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Modern Slavery

Anti Trafficking and Modern Slavery Policy

Medina Food Group Ltd adopts and maintains zero-tolerance approach to all forms of modern slavery, servitude, forced or compulsory labour, and human trafficking in our operations and across our supply chain. In line with the Modern Slavery Act 2015 and NHS Supply Chain Standards, we are committed to acting with integrity, transparency and fairness in our business dealings and relationships. We expect our suppliers, contractors, and service providers to operate to the same high ethical standards and implement robust systems to prevent modern slavery risks. The Directors have the responsibility for ensuring that all those under our control complies with it.

Purpose

The purpose of the policy is to prevent occurrence of modern slavery in our organisation and supply chain. Our policy aligns with the NHS Supplier Code of Conduct, particularly in relation to labour rights and comply fully with the Modern Slavery Act 2015. This policy supports the identification, mitigation and remediation of modern slavery risks and promote transparent reporting and continuous improvement.

Aim

The aim of this policy is to prevent trafficking, to effectively prosecute criminals, and to better protect the victims, in line with the highest European standards.

Scope

This policy applies to all employees, contractors, suppliers and any other third parties acting on behalf of Medina Food Group Ltd.

Requirements

  • Under The Immigration Asylum, and Nationality Act 2006 employers must not employ illegal migrants.
  • Human Trafficking (Modern Slavery Act 2015):
    • A person commits an offence if the person arranges or facilitates the travel of another person (‘’V’’) with the view of V being exploited.
  • Slavery, servitude and forced or compulsory labour (Modern Slavery Act 2015):
    • A person commits an offence if the person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude.
    • A person commits an offence if the person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour.
  • The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest a breach of this policy.
  • You must notify your manger as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
  • Managers must report concerns immediately.
  • You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chain at the earliest stage possible.
  • If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.

Breaches of this policy

  • Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
  • We may terminate our relationship with other suppliers if they breach this policy.

Key Commitments

  • Ensuring all employment is freely chosen with no coercion, debt bondage or forced labour
  • Prohibiting the use of child labour in our organisation
  • Respecting the right to fair pay, Safe working conditions, and freedom of association.
  • Transparent reporting, continuous improvement and supplier compliance.
  • Responsible recruitment process
  • Thorough new starter, staff vetting and staff security procedure in place
  • No discrimination is allowed
  • No harsh or inhumane treatment is practised

Positive Food Safety & Quality Culture Excellence

Medina Food Group Ltd recognises that a strong organisational culture is essential for both food safety and ethical labour practices. We are delighted to be certified at the highest grade A in BRCGS for over ten years. In line with BRCGS Food Safety standards, we promote behaviours that support integrity, transparency, accountability, and open communication. These cultural expectations directly reinforce our commitment to preventing modern slavery.

Our food safety culture framework includes:

  • Leadership commitment to ethical behaviour
  • Ensuring staff are happy and encourage teamwork
  • Empowering employees to speak up without fear
  • Open reporting channels for concerns
  • Regular training and awareness programmes
  • Fair treatment and respect for all workers
  • Supplier monitoring and ethical sourcing practices

These behaviours reduce the risk of labour exploitation, coercion, and unethical practices within our organisation and supply chain. By integrating BRCGS cultural principles into our Modern Slavery Policy, we ensure that ethical labour standards are embedded into everyday operations, staff behaviour, and supplier relationships.

We run an annual anonymous survey to gain open and honest feedback from employees across the business. The results from this survey are shared with staff and action plans are created to drive continuous improvements.

Training & Awareness

  • Mandatory Annual Training is provided to all staff in our organisation
  • Training includes how to identify signs of modern slavery and how to report concerns

Monitoring & Review

  • This policy is reviewed annually, or sooner if significant changes occur
  • To ensure transparency, we have published our Modern Slavery Statement on our organisation’s official website