Group Ethical Trade and Human Rights Policy

Description: Group Ethical Trade and Human Rights Policy

Policy Applicable to: Greosn Group

Policy Owner: Greosn Board

Last Updated: (Version 1) January 2025

Next update due: January 2026

Our Policy

Greosn is committed to doing business in a fair and ethical way. It actively works at meeting its moral, legal, ethical and humanitarian responsibilities. This policy provides the principles and framework that Greosn has adopted to manage this commitment.

Scope

This policy applies to all growing companies within the Greosn Group, their sites and locations across the UK and to permanent and temporary/seasonal employees. It does not apply to Pro-Force employees and agency workers.

Responsibility

It is the responsibility of the directors of each business in the group to review, agree and implement this policy.

Greosn Ethical Trade and Human Rights Responsibilities

Greosn has agreed the following in respect of its Ethical Trade & Human Rights responsibilities and includes its commitment to tackling Modern Day Slavery.

·        Group responsibility for Ethical Trading and Human Rights sits with the CEO, Matt Jarrett including the signing of the Modern Slavery Statement for the growing operations

·        Business responsibility for Ethical Trade and Human Rights including risk assessments and action plans sits with the directors of each business

·        The Group Ethical Compliance Manager and the external Group HR Consultant provides expertise and support to deliver this policy

Greosn Principles

Greosn has adopted the following principles:

·        Compliance with all legal requirements. In the UK this includes the Modern-Day Slavery Act and the Human Rights Act. Outside the UK this will include relevant local legislation

·        Commitment to tackling the most extreme forms of labour exploitation

·        Commitment to meeting the ETI Base code

·        Support of the UN Guiding Principles

·        Meeting the requirements of our customers’ Ethical Codes of Practice

·        Taking a risk-based approach to assessing issues

Other Relevant Policies

·        Anti-bribery and Corruption

·        Anti-Bullying and Harassment

·        Equality, Diversity and Inclusion

·        Freedom of Association

·        Grievance

·        Responsible Recruitment

·        Safeguarding

·        Whistleblowing

Legislation, Ethical Codes of Practices and Principles

Modern Slavery Act

Greosn is committed to ensuring that it tackles Modern Day Slavery within its business operations and supply chain. This includes supporting Stronger2gether to tackle issues of modern slavery and hidden labour exploitation.

The Modern-Day Slavery Act 2015 requires businesses with a turnover of £36m+ to produce a slavery and human trafficking statement for each financial year. Greosn complies with this legislation and publishes its statement annually.

Human Rights Act

Greosn embraces and complies with international conventions on human rights. These conventions include the Universal Declaration of Human Rights, Fundamental ILO (International Labour Organisation) Conventions and Voluntary Principles on Security and Human Rights.

The Human Rights Act 1998 came into force in the United Kingdom in October 2000. It is composed of a series of sections that have the effect of codifying the protections in the European Convention on Human Rights into UK law.

The Act sets out the fundamental rights and freedoms that individuals in the UK have access to. They include:

·        Right to life

·        Freedom from torture and inhuman or degrading treatment

·        Right to liberty and security

·        Freedom from slavery and forced labour

·        Right to a fair trial

·        No punishment without law

·        Respect for your private and family life, home and correspondence

·        Freedom of thought, belief and religion

ETI Base Code

Greosn is committed to meeting the standards set out in the ETI Base Code within its operations and its supply chain:

1.      Employment is Freely Chosen

2.      Freedom of Association and the Right to Collective Bargaining is Respected.

3.      Safe and Hygienic Working Conditions

4.      Child Labour Shall not be Used

5.      Living Wages are Paid

6.      Working Hours are not Excessive

7.      No Discrimination is Practised

8.      Regular Employment is Provided

9.      No Harsh or Inhumane Treatment is Allowed

Full details of the ETI Base Code can be downloaded from the ETI website: www.ethicaltrade.org/eti- base-code

UN Guiding Principles

Respect for Human Rights is at the heart of the Greosn Group and as such is an integral part of the way it does business. Greosn supports UN Guiding Principles (UNGP). The key principles are:

·        comply with all applicable laws and respect internationally recognised human rights, wherever they operate

·        seek ways to honour the principles of internationally recognised human rights when faced with conflicting requirements

·        treat as a legal compliance issue the risk of causing or contributing to gross human rights abuses wherever they operate

·        adopt appropriate due diligence policies to identify, prevent and mitigate human rights risks, and commit to monitoring and evaluating implementation

·        consult people who may potentially be affected at all stages of project design and

implementation, in a manner that ensures free and informed participation and takes into account language and other potential barriers to effective engagement, paying particular attention to

indigenous peoples and other groups, including women and girls

·        emphasise the importance of behaviour in line with the UNGPs to their supply chains in the UK and overseas. Appropriate measures could include contractual arrangements, training, monitoring and capacity-building

·        adopt or participate in effective grievance mechanisms which are transparent, equitable and

predictable, to enable the remediation of any adverse human rights impacts they cause or to which they contribute

·        be transparent about policies, activities and impacts, and report on human rights issues and risks as appropriate as part of their annual report

Customer Requirements

Greosn is committed to meeting its customers’ ethical compliance standards. Each business is required to know, understand, and meet their customers’ ethical compliance standards which may include:

·        Compliance with the ETI Base Code

·        SEDEX membership

·        Third Party Ethical Audit (frequency determined by customer’s code of practice)

·        Additional customer audits (determined by customer code of practice)

SEDEX Requirements

Greosn is an B member of SEDEX and each Greosn business is responsible for entering and sharing data with their customers:

Each Greosn business is required to:

·        Complete the online SAQ (Self-Assessment Questionnaire)

·        Update the SAQ every 6 months

·        Link their business to their customers

·        Know and understand their risk rating

·        Chase audit companies to upload audit reports within agreed timescales

·        Upload data to close out non-compliances as quickly as possible

·        Greosn businesses are required to have a third party SMETA audit in line with customer codes of practice

Third Party Audits

Greosn businesses are required to have a third party SMETA audit in line with customer requirements.

Customers will notify each Greosn business of their risk rating - low, medium or high risk. This is usually based on their SEDEX risk rating. This risk rating determines the frequency of third-party audits and it varies by customer. Third party SMETA audits will be booked with customer approved audit companies.

Greosn businesses should be audit ready at all times and should pro-actively manage the process whilst the auditor is on site.

The audit report will highlight all non-compliances to local management and a detailed action plan with defined timescales will be agreed and implemented.

Non-compliances should be closed out as quickly as possible:

·        Desktop - upload corrective actions on to SEDEX as quickly as possible

·        Follow up audit - ensure that this is booked as quickly as possible

The aim is to drive towards zero non-compliances and extend the time between audits. Audit reports and corrective action plans will be shared with customers through SEDEX. Each Greosn business is responsible for chasing the audit companies to complete this process to the timescales set out by customers.

Tackling issues of Modern Slavery

Greosn is committed to tackling issues of Modern Slavery and requires each business to:

·        Have one person from each business who has attended the Stronger2gether Training in the last 3 years

·        Complete the Stronger Together Good Practice Implementation Checklist and update annually

·        Input into the annual group modern slavery action plan to address gaps identified in the checklis

·        Be responsible for implementing the annual group modern slavery action plan and reporting their progress

·        Communicate to all employees (permanent, temporary and via an agency labour provider) an awareness of the Modern Slavery Indicators to look out for and who to contact to raise concerns and issues.

·        Have a well communicated procedure for workers to report complaints

·        Collaborate with the GLAA (Gangmaster and Labour Abuse Authority) to tackle issues when identified

·        Report major issues that are identified to the Group Compliance Manager including remedial action taken

·        Provide Information on activities carried out at business level to the Group for inclusion in the

Group’s Modern Slavery Statement

Fair Internal Practices

Greosn is committed to the following:

Working Hours and Overtime - it is expected that all Greosn businesses will comply with the WTD 1998 and the ETI Base Code Clause 6; Working Hours are not Excessive.

Businesses that do not currently meet these requirements will have in place a plan to achieve compliance.

Working hours and overtime are monitored at business level.

Clear and Fair Employment Practices - it is expected that all Greosn businesses operate with clear and fair employment practices:

·        Eligibility to work checks completed for all employees.

·        Employee contracts exist for all employees.

·        Effective documented disciplinary and grievance procedures exist and are available to all employees.

·        Employee handbooks/information exists and is available to all employees.

·        Employment practices comply with the Working Time Directive 1998 and the ETI Base Code.

·        Employment practices shall comply with the relevant current national laws including employment, immigration and social security.

·        Obligations to employees under the above laws shall not be avoided through the use of labour only contracting, subcontracting, home working or apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contract of employment.