The Restaurant Group Modern Slavery Statement 2024
This document has been published in accordance with the Modern Slavery Act 2015 and constitutes the Modern Slavery Statement for The Restaurant Group Limited and its relevant subsidiaries (including TRG (Holdings) Limited, Brunning & Price Limited, Blubeckers Limited, Ribble Valley Inns Limited, Wagamama Limited, Wagamama International Franchising Limited, Wagamama CPU Limited, TRG Leisure Limited, TRG Concessions Limited and Barburrito Group Limited) for the financial year ended 31 December 2023.
Introduction
As an employer and provider of goods and services we have a key role to play in the fight against slavery, servitude, forced labour and human trafficking (“Modern Slavery”). The Restaurant Group plc (“TRG”) has a zero-tolerance approach to Modern Slavery of any kind in both our operations and our supply chain. We have a responsibility to prevent and detect exploitation and to influence and work together with suppliers and business partners to raise labour standards in our industry. Although our operations and employees are primarily based in the UK, some of the ingredients and food products we use are sourced internationally, and it is our responsibility to promote high standards of ethical behaviour throughout our supply chain.
Our business
TRG is a significant player in the UK casual dining market, operating approximately 300 restaurants, pubs and concessions and employing approximately 14,000 colleagues. Our brands currently include Wagamama, Brunning & Price pubs and Barburrito, as well as a multi-brand Concessions business which trades principally in UK airports. As a responsible business, we recognise our obligation to ensure that our activities are guided by ethical principles and managed in the interests of all our stakeholders. For this reason, the Company has established environmental and social policies and procedures, as well as programmes that protect and sustain the environment, workers within our supply chains and restaurants, and our guests, which are all communicated to suppliers and staff as appropriate. The key policies and statements are also published on our website.
Supply chain purchasing model
Our international supply chain covers over 70 countries. We operate a centralised procurement model across our brands and divisions for food and services provided to our sites, through which we have established strong relationships with our suppliers, and through which we set minimum standards to be adhered to across the Group. We require all our direct suppliers to work closely with their own suppliers, distributors, agents and producers to promote best practice and transparency within our supply chain. For our Concessions outlets, we work closely with the master franchiser for each outlet to achieve similar outcomes.
Our policies
Our Ethical Sourcing Policy, which is published on our website along with other Company policies including those relating to Whistleblowing and Equality & Diversity, confirms our zero-tolerance approach to Modern Slavery in our supply chain. This policy is based on the Ethical Trading Initiative (“ETI”) Base Code for labour practice and the UN Guiding Principles on Business and Human Rights, and sets out our expectation for each supplier to thoroughly assess and ensure that all aspects of their supply chain are compliant. In 2023, we introduced and published a broad Human Rights Policy, affirming our commitment to preventing or mitigating human rights impacts both in our own operations and within our supply chain. We also have a Safeguarding Policy to address staff welfare issues, which is overseen by a dedicated safeguarding officer.
The Ethical Sourcing Policy explicitly prohibits suppliers, among other things, from: using any forced, bonded or indentured labour; employing child labour; charging workers fees or requiring them to lodge identity papers with employers; relying on workers who have been trafficked or transported for the purposes of exploitation; and imposing any form of harsh or inhumane treatment. Suppliers are also required to ensure they provide a safe and hygienic working environment, abide by national employment laws, and pay a fair wage. All suppliers are required to show compliance with this policy and to have their own policies and monitoring systems in place, as well as maintaining appropriate records.
New suppliers
We have a rigorous process for assessing new suppliers on their technical capabilities and ethical credentials. We do not engage with business partners, including suppliers, who do not meet our high standards. New suppliers in our managed supply chain are required to complete a declaration on Responsible Sourcing and Modern Slavery as part of their onboarding. Our procurement contract templates include explicit clauses requiring suppliers to warrant their compliance and that of their own suppliers with the requirements of the Modern Slavery Act. In addition, under the contract, when a supplier sub-contracts, they are required to conduct a third-party audit of that sub-contractor’s Modern Slavery compliance.
Members of our procurement team have been trained to identify the risk indicators of Modern Slavery in our supply chains, and receive annual refresher training on the Modern Slavery Act 2015, with emphasis on Section 54 (Transparency of Supply Chains).
We are committed to staying up to date with any relevant changes and amendments to the legislation and will ensure that the key members of our procurement team complete all the necessary refresher training as required.
Supplier Ethical Data Exchange (SEDEX) and ethical audits
Purchased goods and procurement-sourced services suppliers are required to register with and complete the Supplier Assessment Questionnaire within SEDEX, which is one of the main platforms through which companies can manage and improve working conditions in their global supply chains.
SEDEX has recently introduced a new Supplier Assessment Questionnaire for goods suppliers. The completion date for this is May 2024. Once this has been completed, we will ask suppliers who are considered to be higher risk according to their SEDEX Combined Risk Score (based on questionnaire responses and inherent country/site activity risk) to complete a SMETA audit if one has not already been completed in the last two years and made available on the SEDEX platform. We will then review the results of these SMETA audits to determine next steps.
SMETA audits (SEDEX Members Ethical Trade Audit) provide information on labour standards, health and safety issues, environmental performance and ethical matters, and are designed to help protect workers from unsafe conditions, overwork, discrimination, low pay and forced labour. Suppliers may be provided with a Corrective Action Plan to help improve performance and resolve any issues identified by the audit findings.
We are in the process of ensuring that any suppliers who are not in the SEDEX system are onboarded in a timely manner. We have 271 suppliers registered and linked within the SEDEX platform who supply to our business. Eighty-four suppliers have completed a SMETA audit within the last two years.
Our people
All our employees undertake right-to-work checks and are required to provide a National Insurance number and their own bank account details. Wages and salaries are paid by bank transfer, and we do not allow payment to be made into third-party bank accounts. All prospective employees participate in a comprehensive interview process. A number of mental health first aiders are trained across the Group to support anyone who may need help and also to help identify symptoms when something may be impacting an individual’s ability to perform at work or their well-being outside of work. We also have an employee assistance programme. We encourage colleagues to speak up and inform their line manager or the People team if they are a victim of Modern Slavery, in which case supportive measures will be put in place. Whistleblowing arrangements are in place for the whole group, with Wagamama employees also having access to an external whistleblowing reporting line.
All employees over 21 are paid at least the National Living Wage, and Wagamama pays all teams the National Living Wage regardless of age. All tips are paid directly, with no deductions for any administration or processing charges. Within Brunning & Price, during peak season we employ a number of agency staff to help support the operations. All of these temporary agency employees are vetted based on our Company criteria, and we ensure the same principles apply as if they were direct TRG employees, namely in terms of applicable policies, equal pay, payment methods and ensuring they are protected under the Modern Slavery Act.
Employees can raise any suspicions they may have from time to time that Modern Slavery or human trafficking may be taking place within the Group or its supply chain and will be protected under our Whistleblowing Policy where those concerns relate to criminal or illegal activity.
Governance
Heads of each relevant business area or function, including brand and divisional managing directors, and the heads of the procurement, legal, property, finance and IT teams have responsibility for their department’s compliance with our Ethical Sourcing Policy and other relevant policies. All key Group policies are approved at Board or senior executive level and are reviewed annually to assess their effectiveness for the future.
Assessment of effectiveness in preventing Modern Slavery
We will continue to keep under review new risks as they emerge and carefully monitor both existing and new suppliers and business activities. We have a robust verification program in place to confirm our suppliers’ compliance with the Modern Slavery Act and TRG policies. We achieve this through regular supplier visits, communications and reviews. We believe in continuous improvement in the prevention of Modern Slavery and we will continue to review our ethical trading programme annually to ensure it reflects best practice.
This statement was approved by the Board of The Restaurant Group plc on 22 April 2024.
Signed by
