Modern Slavery & Human Trafficking Statement

We are proud to commit to developing and adopting a proactive approach to combating slavery and human trafficking and reviewing and improving our practices to combat slavery and human trafficking.

Hidden labour exploitation is exploitation of job applicants and workers by third party individuals or gangs other than the employer or labour provider including 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.

This policy covers all those employed at Billington Foods including both operational and warehouse facilities and stretches into the Supply Chain and/or in any part of the business.


  • Peter Allan, Managing Director has overall responsibility for ensuring this policy is maintained and applied.
  • Mark Traynor, Head of People has responsibility for ensuring the delivery of the policy and that all recruitment partners comply with all legislative and moral standards.

Policy Commitments

Billington Foods shall:

  • Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.
  • 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.
  • Ensure that all staff responsible for directly recruiting workers are trained to be aware of issues around third party labour exploitation and signs to look for and have signed appropriate Compliance Principles.
  • Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
  • Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and police.
  • Provide information on tackling “Hidden Labour Exploitation” to our workforce through workplace posters and induction.
  • Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
  • Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities by contacting the People Department, writing confidentially to Mark Traynor, Head of People, Billington Foods, Arkwright Way, Scunthorpe, N. Lincs, DN16 1AL and/or by use of the independently managed whistleblowing line.
  • Require labour providers and any other organisation in the supply chain to adopt policies and procedures consistent with the above.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Slavery and Human Trafficking statement for the financial year ending 31 August 2023.

Peter Allan

Managing Director