Modern Slavery Act Statement
Modern Slavery Act Statement
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 2023 – 31 March 2024.
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.
CBH head office is based in Enfield, and has two other distribution sites based in Coventry and Bradford. CBH has grown predominantly through franchise expansion and today does not directly own or operate any Cake Box stores. As of 31 March 2024, the franchise estate includes 95 franchisees, and a total of 225 shops and 26 kiosks across the UK.
All procurement is done via head office other than fresh fruit, which is sourced locally and this also includes the ingredients, equipment, and materials used by franchises. This means all products (other than fresh fruit) sold from every Cake Box store have been purchased centrally. Goods and services are sourced from just over 150 suppliers, which are predominantly based in the UK and the European Union. CBH also sources products such as balloons, candles, packaging, and goods for resale from China and Turkey.
Our Policy on Slavery and Human Trafficking
CBH has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships and implementing and enforcing effective systems and controls to reduce the risk of modern slavery and human rights abuse in the business, franchise estate, and supply chain.
CBH colleagues are encouraged to raise concerns if they become aware of or suspect any conduct violating any law, rule, regulation, or CBH’s policies. CBH's whistleblowing policy describes the procedure and different channels through which CBH employees can report any actual and suspected misconduct, ensuring that colleagues reporting their concerns remain anonymous and are protected from retaliation.
CBH has high ethical standards for the individuals and organisations they do business with. During the financial year 2021-22, CBH developed a Supplier Code of Conduct, which outlines what is expected from all contractors, suppliers and other 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 the 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. All suppliers and franchisees are required to acknowledge the Supplier Code, which is systematically included in all purchase orders issued.
Risk Assessment and Due Diligence
The risk of modern slavery and human trafficking in the business sits predominantly in the franchise estate and supply chain.
Our Franchisees
CBH franchisees operate independently, with support from CBH. All new franchisees receive a mandatory five-day training course 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. CBH divides the franchisee estate into five regions; each region has an audit officer, supported by a manager who audits all franchisees at least once a quarter. During the audits, audit officers verify payslips to ensure that all franchise employees are paid at least the minimum wage. CBH provide recommended rates of pay to all franchisees that exceed the minimum wage.
Our Suppliers
CBH works closely with suppliers to ensure high ethical standards across the supply chain. Every purchase order issued refers to the Supplier's Code of Conduct. CBH expects its business partners to communicate CBH standards with lower-tier suppliers. CBH mitigate the risk of human and labour rights abuse by building long-lasting relationships with suppliers and require all raw materials, food products and food packaging suppliers to complete self-assessment questionnaires, allowing CBH to better understand their business and prioritise those suppliers that require the most attention.
CBH continuously work with sustainability consultants at SLR Consulting (previously known as Carnstone Partners Ltd) to analyse ethical risks in the value chain and identify high-risk suppliers. CBH has implemented processes meaning for all high-risk suppliers and for medium-risk suppliers outside the UK and the EU; CBH requires an independent audit undertaken by third-party experts. For medium-risk suppliers based in the UK or the EU, the procurement team assess the need for a site visit or third-party audit based on a case-by-case basis based on Self assessment questionnaire results. As of the 31st of March 2024, 100% of high-risk suppliers and 91% (10 out 11) of medium-risk suppliers complied with this requirement, we are committed to achieving 100% compliance by the end of FY25.
Key Performance Indicators (KPIs) to measure the effectiveness of steps being taken
CBH has set the following key performance indicators (KPIs) to measure its effectiveness in identifying and preventing slavery and human trafficking:
• All of shops are audited at least once a quarter by CBH’s audit officers.
• All of new raw materials, food products and food packaging suppliers have completed a self-assessment questionnaire.
• All of high-risk suppliers and business partners have been audited in the last two year.
Training on Modern Slavery and Trafficking
CBH recognise the importance of training to ensure employees can identify the signs of modern slavery and act on them appropriately. During the financial year 2023-2024, CBH partnered with Stronger Together, a UK specialist organisation, to ensure all colleagues from team leader upwards (64 colleagues in total across human resources, procurement, and operations) received human trafficking and modern slavery training. CBH has delivered training on modern slavery and human trafficking to franchise owners. The board of directors also received refresher training on modern slavery during the year.
Next Steps
CBH recognises that they are in the evolving stages of their journey to tackle modern slavery exploitation in their own operations and supply chains. CBH has identified the following areas for additional focus during the financial year 2024-2025 and beyond:
• Provide refresher training for colleagues from HR, procurement, and franchise management on modern slavery and human trafficking every year.
• Complete a desk-based ethical risk assessment of all high-risk suppliers twice a year.
• Continue strengthening supplier due diligence, ensuring all medium and high-risk suppliers and business partners have been audited in the last two years.
• Continue to increase visibility and transparency across the supply chain, collecting detailed information on all primary producers via brokers and agents.
• To ensure all franchisees replace zero-hour contracts with permanent contracts.
Sukh Chamdal - CEO
Cake Box Holdings Plc
Dated 30th July 2024