Modern Slavery Statement


It is the ethos of Circle Foods to ensure that there is no modern slavery or human trafficking within our corporate activities or within our supply chains.

Organisational Structure and Supply Chains

Circle Foods supplies food manufacturers, processors and wholesale businesses throughout the UK and several EU countries.

Our supply chains are based predominantly in Europe, but includes also suppliers around the globe, and we require all of our suppliers and partners to commit to complying with the Modem Slavery Act 2015.

Policies, Standards and Practices

We are a member of Supplier Ethical Data Exchange (SEDEX) and we request other SEDEX suppliers to link with us, otherwise suppliers are requested to sign off and confirm compliance with Ethical Trade Initiative (ETI) standards, or requested to provide copies of ethical policies and procedures.

We operate the following policies that detail our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations and supply chain:

Awareness Programme

All relevant employees are made aware of the basic principles of the Modern Slavery Act 2015. Key areas include:

  • Understanding human trafficking and labour exploitation
  • How employers can identify and prevent slavery and human trafficking
  • What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and what external help is available


All relevant personnel shall be provided with further training on identifying and preventing modern slavery where necessary.

Preventing Hidden Labour Exploitation Policy

We are committed to developing and adopting a positive and proactive approach in tackling the hidden exploitation of Migrant Workers. Circle Foods currently operates two office-based functions located in Reigate and Cardiff, and both comply fully with all current UK employment legislation.

All suppliers are obliged to ensure that any third-party labour supplier will hold a GLA licence, or recognised equivalent.

We encourage suppliers to adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gang masters Licensing Authority, or equivalent within their respective jurisdictions

Labour Providers

Circle Foods do not use any third-party labour providers.

Supplier / Procurement Code of Conduct

We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code. Non-compliance with the Modern Slavery Act will lead to appropriate sanctions, and potential termination of the business relationship, if necessary actions and obligations are not met.

Reporting Concerns

We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

Due Diligence

Circle Foods recognises that the principal exposure to Modern Slavery is within the supply chain, we undertake due diligence when considering new suppliers, and review our existing suppliers.

Reviews include:

  • Assessing and reviewing the supply chain to consider their particular product and or geographical risks of modern slavery and human trafficking.
  • Evaluating the modern slavery and human trafficking risks of each new supplier.
  • We conduct risk assessments and endeavour to monitor supplier ethical conduct.
  • We are in the process of building SEDEX membership progressively across our supply base, all our supply chain is encouraged to demonstrate good ethical practise either by having SEDEX membership, sign up to ETI code, or have in suitable ethical policies.

This statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 and constitutes Circle Foods Slavery and Human Trafficking Statement for the foreseeable future.


This statement has been approved by the Company Directors, who will review and update as required.