Responsibility

We take an active role in improving bird welfare standards across our hatcheries and farms and are committed to ensuring the highest standards of bird health and welfare by working closely with Universities, Government Agencies, RSPCA, Welfare Organisations, Veterinarians and customers to continually monitor key health and welfare outcomes. We fully endorse the Five Freedoms proposed by the Farm Animal Welfare Council.

Our employees are trained to ensure we maintain the highest standards of bio-security and flock health enabling us to produce birds to the highest standards of food safety and quality. All our farms and hatcheries are subject to Independent audits to ensure we are always meeting our customer expectations and our poultry is fully traceable from flock to hatchery and the breeder farm where the eggs came from.

The Board of P D Hook Group recognises that compliance with tax filing and payment obligations is one of its key responsibilities. In common with all aspects of the operation of its business, the oversight is assigned to one member of the Board, namely the Group Finance Director (GFD), whose responsibility is to appraise the Board of key tax events.  This allows all Board members to be adequately engaged in the tax affairs of the business and thereby ensure P D Hook is adhering to its responsibilities.

In making this strategy available the UK group is fulfilling its responsibilities under paragraph 16(2) Schedule 19 FA 2016 for the year ended 31 October 2019

There are five key principles to which P D Hook Group adheres when considering all aspects of taxation. These principles provide steering to key stakeholders and offer a framework for decision making as follows:

  • Transparency with HMRC – P D Hook Group has an open and transparent relationship with HMRC and values the trust which HMRC places in the business to correctly deliver taxes due. In all dealings with HMRC, P D Hook Group seeks to maintain and further build on this relationship through proactive engagement.
  • Appropriately qualified Tax team – P D Hook Group is supported by an appropriately qualified and experienced tax team and invests in continued professional development. The Board will continue to review the structure of the Tax team at suitable intervals to ensure it remains appropriate to the business environment and external tax environment.
  • External advisers – To assist the Tax team, P D Hook Group engages with external advisers to provide technical expertise when necessary. This engagement takes place with the GFD for operational and compliance matters.
  • Attitude to tax planning – P D Hook Group has a strong commercial focus and as part of its duty to its stakeholders to control unnecessary costs, the Group utilise tax reliefs and allowances available in the manner in which intended by the tax authorities and statute. P D Hook Group does not engage in any artificial tax arrangements.
  • Risk Management and Governance – P D Hook Group has a clear overview of its tax risk which is documented in its tax risk matrix. The Board recognises this and considers that the tax strategy sits alongside stringent financial controls to manage tax exposures.

As an employer with a large number of employees, corporation tax alone is not a balanced reflection of the total tax contribution made by P D Hook Group. The estimated taxes borne or collected by P D Hook Group in relation to the 2018 financial year were as follows:

£000
Employer’s National Insurance 2,117
Employee’s National Insurance 1,833
PAYE 3,404
Corporate Tax 4,729
Total 12,083

Issue date 23/10/19

PD Hook and associated companies understands that the information trusted to us is important and we are committed to protecting it’s privacy. This applies to data from our employees, suppliers and customers.

We collect and retain data, whether of a personal or corporate nature solely for the purposes of running our company. None of the data will be shared outside our companies or occasionally suppliers where data may be needed for audit purposes. We will not sell any data, nor share it with others who are not involved in assisting us to operate our business.

Data will only be retained for as long as we have a legal need, specifically with employees this is often for many years after you leave the business; Accountancy and Insurance legal requirements necessities this retention. Notwithstanding this data will be removed from our system as soon as we are allowed to do so.

All data is kept securely in password controlled areas and personal data is additionally encrypted wherever possible with restricted access. We work hard to maintain this, however if you have a complaint please contact our Data Protection Officer either on 01993 853886 or DataProtectionOfficer@pdhook.co.uk

We take an active role in improving bird welfare standards across our hatcheries and farms and are committed to ensuring the highest standards of bird health and welfare by working closely with Universities, Government Agencies, RSPCA, Welfare Organisations, Veterinarians and customers to continually monitor key health and welfare outcomes. We fully endorse the Five Freedoms proposed by the Farm Animal Welfare Council.

Our employees are trained to ensure we maintain the highest standards of bio-security and flock health enabling us to produce birds to the highest standards of food safety and quality. All our farms and hatcheries are subject to Independent audits to ensure we are always meeting our customer expectations and our poultry is fully traceable from flock to hatchery and the breeder farm where the eggs came from.

Introduction

P D Hook / Hook2Sisters understands that slavery, forced labour, servitude and human trafficking (Modern Slavery) are issues that pose an increasing threat to workers and their employers. Throughout our operations, we have a responsibility to be alert and vigilant to the risks, however small, in our Business and our supply chain, and to react immediately to any reported concerns to the Gangmasters and Labour Abuse Authority (GLAA)

In accordance with Section 54 of the Modern Slavery Act 2015, we set out below the steps that have been and currently are being taken by the organisations to actively ensure that we prevent slavery and/or trafficking in our Business. We acknowledge and understand that Modern Slavery risk can vary, and will, in collaboration with our Supply Chain Partners continue our approach to robustly and adaptively mitigate this risk.

  • Responsibility for the maintenance of this Policy resides with the Head of HR
  • Responsibility for the execution of this Policy resides with everyone involved in our Business

Our Organisation

 Our Organisation comprises a Group of Companies operating thought the United Kingdom, involved in each stage of the production of eggs, chick, chicken and turkey, working in conjunction with Contract Growers, Contractors and Labour Agencies (our Supply Chain Partners).

Procedural Policies and Contractual Controls

 We have completed and distributed updated Employment and relevant Policies which make clear that any form of Modern Slavery – including coercion, trafficking, payment for work-finding, and other related exploitation – is not permitted, and totally unacceptable within our Business.

We will continue to operate the signed Service Level Agreements (SLAs) process with our Supply Chain Partners and have updated and re-issued Memorandums of Understanding (MOUs) to our Contract Growers which set out the Ethical Standards expected of our Partners, together with an express statement of expectation that any Sub-Contractors working with them also adheres to those same principals and rules.

Commitments to Anti-Modern Slavery

  • Our Anti-Slavery Human Trafficking Policy details our requirements to ensure there is total transparency throughout our Business and in our approach to tackling and eradicating Modern Slavery throughout our supply chains.
  • Processes and Procedures relating to Sourcing, Recruitment, and Worker Placement include our full commitment to detecting and preventing Modern Slavery. These processes are carried out by, and are under the control of, trusted and competent Managers and Employees to enable them to identify possible signs of exploitation in our own Workforce as well as in the Workforces of our Supply Chain Partners.
  • We have completed a SMETA audit with no non-compliances in 2017
  • As part of the British Poultry Council (BPC) we are working with the GLAA to produce a Code of Practice which will outline the commitment to Modern Slavery.  This will be launched to Retailers once complete.
  • We work with ‘Preferred Suppliers’ to engage Agency staff.  We have and will continue to check that they hold a GLAA Licence.
  • Monthly Management Meetings and Quarterly Farm and Hatchery Meetings reinforce our commitment to encourage Employees to report such possible exploitation, and investigate and act on reports appropriately, sensitively and urgently. An agenda with supporting information is sent to regions for discussion at relevant meetings.
  • We have a system in place to ensure new Contractors comply with our Approved Contractor Scheme in order to carry out work in our Business, regardless of whether they do or do not require a GLAA License, and that those who require one, do have a current GLAA Licence in place at all times. We have signed up for Active Checks on the GLAA website.
  • Our Existing Contractors who are part of our Approved Contractor Scheme are contacted annually to advise of any changes in their circumstances that may affect our Business.
  • Contractors and Suppliers who do not commit to implementing anti-slavery policies in potentially high-risk scenarios, or covertly operate outside of Policy Guidelines, will be removed from the Supply Chain.
  • We will continue to work with our Contract Growers to ensure compliance with the (BPC) Poultry Supply Chain Ethical Compliance Code of Practice (BPC CoP) and our MOU
  • Together with the BPC and GLAA we have organised and delivered regional meetings to advise our Supply Chain Partners how to adopt similar systems and procedures and advise on how to sign up to the BPC CoP.
  • We will continue to work to the standards of the BPC (CoP) which incorporates the Ethical Trading Initiative (ETI) Base Code and will continue to strive to adhere to and maintain these Standards in our Business.
  • We have set up a Disclosures Helpline which is advertised prominently on each of our sites, and have posted Modern Slavery advisory information posters prominently on each of our sites.
  • We will again undertake face to face audits with Catchers and other high risk Contractors e.g. with Washers and Muckers and Staff Agencies.
  • We will continue to work with the GLAA and have committed to hold 6 monthly meetings with the Catchers. We will extend these meetings to include the high risk Contractors i.e. Washers and Muckers.
  • We are a Stronger Together Business

Modern Slavery Training

 We will continue to provide our Employees, Managers, Directors and Supply Chain Partners with the necessary tools and training, as well as support, guidance and information based on current advice from the GLAA to equip them with the skills required to identify and prevent Modern Slavery and Human Trafficking by:

  • Employees: Tool Box Talks and Poultry Passport Training – We have been instrumental in having a Modern Slavery module added to the Poultry Passport Training Scheme – minimum standards of training provided for the Poultry Industry.
  • Managers: Engage with them in Monthly Management Meetings
  • Directors: Updates from weekly HR report
  • Supply Chain Partners: face to face meetings and MOU.

We will maintain:

  • Our commitment to the attendance of relevant personnel at Stronger Together and ETI Modern Slavery Workshops.
  • Our support of Stronger Together
  • Maintain our presence on SEDEX – (Retailer recognised database)

Principal Risks

We will continue to undertake internal audits as a means of identifying the principal risks relating to slavery and human trafficking in our Business and Supply Chain Partners and will, if identified as High Risk, request external assistance. Areas of highest risk are those involving manual, unskilled, repetitive activities and have not been identified as intrinsically geographical.

High risk activities will be monitored and reviewed on a regular basis. Any undesirable issues discovered within our Contractor base will be immediately highlighted to the GLAA. Any issues involving people will be notified to the appropriate authorities.

Whistleblowing

We encourage consistently an open culture in all our dealings between Employees and people with whom we come into contact. Effective and honest communication is essential if malpractice and wrongdoing are to be dealt with effectively. Our Whistleblowing Policy sets out guidelines for individuals who feel they need to raise certain issues in confidence, which could include forced labour concerns. We provide an independent confidential channel of communication for whistleblowing.

This Policy applies to all individuals working at all levels within the Organisation, including Senior Managers, Officers, Directors, Employees, Consultants, Contractors, Trainees, Homeworkers, Part-Time and Fixed-Term Workers, Suppliers, Casual and Agency Staff.

Key Performance Indicators

As part of the Audit Process referred to above, we will employ primary KPIs, remedial actions, timescales and steps for completion, for the following:

  • The outcomes of internal and external compliance audits we undertake, including all legal obligations.
  • The ongoing monitoring of payroll systems for warning indicators. i.e. checking for anomalies in Bank Accounts or Employee addresses
    • We have implemented a Probationary Welfare Review which encourages employees to address and report any issues.
    • Our Anti Slavery hotline has not been accessed but we will continue to monitor for usage
    • The Mental Health support partnership with Farming Communities Network (FCN) will continue to be monitored.
  • Inconsistencies within normal day to day staffing of operations, and potential Staff welfare issues.

These will be constantly reviewed and modified where appropriate for inclusion in future versions of this statement

Board Approval

We are confident that by taking these steps we will be successful in identifying and reducing, with the aim of eradicating, the risk of there being slavery or trafficking in our Business and our Supply Chains.

As a responsible Employer we are committed to identifying and implementing improvements in our Processes, Procedures and Systems.

This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Organisation’s Slavery and Human Trafficking Statement for the financial year 2017/18.

Our current and future endeavours remain the identification and eradication of actual / potential slavery and human trafficking issues, and I confirm that the contents of this statement have been approved by our Board of Directors.

James W Hook
Managing Director
For and on behalf of P D Hook Group & Hook2Sisters Ltd.
October 2018

We take an active role in improving bird welfare standards across our hatcheries and farms and are committed to ensuring the highest standards of bird health and welfare by working closely with Universities, Government Agencies, RSPCA, Welfare Organisations, Veterinarians and customers to continually monitor key health and welfare outcomes. We fully endorse the Five Freedoms proposed by the Farm Animal Welfare Council.

Our employees are trained to ensure we maintain the highest standards of bio-security and flock health enabling us to produce birds to the highest standards of food safety and quality. All our farms and hatcheries are subject to Independent audits to ensure we are always meeting our customer expectations and our poultry is fully traceable from flock to hatchery and the breeder farm where the eggs came from.

The Board of P D Hook Group recognises that compliance with tax filing and payment obligations is one of its key responsibilities. In common with all aspects of the operation of its business, the oversight is assigned to one member of the Board, namely the Group Finance Director (GFD), whose responsibility is to appraise the Board of key tax events.  This allows all Board members to be adequately engaged in the tax affairs of the business and thereby ensure P D Hook is adhering to its responsibilities.

In making this strategy available the UK group is fulfilling its responsibilities under paragraph 16(2) Schedule 19 FA 2016 for the year ended 31 October 2018

There are five key principles to which P D Hook Group adheres when considering all aspects of taxation. These principles provide steering to key stakeholders and offer a framework for decision making as follows:

  • Transparency with HMRC – P D Hook Group has an open and transparent relationship with HMRC and values the trust which HMRC places in the business to correctly deliver taxes due. In all dealings with HMRC, P D Hook Group seeks to maintain and further build on this relationship through proactive engagement.
  • Appropriately qualified Tax team – P D Hook Group is supported by an appropriately qualified and experienced tax team and invests in continued professional development. The Board will continue to review the structure of the Tax team at suitable intervals to ensure it remains appropriate to the business environment and external tax environment.
  • External advisers – To assist the Tax team, P D Hook Group engages with external advisers to provide technical expertise when necessary. This engagement takes place with the GFD for operational and compliance matters.
  • Attitude to tax planning – P D Hook Group has a strong commercial focus and as part of its duty to its stakeholders to control unnecessary costs, the Group utilise tax reliefs and allowances available in the manner in which intended by the tax authorities and statute. P D Hook Group does not engage in any artificial tax arrangements.
  • Risk Management and Governance – P D Hook Group has a clear overview of its tax risk which is documented in its tax risk matrix. The Board recognises this and considers that the tax strategy sits alongside stringent financial controls to manage tax exposures.

As an employer with a large number of employees, corporation tax alone is not a balanced reflection of the total tax contribution made by P D Hook Group. The estimated taxes borne or collected by P D Hook Group in relation to the 2017 financial year were as follows:

£000
Employer’s National Insurance 2,188
Employee’s National Insurance 1,716
PAYE 3,501
Corporate Tax 4,983
Total 12,388

PD Hook and associated companies understands that the information trusted to us is important and we are committed to protecting it’s privacy. This applies to data from our employees, suppliers and customers.

We collect and retain data, whether of a personal or corporate nature solely for the purposes of running our company. None of the data will be shared outside our companies or occasionally suppliers where data may be needed for audit purposes. We will not sell any data, nor share it with others who are not involved in assisting us to operate our business.

Data will only be retained for as long as we have a legal need, specifically with employees this is often for many years after you leave the business; Accountancy and Insurance legal requirements necessities this retention. Notwithstanding this data will be removed from our system as soon as we are allowed to do so.

All data is kept securely in password controlled areas and personal data is additionally encrypted wherever possible with restricted access. We work hard to maintain this, however if you have a complaint please contact our Data Protection Officer either on 01993 853886 or DataProtectionOfficer@pdhook.co.uk

We take an active role in improving bird welfare standards across our hatcheries and farms and are committed to ensuring the highest standards of bird health and welfare by working closely with Universities, Government Agencies, RSPCA, Welfare Organisations, Veterinarians and customers to continually monitor key health and welfare outcomes. We fully endorse the Five Freedoms proposed by the Farm Animal Welfare Council.

Our employees are trained to ensure we maintain the highest standards of bio-security and flock health enabling us to produce birds to the highest standards of food safety and quality. All our farms and hatcheries are subject to Independent audits to ensure we are always meeting our customer expectations and our poultry is fully traceable from flock to hatchery and the breeder farm where the eggs came from.

Introduction

P D Hook / Hook2Sisters understands that slavery, forced labour, servitude and human trafficking (Modern Slavery) are issues that pose an increasing threat to workers and their employers. Throughout our operations, we have a responsibility to be alert and vigilant to the risks, however small, in our Business and our supply chain, and to react immediately to any reported concerns to the Gangmasters and Labour Abuse Authority (GLAA)

In accordance with Section 54 of the Modern Slavery Act 2015, we set out below the steps that have been and currently are being taken by the organisations to actively ensure that we prevent slavery and/or trafficking in our Business. We acknowledge and understand that Modern Slavery risk can vary, and will, in collaboration with our Supply Chain Partners continue our approach to robustly and adaptively mitigate this risk.

  • Responsibility for the maintenance of this Policy resides with the Head of HR
  • Responsibility for the execution of this Policy resides with everyone involved in our Business

Our Organisation

 Our Organisation comprises a Group of Companies operating thought the United Kingdom, involved in each stage of the production of eggs, chick, chicken and turkey, working in conjunction with Contract Growers, Contractors and Labour Agencies (our Supply Chain Partners).

Procedural Policies and Contractual Controls

 We have completed and distributed updated Employment and relevant Policies which make clear that any form of Modern Slavery – including coercion, trafficking, payment for work-finding, and other related exploitation – is not permitted, and totally unacceptable within our Business.

We will continue to operate the signed Service Level Agreements (SLAs) process with our Supply Chain Partners and have updated and re-issued Memorandums of Understanding (MOUs) to our Contract Growers which set out the Ethical Standards expected of our Partners, together with an express statement of expectation that any Sub-Contractors working with them also adheres to those same principals and rules.

Commitments to Anti-Modern Slavery

  • Our Anti-Slavery Human Trafficking Policy details our requirements to ensure there is total transparency throughout our Business and in our approach to tackling and eradicating Modern Slavery throughout our supply chains.
  • Processes and Procedures relating to Sourcing, Recruitment, and Worker Placement include our full commitment to detecting and preventing Modern Slavery. These processes are carried out by, and are under the control of, trusted and competent Managers and Employees to enable them to identify possible signs of exploitation in our own Workforce as well as in the Workforces of our Supply Chain Partners.
  • We have completed a SMETA audit with no non-compliances in 2017
  • As part of the British Poultry Council (BPC) we are working with the GLAA to produce a Code of Practice which will outline the commitment to Modern Slavery.  This will be launched to Retailers once complete.
  • We work with ‘Preferred Suppliers’ to engage Agency staff.  We have and will continue to check that they hold a GLAA Licence.
  • Monthly Management Meetings and Quarterly Farm and Hatchery Meetings reinforce our commitment to encourage Employees to report such possible exploitation, and investigate and act on reports appropriately, sensitively and urgently. An agenda with supporting information is sent to regions for discussion at relevant meetings.
  • We have a system in place to ensure new Contractors comply with our Approved Contractor Scheme in order to carry out work in our Business, regardless of whether they do or do not require a GLAA License, and that those who require one, do have a current GLAA Licence in place at all times. We have signed up for Active Checks on the GLAA website.
  • Our Existing Contractors who are part of our Approved Contractor Scheme are contacted annually to advise of any changes in their circumstances that may affect our Business.
  • Contractors and Suppliers who do not commit to implementing anti-slavery policies in potentially high-risk scenarios, or covertly operate outside of Policy Guidelines, will be removed from the Supply Chain.
  • We will continue to work with our Contract Growers to ensure compliance with the (BPC) Poultry Supply Chain Ethical Compliance Code of Practice (BPC CoP) and our MOU
  • Together with the BPC and GLAA we have organised and delivered regional meetings to advise our Supply Chain Partners how to adopt similar systems and procedures and advise on how to sign up to the BPC CoP.
  • We will continue to work to the standards of the BPC (CoP) which incorporates the Ethical Trading Initiative (ETI) Base Code and will continue to strive to adhere to and maintain these Standards in our Business.
  • We have set up a Disclosures Helpline which is advertised prominently on each of our sites, and have posted Modern Slavery advisory information posters prominently on each of our sites.
  • We will again undertake face to face audits with Catchers and other high risk Contractors e.g. with Washers and Muckers and Staff Agencies.
  • We will continue to work with the GLAA and have committed to hold 6 monthly meetings with the Catchers. We will extend these meetings to include the high risk Contractors i.e. Washers and Muckers.
  • We are a Stronger Together Business

Modern Slavery Training

 We will continue to provide our Employees, Managers, Directors and Supply Chain Partners with the necessary tools and training, as well as support, guidance and information based on current advice from the GLAA to equip them with the skills required to identify and prevent Modern Slavery and Human Trafficking by:

  • Employees: Tool Box Talks and Poultry Passport Training – We have been instrumental in having a Modern Slavery module added to the Poultry Passport Training Scheme – minimum standards of training provided for the Poultry Industry.
  • Managers: Engage with them in Monthly Management Meetings
  • Directors: Updates from weekly HR report
  • Supply Chain Partners: face to face meetings and MOU.

We will maintain:

  • Our commitment to the attendance of relevant personnel at Stronger Together and ETI Modern Slavery Workshops.
  • Our support of Stronger Together
  • Maintain our presence on SEDEX – (Retailer recognised database)

Principal Risks

We will continue to undertake internal audits as a means of identifying the principal risks relating to slavery and human trafficking in our Business and Supply Chain Partners and will, if identified as High Risk, request external assistance. Areas of highest risk are those involving manual, unskilled, repetitive activities and have not been identified as intrinsically geographical.

High risk activities will be monitored and reviewed on a regular basis. Any undesirable issues discovered within our Contractor base will be immediately highlighted to the GLAA. Any issues involving people will be notified to the appropriate authorities.

Whistleblowing

We encourage consistently an open culture in all our dealings between Employees and people with whom we come into contact. Effective and honest communication is essential if malpractice and wrongdoing are to be dealt with effectively. Our Whistleblowing Policy sets out guidelines for individuals who feel they need to raise certain issues in confidence, which could include forced labour concerns. We provide an independent confidential channel of communication for whistleblowing.

This Policy applies to all individuals working at all levels within the Organisation, including Senior Managers, Officers, Directors, Employees, Consultants, Contractors, Trainees, Homeworkers, Part-Time and Fixed-Term Workers, Suppliers, Casual and Agency Staff.

Key Performance Indicators

As part of the Audit Process referred to above, we will employ primary KPIs, remedial actions, timescales and steps for completion, for the following:

  • The outcomes of internal and external compliance audits we undertake, including all legal obligations.
  • The ongoing monitoring of payroll systems for warning indicators. i.e. checking for anomalies in Bank Accounts or Employee addresses
    • We have implemented a Probationary Welfare Review which encourages employees to address and report any issues.
    • Our Anti Slavery hotline has not been accessed but we will continue to monitor for usage
    • The Mental Health support partnership with Farming Communities Network (FCN) will continue to be monitored.
  • Inconsistencies within normal day to day staffing of operations, and potential Staff welfare issues.

These will be constantly reviewed and modified where appropriate for inclusion in future versions of this statement

Board Approval

We are confident that by taking these steps we will be successful in identifying and reducing, with the aim of eradicating, the risk of there being slavery or trafficking in our Business and our Supply Chains.

As a responsible Employer we are committed to identifying and implementing improvements in our Processes, Procedures and Systems.

This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Organisation’s Slavery and Human Trafficking Statement for the financial year 2017/18.

Our current and future endeavours remain the identification and eradication of actual / potential slavery and human trafficking issues, and I confirm that the contents of this statement have been approved by our Board of Directors.

James W Hook
Managing Director
For and on behalf of P D Hook Group & Hook2Sisters Ltd.
October 2018