1. Introduction

Caper & Berry is committed to preventing modern slavery and human trafficking in our business and supply chains. Everyone has the right to work freely, be treated with dignity and receive the pay and protections to which they are entitled.

Modern slavery includes slavery, servitude and forced or compulsory labour. Human trafficking involves arranging or facilitating a person’s travel with a view to exploiting them. Exploitation can occur without someone crossing an international border.

This policy sets out our ongoing commitments, responsibilities and procedures. It applies to all employees, workers, managers and relevant contractors, agency workers, suppliers and others working for or with Caper & Berry. It supports our Equity, Diversity & Inclusion Policy and our wider principles of justice, equity, diversity and inclusion (JEDI).

2. Organisational Structure & Supply Chains

Caper & Berry is an event caterer working across London and the South East, collaborating with corporate and private clients, as well as event planners and agencies. The company operates in the UK and is based in Eashing, near Godalming. We directly employ many permanent and casual staff to support our events and operations.

Our direct suppliers mainly provide agency staffing, food and equipment. Our assessment also considers risks further down the supply chain, including the suppliers and subcontractors used by our direct suppliers. Operating solely in the UK does not remove the need to consider the origins of products or how workers are recruited.

3. Due Diligence Processes for Slavery & Human Trafficking

For staff we employ directly, including casual staff, we complete all required right-to-work checks before employment begins. Our process includes physical identity checks and the applicable right-to-work verification method. We pay wages only into a bank account held in the worker’s own name, rather than an account belonging to another person. These safeguards support our efforts to prevent exploitation and sit alongside our wider recruitment, reporting and employment practices.

We undertake due diligence when considering new suppliers and reviewing existing suppliers. The level of assessment will reflect the nature of the goods or services, recruitment arrangements and identified risks. We will:

• Assess each new supplier’s modern slavery risks and request its modern slavery policy or statement where available. Where no statement is available, request proportionate evidence of the safeguards it uses to prevent exploitation.
• Assess suppliers on their practices and supporting evidence. The absence of a published statement alone will not automatically exclude a smaller supplier that is not required to publish one.
• Check that staffing agencies carry out appropriate right-to-work checks and comply with applicable employment law, including minimum wage requirements. These checks form part of our assessment and do not, by themselves, establish that workers are free from exploitation.
• Ask about recruitment fees charged to workers, withholding of identity documents or wages, coercion, restrictions on leaving employment and the use of subcontractors. Review how workers can raise concerns safely.
• Use the company’s modern slavery questionnaire and supporting information to assess suppliers, with particular attention to higher-risk arrangements and the safeguards suppliers apply in their own supply chains.
• Build long-standing relationships with suppliers and communicate our expectations for fair treatment, lawful employment and cooperation in addressing concerns.

Where shortcomings are identified, the Head of Finance will coordinate a proportionate response with relevant managers and the Company Director. This may include further enquiries, a corrective action plan with timescales, additional monitoring, suspension or termination of the business relationship. Serious concerns may require immediate escalation rather than waiting for an action plan. Decisions will consider the safety and welfare of affected workers and the potential consequences of withdrawing from a supplier.

4. Monitoring & Performance Indicators

The Head of Finance will monitor the following indicators and report findings to the Company Director at least annually:

• The number and proportion of staff in designated roles who have completed the required annual training.
• The number and proportion of new suppliers assessed before engagement, and existing suppliers reviewed in line with their assessed risk.
• The number of suppliers with outstanding corrective actions, including overdue actions, and the time taken to resolve them.
• The time taken to acknowledge and assess reported concerns and progress agreed follow-up actions.
• Feedback on whether workers understand the policy, can access reporting routes and feel able to raise concerns safely.

Records will distinguish completed activities from planned improvements. Findings will inform risk assessments, training and supplier reviews. A low number of reports will not automatically be treated as evidence that exploitation is absent; it may also indicate barriers to reporting.

5. Training & Awareness

Employees responsible for recruitment, purchasing, supplier management or responding to concerns, and relevant managers, must complete modern slavery training annually. The Head of Finance will identify the roles requiring training and maintain completion records.

Everyone working for or with Caper & Berry will be given relevant information about this policy and how to raise concerns. Managers will ensure that agency workers and contractors can access the reporting information relevant to their work.

Training and reporting information will be provided in accessible formats. We will consider alternative delivery methods, language support and reasonable adjustments where needed. Managers or HR can help arrange support.

6. Risk Assessment & Responsibilities

Our risk assessments give particular attention to agency recruitment, subcontracted kitchen support and cleaning services, and suppliers further down our supply chain where we have less visibility of recruitment and working conditions. Risk relates to working and recruitment arrangements, rather than a person’s job title, nationality or background.

Potential warning signs include workers appearing unable to leave employment freely, withheld wages or identity documents, recruitment debts, threats, or another person controlling their communication or movements. These signs should prompt sensitive assessment; they are not proof of exploitation on their own.

• The Company Director has overall responsibility for endorsing this policy, supporting its implementation and reviewing significant concerns.
• The Head of Finance is responsible for developing and reviewing the policy, coordinating risk assessments and supplier due diligence, maintaining relevant records and monitoring corrective actions.
• Managers and employees responsible for recruitment or purchasing must apply the relevant checks and escalate concerns. Enquiries and investigations must be handled by designated staff with appropriate training and, where necessary, specialist advice.
• All employees and workers are responsible for reporting known or suspected concerns. They are not expected to investigate, obtain proof or confront anyone suspected of exploitation.

7. Reporting Concerns & Responding Safely

Anyone working for or with Caper & Berry may raise a concern or seek help, including someone who believes they are experiencing exploitation. You do not need proof before reporting.

You can speak to your manager, HR or Corrina Wilson, Head of Finance. If your concern involves one of these people, or you do not feel comfortable speaking to them, contact another of these contacts or the Company Director. You may also use the external reporting routes below without first reporting internally.

Concerns may be raised verbally or in writing. If language, literacy, disability or another communication need makes reporting difficult, ask a trusted contact, manager or HR for help using an accessible method. Where interpretation is needed, we will seek independent support rather than rely on someone who may be involved in the concern.

Reports will be taken seriously and handled sensitively. Information will be shared only where necessary to assess the concern, protect people or meet legal obligations. We cannot promise absolute confidentiality where information needs to be shared for these purposes.

Anyone raising a genuine concern, assisting with an enquiry or seeking help will be protected from retaliation or detrimental treatment, even where the concern is not substantiated. Any suspected retaliation should be reported through the same routes.

The Head of Finance, or an alternative designated lead if the concern involves them, will coordinate the response. The immediate priority is the safety of affected people. We will consider their needs and wishes, seek specialist advice where appropriate, record actions securely and provide updates where it is safe and appropriate to do so.

Do not confront a suspected exploiter or take action that could put yourself or another person at risk. If someone is in immediate danger, call 999.

For confidential information, advice or to report a concern, contact the Modern Slavery & Exploitation Helpline on 08000 121 700 or visit www.modernslaveryhelpline.org. Its online reporting form is in English; if you need an interpreter, telephone the helpline.