M.P. Evans Group PLC (“the Company” or “the Group”) embraces its responsibilities to combat slavery and human trafficking. This statement is made in accordance with the Modern Slavery Act 2015 and sets out those steps taken by the Group to date to prevent slavery by both the Group and its suppliers.
The Company is the holding company of a Group with its subsidiaries operating oil-palm plantations in Indonesia. It additionally has a minority share in a property-development company in Malaysia, to which it is in the process of selling its remaining 70 hectares of land in Malaysia. The Group’s turnover derives entirely from its Indonesian plantations. As an agricultural business, the Group employs some 10,000 estate workers, as well as working with contractors who are responsible for the delivery of other services including planting and construction. In addition, the Group acquires supplies critical to its operation, including seedlings, machinery spare parts and fertiliser, from third-party suppliers. It also purchases some oil-palm fresh fruit bunches from third parties.
The Group’s board has full oversight of all corporate policies and recognises the importance of modern slavery and human trafficking as a current issue. In September 2020, following publication of a carefully-researched news article by investigative journalists highlighting instances of modern slavery within the palm-oil industry, the executive board together with senior management in Indonesia, reflected on modern-slavery concerns levelled at the industry. The Group’s own policies and practices were thoroughly scrutinised by reference to a list of specific concerns and scenarios set out in the article and, in each case, management was satisfied that the Group’s own practices and policies ensured that no modern slavery exists within the Group’s own operations.
The Group’s Modern Slavery Act statement and all related policies and procedures are reviewed by the Group board annually.
Internal procedures and policies
M.P. Evans Group PLC has policies on sustainable and ethical business, including the detection and prevention of modern slavery in the Group or in any of its suppliers or business partners.
Since its initial statement under the Modern Slavery Act, the Group has adapted its own employment practices to increase the number of workers that are engaged and paid individually by the Group. In addition, the Group has a whistleblowing hotline run by an independent provider, accessed by telephone, email, WhatsApp or SMS messaging, which can be used to report any concerns about modern slavery.
The Group has produced training material that explains modern slavery and sets out indicators of potential modern slavery. This was translated into Indonesian and deployed in November 2019 with the intention that all staff with any management responsibility receive training in their local language before the end of 2020.
Suppliers and contractors
The Group assesses external contractors and independent smallholders supplying it with fresh fruit bunches as being at the highest risk of modern slavery. In 2019 the Group wrote to all its suppliers setting out its expectations in respect of modern slavery. Also in 2019, the Group conducted site visits to its six largest suppliers to explain its policies on modern slavery and look for any indicators of modern slavery. Since then, all the Group’s purchase contracts have contained clauses covering the responsibility of suppliers regarding modern slavery. Whilst the Group would expect to engage with suppliers to work towards a resolution of any issues identified, since November 2020, it has included clauses in all contracts which allow for termination without notice or compensation in cases where a supplier is guilty of modern slavery.
Impact of Covid-19
The Group’s response to the Covid-19 pandemic interrupted its delivery of training, meaning the objective to deliver training to all supervisory staff before the end of 2020 was not met. However, training has now been delivered on 25 courses to a total of 326 members of staff, and it remains the Group’s intention that this training will be delivered to all supervisory staff before the end of 2021. Whilst the pandemic continues to reduce the extent of travel between the Group’s regional office and its operations, local management and staff remain alert to signs of modern slavery which, if seen, could be quickly communicated to the Group’s senior management. The independent whistleblowing hotline is also available as a reporting channel.
The ability of the Group to conduct visits to suppliers has been curtailed by the Covid-19 pandemic, but it intends to repeat this exercise when circumstances allow.
The Group has begun a pilot project that will eventually lead to certification of all its independent smallholders under the RSPO Independent Smallholder Standard. This standard includes commitments and training to guard against modern slavery. The Group has developed a system for monitoring its highest risk suppliers and validating that no signs of modern slavery have been detected and will be deploying this system in the second half of 2021.