Principle

There should be policies and procedures that define worker welfare standards for the manufacturing organisation. These policies and procedures should be appropriate to the tasks undertaken, and reflect the requirements of legislation in the country where manufacture takes place and the requirements of supply chain standards where these are higher and a prerequisite to supply. Worker welfare standards where these relate to the working environment, welfare facilities, good housekeeping and physical safety are all key elements of good manufacturing practice (GMP).

Introduction

18.1 The term ‘worker welfare’ describes the actions taken by a manufacturing organisation to ensure the wellbeing of those who are employed by them and their wider supply base. As described in Chapter 17, the physical health of employees, especially if they suffering from or are a carrier of any potential disease or infection which could via their work activities contaminate other staff or the food product itself, is a key concern that is addressed by GMP (see 17.21 and 17.22). Personal occupational health and safety issues are considered in Chapter 42 of this Guide and again fall within the context of worker welfare. However, worker welfare as an issue extends beyond these two aspects to a far wider scope. Ethical trade standards focus on the protection of workers’ health, safety and rights throughout the supply chain and how they are impacted by the contractual interaction of organisations in the supply chain.

Ethical standards can be of two types: business‐to‐business (B2B), where there is a requirement for a manufacturing organisation to demonstrate that it meets minimum contractual requirements for workers’ health, safety and rights, and business‐to‐consumer (B2C), where the compliance of organisations in the supply chain to ethical standards is communicated to the consumer via labelling of specific products, for example Fairtrade bananas, coffee or chocolate and so on. In terms of GMP it is important for the manufacturer to consider whether there is a contractual requirement to meet legislative requirements alone in terms of worker conditions or whether their customers require them to comply with additional market standards that could be B2B or B2C in orientation.

Business‐to‐Business Ethical Standards

18.2 It may be a requirement of retail or food service customers that as a prerequisite to supply that the manufacturer demonstrates that they comply with a B2B standard such as the Ethical Trading Initiative (ETI) Base Code,¹ SA 8000:2014 or another second‐ or third‐party standard. The ETI Base Code is based on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of practice. Social Accountability International SA 8000:2014² is a standard also based on the conventions of the ILO and the Universal Declaration of Human Rights, and has a series of system standards that organisations are required to meet in order to gain certification.

18.3 It is best practice for manufacturers, where ethical trading is a market requirement, to ensure that their suppliers comply with sustainable sourcing policies as well as the relevant ethical trading standard(s). It may also be a supply chain requirement for a manufacturer to be a member of the Supplier Ethical Data Exchange (Sedex) as well as having a formal Sedex Members Ethical Trade Audit (SMETA).

Business‐to‐Consumer Ethical Standards

18.4 A manufacturer may be required to comply with specific retailer or food service organisation standards for ethical trading where these are then communicated directly to the consumer in terms of labelling on the product. Where claims are made on packaging, the onus is on the manufacturer to demonstrate that the product and the ingredients used to make the product can be traceable to source. The Fairtrade claim, however, may only relate to one ingredient in a composite product and it is important that for those products traceability is assured.

Modern Slavery

18.5 In the United Kingdom (UK), the Modern Slavery Act 2015 applies to public and private companies if they have a global net turnover of over £36 million and the company carries on all or any part of its business in the UK. Companies who meet this criterion have an obligation to publish a slavery and human trafficking statement every year, six months after the end of the company’s financial year. Whilst this may seem from the turnover figure identified to be of interest only to large manufacturing organisations, there is a requirement for large organisations to include information in their review on how the supply chains they interact with meet this requirement too. The Stronger Together Initiative³ is a multi‐stakeholder approach aiming to address modern slavery and human trafficking and provides resources and information for manufacturers who are required to demonstrate that they have considered modern slavery and human trafficking in their own business and their wider supply chain. The resources available include risk screening tools and templates for documents and policies.

Gangmaster and Labour Abuse Authority

18.6 In collaboration with other agencies, e.g. HM Revenue and Customs, the Gangmasters and Labour Abuse Authority (GLAA) investigates labour exploitation concerns in the UK and is responsible for regulating the activities of gangmaster, employment agencies and labour providers in the agriculture, horticulture, shellfish gathering, and food and drink processing and packaging sectors. A labour provider must have a GLAA licence to provide labour in these areas of employment.

Agency Staff

18.7 The employment of agency staff should be in compliance with the legal requirements operating in the country where the manufacturing site is situated. In the UK, employment agencies that operate in food processing must hold valid GLAA approval. The onus is on the manufacturer to check at routine intervals that the agencies’ approval has not been revoked. In order to manage this effectively, a formal procedure should be in place with responsibilities defined as to who will coordinate and implement the procedure and, if required, appropriate corrective action.