Modern Slavery Statement
Keith Spicer is a global leader in the manufacture, marketing and distribution of tea, spices, herbs, seasonings, and other flavours to the food industry and is part of the Harris Freeman Group. Harris Freeman and its subsidiaries, Harris Tea, Southern Tea, Keith Spicer, Harris Spice and Spice Products, conducts its business in compliance with applicable law, and in an ethical and socially responsible manner. The Company has a culture based on fundamental values of integrity, fairness, mutual respect, teamwork, and innovation. Harris Freeman fully supports the United Nations Global Compact’s (UNGC) guiding principles on human rights and labour and aim to provide an example of good human rights and labour practices throughout our business activities.
All suppliers and contractors ("Suppliers") who wish to conduct business with Harris Freeman and its subsidiaries, Harris Tea, Southern Tea, Keith Spicer, Harris Spice and Spice Products, are expected to conform to the principles and practices as set forth in this document. Failure to conform as expected may result in a loss of business with the Company.
Section 1. Compliance with Law: All our business activities conform to applicable legal requirements, including those requirements pertinent to equal employment opportunity, wages and benefits, and worker and product safety.
Section 2. Employment Practices: The following principles apply to our employment practices:
A. Child Labour: Child labour is strictly prohibited. We do not employ workers under the legal age of employment. u
B. Prison or Forced Labor: We do not use prison or forced labour or any form of indentured servitude. The use of physical punishment, confinement, threats of violence or other forms of physical, sexual, psychological, or verbal harassment or abuse as a method of discipline or control is prohibited.
C. Working Hours: Our employees work in compliance with all applicable laws pertaining to the number of hours and days worked. Employees are provided with reasonable daily and weekly work schedules, and adequate allowance is made for time off.
D. Compensation: Employees are compensated and provided with wages and benefits that comply with applicable laws, including appropriate compensation for overtime work and other premium pay situations required by applicable law.
E. Non-Discrimination: We conform to all applicable laws prohibiting discrimination in hiring and employment practices on the basis of race, religion, sex, age, physical ability, national origin, or any other applicable prohibited basis.
F. Workplace: We provide our employees with safe and healthy working conditions.
Section 3. Business Practices:
A. General: Purchases of materials and services are only made from Suppliers who continually meet Harris Freeman’s and its subsidiaries Harris Tea, Southern Tea, Keith Spicer, Harris Spice and Spice Products, specifications on manufacturing practices, distribution methods, product quality, delivery dates, and price objectives. Our Code of Conduct is not in lieu of, but is in addition to, the Suppliers' obligations to the Company, as set forth in any written agreement between the Company and the Supplier. Should there be a conflict between this Code of Conduct and the agreement in question, the agreement shall control.
B. Minority/Disadvantaged Businesses: The support of a diverse business community is important to Harris Freeman and its subsidiaries, Harris Tea, Southern Tea, Keith Spicer, Harris Spice and Spice Products. Harris Freeman’s Supplier Diversity Program seeks to develop relationships with qualified minority, women-owned and/or disadvantaged businesses that meet Harris Freeman's quality standards. The economic growth of a diverse business community will occur through contracting with minority, women-owned and/or disadvantaged businesses that can supply high quality goods and services at competitive prices. Our Suppliers honour the requirements of all applicable law governing contracts with minority, women-owned, and disadvantaged businesses.
C. Supplier Products: All products when offered for sale to the Company shall comply with the Company's specifications and all applicable laws of the country and political subdivisions in which they are to be offered for sale.
D. Audits: Suppliers periodically conduct audits and inspections to ensure their compliance with the principles set forth in this document. In addition, our Company may conduct such audits and inspections of Supplier's facilities, records, and employees to confirm compliance with this document. Unsatisfactory audit results may result in the Company terminating its relationship with the Supplier, without further liability to the Supplier.
Section 4. Business Ethics:
A. General: The Company is committed to uncompromising integrity in all that it does. While standards of conduct are mainly based on laws, they also reflect the values that define the Company.
B. Compliance with Laws: Employees and directors of our Suppliers are required to comply with all applicable laws, rules, and regulations. Such persons are also responsible for honouring and abiding by the contracts that Supplier has entered with the Company, and undertakings and other commitments Supplier has with government authorities.
C. Conflicts of Interest: Our employees refrain from accepting gifts and entertainment from suppliers.
D. Confidential Information: The Company's business information is a valuable corporate asset. Supplier and its employees and directors have an obligation to safeguard confidential information about the Company and to protect it against unauthorised disclosure. This obligation is not limited to the duration of the Company's relationship with the Supplier, or the duration of employment or service of the Supplier's employees with the Supplier.
E. Antitrust and Competition Laws: Most countries have laws that govern the ways in which companies may compete. The purpose of these laws is to prevent interference with a competitive market system. We will comply with all such laws.
F. Respect for the Environment: Our Company and suppliers will conduct their Business in a manner compatible with the environment and in accordance with applicable law. Reasonable standards of care are to be taken to protect the environment and to provide for the health and safety of employees and the communities in which we operate worldwide. To accomplish this, we take prudent steps to minimize solid waste by reducing, reusing, and recycling materials; encourage conservation of resources and energy; provide training and education for its employees, as appropriate; and support efforts to establish and implement policies that also protect the environment.
G. Ethics and Compliance Helpline and Whistle-blower Policy
Keith Spicer recognises and respects each employee’s right to freedom of association, including the right to join trade unions. Keith Spicer encourages its employees, customers, suppliers and other stakeholders to raise concerns or make disclosures when they become aware of any actual or potential violation of any of our policies or law, including any human rights abuses. We also encourage reporting of any event (actual or potential) of misconduct that is not reflective of our values and principles. The avenues available for raising concerns include: • Line Manager, Head of Operations , Head of HR or the external confidential Whistleblowing Helpline which is managed by a third party. If any such issues were reported Keith Spicer would undertake an immediate and thorough investigation into the concerns raised. If the investigation confirmed the concerns to be true, we would take firm action to address the issues and protect those affected. Since starting with our external confidential helpline at the beginning of 2020, Keith Spicer has not received through its whistleblowing procedure, any reports of forced, compulsory, slave, trafficked or bonded labour in our operations
H. Our due diligence processes for slavery and human trafficking
We are very aware of our responsibilities to the people who grow and pick our tea, and of our responsibility to help sustain the environment on tea estates. One of the ways in which we are fulfilling these responsibilities is through our collaboration with the Rainforest Alliance and other similar organisations.
I. Training on slavery and human trafficking
Senior Managers in our Business have been educated about slavery and human trafficking. The objectives of this training includes: providing colleagues with an understanding on the scope of the human trafficking and slavery issue, training colleagues on how to identify slavery in the supply chain, providing examples of red flags; and reminding colleagues of our internal reporting procedures. Throughout the next 12 months, we plan to provide further training to all of our Managers and Supervisors in our Business to enhance our ability to identify and combat any slavery and trafficking issues in our Business.