Modern Slavery and Human Trafficking Statement 2025/2026
Our modern slavery statement applies to all individuals working for Hill Biscuits Limited or on the Company’s behalf in any capacity including employees, directors, officers, agency workers, contractors, labour providers and recruitment providers.
This statement sets out the steps taken by Hill Biscuits Limited to prevent modern slavery in its business and supply chains.
Introduction
Hill Biscuits Limited continues to have a zero tolerance to modern slavery, and commits to developing and adopting a proactive approach to prevent, respond to and remediate the risks of modern slavery, forced and debt-bonded labour, human trafficking and hidden exploitation within its workplaces.
Modern Slavery is a broad term used to encompass offences that involve one person depriving another person of their liberty, in order to exploit them for personal or commercial gain.
Forced labour is all work or service that is exacted from another person under the menace of any penalty and for which the said person has not offered himself voluntarily.
Debt-bonded labour is where a person’s labour is demanded as a means of repayment for a loan or service.
Human Trafficking is the recruitment of persons by threat, force, coercion or other abuse of power or vulnerability to achieve the consent of a person having control over another person for the purpose of exploitation.
Hidden labour exploitation is action up to and including modern slavery which involves the exploitation of workers and job applicants by internal and external individuals without the sanction or explicit knowledge of the employer or labour provider.
Our Structure and Business
Hill Biscuits Limited, is part of a global label food manufacturer supplying products to large distribution chains and multinationals in the B2B sector. Our business in the UK is based in Ashton-under-Lyne, Manchester employing over approximately 300-350 colleagues, and manufacturing sweet biscuits.
Our Supply Chain
Throughout our supply chain, we are committed to high ethical standards, promoting safe and fair working conditions and responsible management of social issues. We believe we have a responsibility and opportunity to encourage sustainable business practices as well as inclusion and diversity amongst our suppliers. Our supply chains include recruitment providers, labour providers, raw materials and equipment suppliers, contractors and consultants, primarily based in the UK. For the minority of our suppliers that are outside the of the UK, if modern slavery is identified or suspected, then the response will be tailored to the local circumstances, including engaging with local government, law enforcement, non-governmental organisations, industry bodies or trade unions.
Our supplier approval system includes social and environmental criteria; with a Supplier Code of Conduct that all suppliers and contractors must adhere to in order to work with us.
Suppliers are obliged to meet the principles, values and rules defined in this code, in respect to human and labour rights and report any breach as and when detected.
Our Policies
Hill Biscuits Limited are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Modern Slavery Policy (POL 137) reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking is not taking place anywhere in our supply chains. In addition to this, we have a number of appropriate policies such as:
- Ethical Policy
- Freedom of Association Policy
- Human Rights Policy
- Equal Opportunties Policy
- Recruitment (including responsible sourcing) Policy
- Whistle-blowing Policy
- Dignity at Work (Anti-harassment and bullying) Policy
- Grievance Policy
- Corporate Social Responsibilty Policy
- Corporate Criminal Offense Policy
- Risk Management Policy
- Health and Safety Policy
These policies affirm our high ethical standards, promoting safe and fair working conditions and create a platform to encourage staff to report any wrongdoing, which extends to human rights violations such as modern slavery. All reports will be fully investigated, and appropriate remedial actions shall be taken.
Our modern slavery policies meet the following good practices:
- Policies are approved by senior management
- Policies are available to all staff in the organisation and communicated to them
- Relevant staff are trained in these policies
- High risk suppliers are required to adhere to our modern slavery policies
Due diligence process
Within Hill Biscuits Limited, we have robust recruitment processes, which include undertaking document checks on candidates prior to employment to evidence they are allowed to work in the UK, performing appropriate reference checks and ensuring that staff are paid directly into a suitable personal bank account. In relation to our supply chains, we have reviewed our contractual arrangements with current and prospective suppliers to ensure they comply with the Act. This involves placing obligations upon suppliers to conduct modern slavery risk assessments within their own supply chains, implement appropriate controls to prevent modern slavery, and notify our business immediately if any supplier becomes aware of any modern slavery within their supply chains.
Risk assessment and management
At Hill Biscuits Limited, we can confirm 100% of our employees provide their services voluntarily.
All our workers:
- are above the age of 18 years
- are eligible to work in the UK
- sign a contract of employment upon their incorporation into the business and are given a copy
- are paid at least the national minimum wage, and in accordance with collective bargaining agreements, if applicable
- working hours are reviewed to ensure compliance with the working time directive, including respecting rest periods between shifts, per week and vacations
- extra shifts and hours are voluntary and paid with a premium applied
Our strategy for managing risks in relation to modern slavery and human trafficking are achieved through ongoing audit and assessment to identify compliance issues and identify improvements.
Responsibilities for compliance
The Senior Leadership team are responsible for compliance and for supplier relationships. To demonstrate the organisation’s commitment to combat modern slavery and human trafficking in its business and supply chains, we monitor and enforce compliance with our Modern Slavery Policy.
All risks that are identified as extreme or high risk are to be reported to the Managing Director.
Training
To ensure understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have appropriate staff training. All staff receive Stronger Together training as part of their induction – this provides our employees with knowledge on how to identify exploitation and modern slavery as well as the process for reporting suspected cases. During the induction process and throughout employment, training is provided to staff on topics relating to business ethics.
Our effectiveness in combating modern slavery and human trafficking
We understand that modern slavery is not static, and will ensure that our organisation continues its leading approach to mitigating this risk in the year ahead. In order to assess the effectiveness of the measures taken by our organisation, we will continue to review the following key performance indicators:
- Staff training levels, particularly in connection with specific modern slavery training;
- Actions taken to strengthen supply chain auditing and verification;
- Steps taken to raise awareness of modern slavery and human trafficking throughout supply chains; and
- Investigations undertaken into reports of modern slavery and remedial actions taken in response.
We are committed to continual improvement and will take active measures to combat modern slavery and human trafficking in our business and supply chains.
Cerealto UK Managing Director
