Section 54 of the Modern Slavery Act 2015 requires any commercial organisation with a turnover of £36m or more that carries out business in the UK to produce a Modern Slavery and Human Trafficking statement for each financial year.
This is Fruugo’s first Modern Slavery and Human Trafficking Statement and it explains the steps that Fruugo has undertaken during the 2022-2023 financial year to identify, prevent and mitigate modern slavery and human trafficking in our operations and supply chains. This statement also sets out our aims for the 2023-2024 financial year.
The Board and management of Fruugo has a zero-tolerance approach to modern slavery and human trafficking and we are committed to ensuring that there is no modern slavery or human trafficking in any part of our business, including our supply chain.
Our Modern Slavery and Human Trafficking Statement covers Fruugo.com Ltd, Fruugo (Ireland) Ltd and Fruugo PLC, respectively all the legal entities within the Fruugo group of companies.
Our Business
Fruugo is a global marketplace, which allows independent retailers and buyers to connect with each other. Our mission is to enable retailers anywhere to be able to sell their products to shoppers everywhere. Our supply chain therefore comprises suppliers which primarily provide us with the goods and services essential to the development of our technologies, and the servicing of our partnerships.
We are committed to acting ethically and with integrity in all of our business dealings and relationships and in implementing and enforcing effective systems and controls to combat modern slavery and human trafficking. We endeavour to ensure that there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.
Our Supply Chain
We look to procure products and services from high quality and high integrity suppliers. We achieve this through a robust selection process and ongoing management of suppliers who fully comply with our safety, environmental and ethical standards.
We recognise the risks of partnering with a varied spectrum of global suppliers and the possibility of modern slavery occurring deeper in those complex supply chains. Fruugo is committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business, and that the same high standards are applied by our business partners. Fruugo has a robust set of guidelines and policies in place that inform our work, and ensure we are considering the impact of our corporate behaviour as appropriate.
At the time of writing, Fruugo is not aware of any current or recent incidents, nor accusations of forced/involuntary labour or human trafficking in our operations or those of our business partners.
Policies & Procedures
Fruugo has a Third Party Code of Conduct which focuses on maintaining positive relationships with all counterparties, including business partners, suppliers and the wider communities in which we work. The policy promotes working within the laws and regulations of the countries in which we operate (including, by implication, those relating to forced/involuntary labour and human trafficking), promoting high ethical standards and a culture whereby people are empowered to report issues of concern.
Business integrity is a key standard in the selection of partners, contractors and other organisations with which Fruugo works. This policy is communicated to all employees and compliance with its requirements is a condition of employment with Fruugo.
Fruugo is committed to providing safe and healthy working conditions for its personnel and conducts its business as a responsible corporate citizen.
Contractual Terms
Fruugo’s template contractual terms for suppliers require the highest standards of business ethics, compliance with all applicable laws and commitment to health, safety and the protection of the environment and personnel. When negotiating agreements using a third party’s contractual terms, we insist that modern slavery issues are covered comprehensively.
Third-Party Due Diligence
We undertake and will continue to undertake, due diligence when considering new suppliers and we will continue to regularly review existing suppliers.
Fruugo’s due diligence throughout the financial year ahead will include:
- An enhanced approach to third-party risk management, including better risk identification, assessment, mitigation, controls and ongoing monitoring.
- We will undertake a company-wide risk assessment to identify the areas of risk in our business supply chains.
- We will progress with embedding modern slavery throughout the procurement lifecycle.
- We will increase the frequency of contract reviews with suppliers and will take steps to improve substandard supplier practices by insisting on action plans and if appropriate, invoking sanctions on suppliers, including the termination of the business relationship.
- We will expect all of our contractors, suppliers and other business partners have their own policies in place relating to working practices or modern slavery, or for evidence to be available to ensure their standards are in accordance with Fruugo’s expectations.
- We will continue to develop appropriate clauses and wording for all relevant documents, including contracts including provisions to ensure that any supplier subcontractors comply with all applicable anti-slavery and human trafficking laws, statutes and regulations including but not limited to the Modern Slavery Act 2015.
- Fruugo will implement a ‘Country Risk List’. This list will be based on external indices and data such as the Walk Free Foundations Global Slavery Index and the UK Foreign, Commonwealth and Development Office’s Human Rights and Democracy report.
- Fruugo will complete a risk assessment on all its new suppliers and sellers prior to onboarding. We will categorise all third parties as low, medium or high risk, based on a range of factors and different due diligence requirements will apply depending on which category the third party falls into. Assessments and additional due diligence will be conducted by the relevant team based on the determined risk level.
- Suppliers exposed to elevated geographic risk will be risk accepted by the business and must be approved at a Director level.
- We will undertake more targeted dialogue with international suppliers not subject to the UK Modern Slavery Act.
- We will have procedures in place for managing issues raised during the due-diligence process, including referral to Risk and Audit, mitigation where possible and risk acceptance by appropriate senior representatives.
Training and Awareness
We understand that education and training is a critical component to ensuring that our company has a robust approach to tackling modern slavery and human trafficking. Our employees have all undertaken training on the core issues and have all been briefed as to the importance and seriousness of the issues by their Heads of Departments.
This year we will be producing an updated training module to raise awareness and increase compliance for all employees within the company. We will also be undertaking more in-depth, bespoke training with employees whose roles require additional awareness of the issues and whose areas of the business are identified as high risk in our company wide risk assessment.
Reporting Concerns Relating to Modern Slavery
By encouraging a culture of openness within our organisation, Fruugo aims to prevent any form of malpractice. We encourage all employees to raise issues which concern them at work expeditiously through the Whistleblowing Policy which is made available to them.
Monitoring Actions
Our Board of Directors shall monitor progress in respect to the above actions throughout the financial year ahead and our commitment to tackling modern slavery and human trafficking will continue to underpin how we do business. We will take measures to ensure compliance and address any potential instances of non-compliance robustly.
We will regularly undertake reviews of the actions being taken to ensure they remain relevant and effective.
Statement Approval
Executive responsibility for this Modern Slavery and Human Trafficking Statement rests with the Fruugo Board of Directors.
The Fruugo Board of Directors approved this statement on 30-03-2023.
Tony Preedy
Managing Director
