Modern Slavery Act Statement
As a responsible restaurant chain, Casual Dining Group is committed to ensuring that our supply chain and within our own operations, we take a robust stance in the prevention of slavery and human trafficking. We continue to work with our suppliers to strengthen our supply chain due diligence in social, environmental and ethical standards whilst recognising that many may need practical help and support in implementing these.
CDG’s Modern Slavery statement sets out the steps we have taken in understanding all potential risks, ensuring that these are addressed to support our objective of zero tolerance to slavery and human trafficking in all our business activities both in the UK and overseas.
Structure and Supply Chains
Casual Dining Group is one of the largest independent restaurant companies in the UK employing over 10,000 people and serving more than 20 million meals at around 300 locations. It is a parent business to five main operating companies: Bella Italia, Café Rouge, Las Iguanas, La Tasca and Belgo.
We have a centralised procurement team who work with around 120 suppliers and with them we have established strong relationships based on mutual trust and transparency.
Our aim is to build best practice supply chain assurance that is resilient to any potential risks and supports us to be vigilant in all parts of our business. To this end, we require our direct suppliers to work closely with all their supply chain partners including raw material producers, distributors, wholesalers and agents to meet this aim.
All direct suppliers and their supply chain partners must comply with all EU and UK legislation relating to ethical trading and worker welfare as a minimum. These include the following:
• The Data Protection Act 1998
• The Foreign Corrupt Practices Act 1977
• The Proceeds of Crime Act 2002
• United Nations (UN) Universal Declaration of Human Rights
• The International Labour Organisation (ILO)
• The Ethical Trading Initiative (ETI) whose Base Code is drawn from the scope and standards defined by the UN and ILO
Where applicable i.e. companies that have a turnover of £36 million or more, they should also demonstrate compliance with the Modern Slavery Act 2015.
In addition to this, CDG has its own Ethical Trading Policy that sets out company policies and practices to ensure our business and supply chain practices are free from slavery and human trafficking.
Our policy covers 14 key principles including prohibition of slavery and human trafficking, safe and hygienic working conditions and payment of a fair wage. All direct suppliers are required to show compliance with this Policy and to provide evidence of continuous improvement in worker welfare.
Suppliers must have their own Codes of Conduct, ethical trading policies and management systems to demonstrate their approach to prevent modern slavery and human trafficking.
All first tier suppliers are required to be SEDEX members and to provide due diligence on ethical trading including self assessment, third party audits and corrective action of non-compliances on request from CDG. CDG is also a SEDEX member that allows us to access information on suppliers including latest audits undertaken and corrective action reports at any given time. Currently this is carried out on a quarterly basis.
Casual Dining Group encourages its employees to report in confidence any concerns relating to any part of the organisation. This will extend to suppliers and other business partners and specifically include any risk of slavery or human trafficking.
Employee Code of Conduct
Casual Dining Group has employment policies where we make clear to our employees the actions and behaviour which are expected of them whilst at work and through the course of their duties and responsibilities. We strive to maintain the highest standards of employee conduct and ethical behaviour in all business activities including when operating and managing our supply chain abroad.
Casual Dining Group complies with the Anti-Bribery Act 2010. It does not tolerate any form of bribery by or of its employees, agents or any person acting on our behalf.
Recruitment and Selection
In our own operations, CDG carefully selects recruitment partners to ensure they source new employees in a manner that is legally compliant and ethical. Approved partners are reviewed on a regular basis.
Eligibility and Right to Work checks are carried out on all our team members prior to starting employment with CDG.
We have risk mapped first tier food and drink suppliers and identified those who have been deemed high risk based on type of products supplied and the geographic location of source. These suppliers have been required to submit their own ethical trading policies and procedures and evidence of management systems to prevent modern slavery and human trafficking.
The procurement team approve new suppliers only after a rigorous assessment of their technical capabilities and their ethical credentials. Anti-slavery requirements are included in our contractual Terms and Conditions.
In 2017/18, we made a significant investment in our supplier management IT infrastructure and adopted Authenticate digital platform with the aim of establishing greater levels of transparency and visibility in our supply chains back to source as well as improved management of supplier risk mapping, chain of custody and sourcing certification. 90% of CDG’s direct suppliers have joined the platform.
All policies are developed by the relevant issue experts and responsibility is shared by the Group Directors. All policies are approved by the Chief Executive Officer and will undergo annual reviews to assess their effectiveness going into the future.
Next Steps for 2019
• A new section will be included in Authenticate in line with our compliance to the Modern Slavery Act 2015 and this is a supplier questionnaire, the purpose of which is to:
– Continue to raise awareness across our supplier base particularly new suppliers about the Modern Slavery Act and their compliance requirements.
– To update our risk mapping of new and existing suppliers according to product category and source location and to extend this to all first tier suppliers including property and marketing.
– To request that our suppliers confirm their own compliance to the Modern Slavery Act and their cooperation if any slavery and human trafficking incidents are found in their supply chains.
• We will use Authenticate to report on how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business including key performance indicators (KPIs) as follows:
– % of suppliers who have been audited against ethical trading requirements.
– % of suppliers approved.
– % of suppliers who have had to adopt corrective action for any legislative or company requirements.
This statement is made pursuant to section 54 (1) “Transparency in Supply Chains’ clause of the Modern Slavery Act 2015 and constitutes CDG’s modern slavery and human trafficking statement for the financial year ending 31 May 2019.
CEO, Casual Dining Group