Modern Slavery

Introduction
This statement applies to Cake Box Holdings plc (referred to in this statement as (‘CBH’). The information included in this statement refers to the financial period 1 April 2022 – 31 March 2023. 
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person's liberty by another, in order to exploit them for personal or commercial gain. 

About Cake Box Holdings Plc (our organisation structure and supply chains)
CBH is a franchise retailer and manufacturer of egg-free cakes with a growing store base across the UK. The Group specialises in making high-quality, individually crafted, and personalised fresh cream cakes for purchase on-demand or ordered in advance in-store or online. 

Our Head office is based in Enfield (Middlesex), and we have two other distribution sites based in Coventry and Bradford, respectively. CBH has grown predominantly through franchise expansion and today does not directly own or operate any Cake Box stores. As of 31 March 2023, our franchise estate includes 96 franchisees, for a total of 205 shops and 27 kiosks based across the UK. 

All procurement is done via our Head Office, and this also includes the ingredients, equipment, and materials used in our franchises. This means all products sold from every Cake Box store have been purchased centrally. We source goods and services from just over 100 suppliers, which are predominantly based in the UK and the European Union. We also source products such as balloons, candles, packaging, and goods for resale from China and Turkey. Out of our 130+ suppliers,38 are distributors or agents. 

Our Policy on Slavery and Human Trafficking
CBH has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to reduce the risk of modern slavery and human rights abuse in our own business, our franchise estate, or our supply chain.

Our colleagues are encouraged to raise their concerns if they become aware of or suspect any conduct violating any law, rule, regulation, or CBH’s policies. Our Whistleblowing Policy describes the procedure and different channels for CBH employees to report any actual and suspected misconduct. We ensure that colleagues reporting their concerns remain anonymous and are protected from retaliation.

We have high ethical standards for the individuals and organisations we do business with. During the financial year 2021-22, we developed a Supplier Code of Conduct which outlines what we expect from all our contractors, suppliers, franchisees, and others business partners. The Supplier Code is based on the Ethical Trading Initiative (ETI) base code, an internationally recognised code of labour practice founded on the conventions of the International Labour Organisation (ILO). The key components of our Supplier Code relating to the Modern Slavery Act include child labour, forced labour, discrimination, working hours and wages, freedom of association, and health and safety. We require all our suppliers and franchisees to acknowledge our Supplier Code, which is systematically included in all the Purchase Order (PO) statements we issue.

Risk Assessment and Due Diligence
The risk of modern slavery and human trafficking in our business sits predominantly in our franchise estate and our supply chain. We currently do not use agency labour in our operations, but we will monitor this topic as CBH continues growing.

Our Franchisees
Our franchisees operate independently, with support from CBH. We onboard all new franchisees with a mandatory five-day training that covers human resources (HR) management, health and safety, and labour rights. Franchisees must register with Peninsula, an HR outsourcing business that provides them with expert support and advice, notably on employee contracts and documentation. We also have appointed five area managers who audit all franchisees every quarter. During the quarterly audits, our area managers systematically verify payslips to ensure that all our franchise employees are paid the minimum wage.

Our Suppliers

We work closely with our suppliers to ensure high ethical standards across our supply chain. Every PO statement we issue refers to our Supplier's Code of Conduct. We expect our business partners to communicate our standards with lower-tier suppliers. We mitigate the risk of human and labour rights abuse by building long-lasting relationships with our suppliers. We also require all raw materials, food products and food packaging suppliers to complete self-assessment questionnaires, allowing us to better understand their business and prioritise those suppliers that require the most attention. 

In the Summer of 2023, we worked with sustainability consultants at Carnstone & Partners PLC to analyse ethical risks in our value chain and identify high-risk suppliers. We implemented new processes to ensure all high and medium-risk suppliers are independently audited every two years. As of the 31st of March, over 90% of them complied with this requirement and we are committed to achieving 100% compliance by the end of FY24. 

Key Performance Indicators (KPIs) to measure the effectiveness of steps being taken 

We have set the following key performance indicators (KPIs) to measure its effectiveness in identifying and preventing slavery and human trafficking: 

•    100% of shops are audited at least every quarter by CBH’s audit officers.
•    100% of new raw materials, food products and food packaging suppliers have completed a self-assessment questionnaire.
•    90% of high-risk suppliers and business partners have been audited in the last two years.

Next Steps

We recognise that we are in the early stages of our journey to tackle modern slavery exploitation in our own operations and supply chains. We have identified the following areas for additional focus during the financial year 2022-2023 and beyond:

• Upskilling our colleagues from HR, procurement, and franchise management on modern slavery and human trafficking.
• Developing a rigorous ethical risk assessment process for new and existing suppliers. This will include all suppliers completing a self-assessment questionnaire (SAQ), our procurement team using an ethical risk assessment tool based on SAQ and geographical parameters, and high-risk suppliers being independently audited at least twice a year.
• Increasing visibility and transparency across our supply chain, collecting detailed information on all primary producers via brokers and agents.

Training on Modern Slavery and Trafficking 

We recognise the importance of training to ensure our employees can identify the signs of modern slavery and act on them appropriately. During the financial year 2022-2023, we partnered with Stronger Together, a UK specialist not-for-profit, to ensure our team receive adequate training on human trafficking and modern slavery. In the summer of 2022, Stronger Together delivered a one-day training to key members of staff across human resources, procurement, and franchise management. Carnstone & Partners PLC also delivered a refresher training on modern slavery to our board of directors.  

Next Steps 

We recognise that we are in the early stages of our journey to tackle modern slavery exploitation in our own operations and supply chains. We have identified the following areas for additional focus during the financial year 2023-2024 and beyond: 

•    Train our colleagues from HR, procurement, and franchise management on modern slavery and human trafficking every year.
•    Extend training on modern slavery and human trafficking to franchise owners.
•    Complete a desk-based ethical risk assessment of all suppliers twice a year.
•    Continue strengthening our supplier due diligence, ensuring all medium and high-risk suppliers and business partners have been audited in the last two years.
•    Increase visibility and transparency across our supply chain, collecting detailed information on all primary producers via brokers and agents.

Sukh Chamdal - CEO
Cake Box Holdings Plc
Dated 4th July 2023