Modern Day Slavery Policy
Modern Slavery and Human Trafficking Statement
1. Introduction
This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and sets out the steps taken by R M Curtis Ltd. during the financial year ending April 2028 to prevent modern slavery and human trafficking in our business operations and supply chains. R M Curtis is committed to conducting business responsibly and ethically in line with the UK Modern Slavery Act 2015, the Ethical Trading Initiative (ETI) Base Code, SEDEX/SMETA ethical audit methodology, and BRCGS Global Food Safety Standard expectations. We recognise that manufacturing supply chains — including raw materials, packaging, logistics, and temporary labour may present risks, and we are committed to mitigating those risks through effective governance and due diligence.
2. Our Business
R M Curtis Ltd is a food manufacturer and distributor operating in the United Kingdom and supplying into the manufacturing, foodservice and retail industries. Our activities include sourcing of food ingredients, mixing and repackaging; packing into form filling bags, poly bags and pots; production, warehousing, and distribution. We have a global supply chain trading in ambient stable food products and are committed to working in a transparent way by ensuring our supply partners adhere to the same obligations in tackling modern slavery.
We work with suppliers in the following areas:
• Nuts, dried fruits and seeds
• Ingredients (dried pulses and snacking products)
• Chocolate and yoghurt coated inclusions
• Packaging materials (film, pots, labels, bags and cardboard)
• Manufacturing equipment and maintenance services
• Logistics and warehousing providers
• Agency labour providers
3. Policies and Standards Alignment
The organisation maintains policies that support ethical business practices and
compliance with SEDEX SMETA and BRCGS expectations, including:
• Modern Slavery Policy
• Supplier Code of Conduct (ETI Base Code aligned)
• Whistleblowing Policy
• Ethical Procurement Procedure
• Agency Labour Approval Procedure
• Health and Safety Policy
These policies are reviewed periodically and approved by senior management as part of
the organisation’s management system and ethical compliance programme.
4. Risk Assessment
In line with SMETA risk‑based principles, R M Curtis assesses modern slavery risks across operations and supply chains.
We recognise that modern slavery risks may arise in:
• Lower-skilled or temporary labour environments
• Agency labour provision in manufacturing and warehousing
• Overseas sourcing of raw materials and packaging
• Third-party logistics and warehousing
• Contract cleaning and facilities services
Risk assessment considers geography, sector vulnerability, labour models, supplier
transparency, and audit information where available.
5. Due Diligence Processes
Consistent with SEDEX and SMETA expectations, our due diligence processes include:
• Supplier onboarding checks and approval process
• Supplier Code of Conduct acceptance
• Risk-based supplier assessment
• Maintaining an approved supplier register
• Review of labour agency credentials and right-to-work controls
• Corrective action follow-up where issues are identified
Where higher risks are identified, additional verification steps such as supplier
questionnaires, audit review, or site visits may be undertaken.
6. Training and Awareness
Relevant employees, particularly those in procurement, HR, operations, and management
roles, receive modern slavery awareness training aligned to ETI Base Code principles and
SMETA audit expectations.
Training includes:
• Identifying indicators of forced labour
• Ethical recruitment principles
• Agency labour risk awareness
• Worker welfare monitoring
• Reporting procedures
Training records are maintained as part of the organisation’s BRCGS competency and
training requirements.
7. Reporting Concerns
Employees and stakeholders are encouraged to report concerns through internal reporting
channels. Reports are handled confidentially and investigated appropriately.
The UK Modern Slavery Helpline (08000 121 700) is also available.
8. Continuous Improvement
R M Curtis is committed to continuously improving its approach to preventing modern
slavery by:
• Reviewing ethical labour risks annually
• Monitoring supplier compliance expectations
• Maintaining SEDEX/SMETA audit readiness
• Reviewing labour agency arrangements
• Updating policies and training where required
Ethical labour controls form part of the organisation’s broader compliance and risk
management systems.
9. Board Approval
This statement has been approved by the Board of Directors of R M Curtis Ltd.
Name: Lynne Tempest
Title: Director
Date: 16/03/2026