Preventing Hidden Labour Exploitation

Policy Statement: Preventing Hidden Labour Exploitation: Norseland Ltd commits to developing and adopting a proactive approach to tackling hidden labour exploitation. Hidden labour exploitation, is the exploitation of job applicants or workers by third party individuals or gangs other than the employer or labour provider. This includes rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation, payment for work-finding services and work-related exploitation such as forced use of accommodation. It is understood that it is often well hidden by the perpetrators with victims, if they perceive of themselves as such, reluctant to come forward.

Coverage: This policy covers all sites owned by Norseland Ltd and applies to all permanent, temporary and agency employees.

Responsibility: The overall responsibility for this policy is with the Business Leadership Team.
The Head of HR & CSR has responsibility for the policy within the company.

Policy Commitments
Norseland Ltd shall:
1. Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to
have responsibility for developing and operating company procedures relevant to this issue.

2. Accept that job finding fees are a business cost, and will not allow these to be paid by job
applicants. The Company will not use any individual or organisation to source and supply workers
without confirming that workers are not being charged a work finding fee.

3. Ensure that all staff responsible for directly recruiting workers are aware of issues around third
party labour exploitation and signs to look for and have signed appropriate Compliance Principles.

4. Ensure that labour sourcing, recruitment and worker placement processes are under the control of
trusted and competent staff members.

5. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the
Gangmasters Licensing Authority and police.

6. Provide information on tackling “Hidden Labour Exploitation” to our workforce through workplace
posters, worker leaflets, induction, other training.

7. Encourage workers to report cases of hidden third party labour exploitation, provide the means to
do so and investigate and act on reports appropriately.

8. Positively encourage and support employees and agency workers to report such exploitation which
may be occurring within their communities.

9. Require labour providers and other organisations in the labour supply chain to adopt policies and
procedures consistent with the above.

Our Company Values:
–        Cost effective in every way
–        Outstanding customer service
–        We are all stakeholders in our business
–        Continuously improving working methods
–        Keep it simple and work together as one outstanding team

We comply with The ETI Base Code – Ethical Trade Initiative and subscribe to SEDEX process – a code that promotes respect for workers around the world.

Ethical Trading Initiative

Clive Richer – Corporate Social Responsibility Manager

‘Here at Norseland we care not just about our staff, but also our local community in which we are based. We believe it’s an important part of the Norseland strategy to actively engage in the lives of people around us.

We have a team responsible for looking into staff, community and environmental issues and are always looking for continuous improvements in what we do. As a new initiative for 2016 we will be writing to key individuals within the local community asking for feedback on how they believe we are performing. It is hoped that through feedback we will go from strength to strength. We want our staff to be proud of the company they work for and we want to employ staff from the local community, so we believe we are all stakeholders in our business.’

As a medium sized company and large employer in the local area, here is a small selection of some of things we are actively involved in or support our local community with:-

  1. As a living wage employer, we hire directly from the local community providing work experience and apprenticeships
  2. Working with the local primary school, planting and developing an orchard on our Production Site
  3. Introduced electric cars into our fleet to reduce our environmental impact
  4. Sponsoring numerous local charity events and sport teams
  5. Raising over £2000 for two local charities each year

2017 is proving to be a great year for Norseland Ltd in both local and national awards and we are proud to have won 3 of the 5 awards we became finalists in.  This year we have become proud winners of the National Manufacturer Excellence Awards “Dairy Manufacturer of the year award” which was awarded in November 2017 as well as scooping two regional awards which included the coveted Business of the Year 51+ employees as well as the Marketing & Promotion Award. Both of these awards were part of the Somerset Business Awards which took place in October of the same year.

Somerset Business Awards – Business of the Year Award 51+ – Winner

Somerset Business Awards – Promotion & Marketing Award – Winner

Food Manufacture Excellence Award – Dairy Manufacture of the Year – Winner

Food Manufacture Excellence Award – Training Programme of the Year – Finalist

IGD – John Sainsburys Learning and Development Award – Finalist


UK Tax Strategy

Norseland Holdings Limited & subsidiaries – UK Tax Strategy

Tax Risk Management: Norseland assesses the tax impact of projects or transactions in the planning stage and aims to continuously identify and asses risk through the life cycle of these. Adherence to this strategy is the responsibility of the Chief Financial Officer in the UK and all individuals and teams who deal with tax matters. This includes the relevant central departments of Finance & Human Resources in the UK.

Tax Planning: Norseland undertakes planning to optimise its tax position where such planning aligns with the commercial objectives of the business. When undertaking this, Norseland complies with all relevant tax laws and fully considers all tax risks of projects or transactions. Where possible, Norseland will apply to take the benefit of tax incentives introduced by government to encourage investment, where it meets the necessary business and economic requirements. When management establish assistance is required, external advice will be engaged to assist with the above.

Relationship with Tax Authorities: Norseland adopts an open and transparent relationship with all relevant tax authorities and engages in regular proactive dialogue with those authorities. Norseland seeks to work collaboratively with tax authorities, particularly where areas of uncertainty are identified, with the intention of resolving matters quickly and efficiently.

Governance: This Tax Strategy has been approved by the Board of Directors and Group Tax Department, it will also be reviewed and updated on an annual basis.

Approved 03.11.17

This information is provided in compliance with the requirements of the Finance Act 2016, Schedule 19.