Modern Slavery Statement
Modern Slavery Statement 2023
In February 2021, Eat Real and PROPER joined forces as WARP Snacks (legal entity – WARP Snacks Ltd) to fire up the healthy snacking revolution. We’re about creating snacks with substance. We believe that you don’t have to sacrifice flavour for health, or planet for profit. Which is why we use natural ingredients and follow ethical business practices, to make sure our snacks taste great and our snackers feel good.
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 is 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, Chris – so that’s why this statement is signed by him.
- 329 permanent employees
- 2 sites (1 office in London 1 snacktory in Nuneaton)
- 22 Material suppliers (ingredients, packaging, co-manufacturing)
- 3 Third-Party manufacturers (across the UK and Continental Europe)
- 4 PROPER product ranges (ready to eat popcorn, microwave popcorn, lentil chips, potato crisps)
- 4 Eat Real product ranges (lentil, hummus & quinoa chips, veggie straws)
- 4 co-manufactured/retailer branded 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 WARP site, we have an anti-harassment policy, whistleblowing 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, to 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 and staff awareness programme.
Our supplier policies:
We have now completed our WARP 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.
During 2022, we started the process of updating our Master Services Agreements (MSA) and our annual contracts with our suppliers. All our suppliers must sign an MSA to be able to work with WARP and this MSA is now linked to agreement to our Supplier Code.
In the last year we have also launched a new Sustainability Supplier Approval and management process. This involves sending a checklist to our suppliers at the start of each year to review their progress across key business, social and environmental metrics. The same checklist is completed as part of our new supplier process. If a supplier is found through this survey to be in breach of basic legal, social or environmental standards, WARP will work with our suppliers to build timebound action plans to close any non-conformance within a 12-month period. If the supplier continues not to meet the standards outlined and legal requirements, WARP will move away from that supplier.
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 Snacktory, we work to an operational model of 70-80% permanent staff with 30-20% agency staff. We purposely engage with only one agency to provide these teams and 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’re still members of the Supplier Ethical Data Exchange Platform (Sedex). This is a world-leading ethical trade membership organisation. The platform provides businesses like WARP 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).
Here’s what we’ve been up to this year:
- Connected with 82% of our direct suppliers (including ingredients, packaging, logistics partners and co-manufacturing sites).
- In 2021, we used the Sedex Supplier Risk Assessment Tool (Radar) to map inherent risks within our ingredient supply chain, at both a country and sector level. In 2022, we completed this assessment across all our ingredients (even the really small volume ones)
- 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
Ongoing, we’re continuing our work on the following areas:
- Getting connected with 100% of our direct material suppliers through the Sedex platform.
- If we identify extreme or high risks to human rights, we will be completing a deeper investigation and working with our direct suppliers to understand and mitigate these risks to individuals within our supply chains.
At least once a year we will share a short Modern Slavery awareness training with all our office-based staff as part of our Monthly meeting, attended by everyone in an office-based role at WARP. Modern Slavery also remains a part of our sustainability induction programme, so that all new starters joining the business are aware of our commitment to protect people and our planet.
Looking back and looking forward
We know we have a long way to go to combat the issues surrounding modern
slavery in our supply chains. This list summarises from this statement what we completed in 2022 vs. what we committed to in our statement last year.
Last year we said
Creating an employee Culture Book, which will include our expectations on conduct of all WARP people.
This year we will extend this to a toolkit for managers.
Rolling out and signing our Supplier Charter with all WARP suppliers in the next year.
We’ll keep rolling this out with our suppliers until we reach 100%
Connecting to 100% of our direct material suppliers on Sedex and ensuring they have completed self-assessments as a minimum.
Continuing to work towards 100% of suppliers connected
Mapping our key ingredients to farm-level, to start to build better transparency of both environmental and ethical standards within our supply chain.
Where necessary, creating action plans to make sure people are being respected within our supply chain.
Continuing to meet and understand risks within our supply chain by visiting, learning from and sharing with our suppliers.
Completing a human rights and environmental risk map for the country of origin of all WARP ingredients.
Continuing to measure all new products against our Product Impact Score.
Thanks 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.
CEO WARP Snacks