients from regions and countries with low risk of human rights impacts. 

We shared our ambitions and expectations on responsible sourcing with 9 of our key, direct suppliers during 2022, where possible through face-to-face visits to their sites and farms within our mutual supply chains. In 2025 we intend to make every supplier aware of our responsible sourcing intentions through the permanent procurement team. We will meet with 100% of our direct suppliers face to face. For those suppliers who are souring goods from farms, we will have met with at least one of the farmers in the supply chain.

Training

We are committed to training to build capacity and capability in this area.  We will align with the Stronger Together recommendations on training, as follows:

• Awareness sessions for our most senior management team

• Appropriate training for our Modern Slavery lead

• Awareness training for our Site Management team

• Appropriate training for our Procurement team

• Appropriate training for our People and Payroll teams, Trade Union/ Employee Reps and any other roles we believe support, address and reduce the risks of modern slavery and hidden labour exploitation

• Appropriate training for our front-line managers so they are clear on how to spot the signs of exploitation, immediately handle and report suspected cases.

Modern Slavery is a part of our induction programme, so that new starters joining the business are aware of our commitment to protect people and our planet.

Looking Forward 

We’re proud of the improvements we’re making, but acknowledge we still have more to do to combat the issues surrounding modern slavery in our supply chains:

Thank you for reading

The progress and next steps we have shared in this statement are the start of a long-term commitment to identify and mitigate the risks to people working across WARP’s operations and supply chains. WARP’s work to protect and respect the people connected to our business is ongoing and we will continue to learn, develop our approach and report on our work to combat modern slavery.

This statement has been published in accordance with the Modern Slavery Act 2015 and constitutes WARP Snacks statement for the financial year ending December 31st 2021. It has been approved by the Board of Directors of WARP.