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 the steps the Group has taken to date to prevent slavery within the Group and 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.
All of the Group’s 2020 purchase contracts contained clauses covering the responsibility of suppliers regarding modern slavery. The Group is now introducing termination without notice or compensation in cases where a supplier is guilty of modern slavery. It expects this sanction to be included in all contracts taking effect in November 2020.
Impact of Covid-19
In 2020, the Group’s response to the Covid-19 pandemic interrupted its delivery of training, meaning the objective to deliver training to all staff with management responsibility in their local language before the end of the year will not be met. However, before the interruption, this material was used to train 1 in 8 of the Group’s existing staff and was used on two induction courses. Considering the challenges presented by Covid-19, the Group now intends that this training will be delivered to all supervisory staff before the end of 2021. Whilst the pandemic has reduced 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 ability of the Group to conduct visits to suppliers was curtailed in 2020 by the Covid-19 pandemic. It now intends to repeat this exercise during 2021 and continue thereafter with regular visits to its largest suppliers.
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. More immediately, the Group is in the process of developing a system for monitoring its highest risk suppliers and validating that no signs of modern slavery have been detected.