Modern Slavery

Modern Slavery Statement for the year ended 31 December 2021

1: Opening statement from senior management
Wismettac Harro Foods Limited is, and will continue to be, committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chain. As such, we impose the same high standards on our suppliers. We are aware as a business, which is part of a global group, that we have obligations to do what we can to prevent slavery and human trafficking in our supply chains and we take a zero-tolerance approach slavery and human trafficking.
Building on previous years, we continue working together as a group to approach the issue of slavery and human trafficking. We have identified slavery and human trafficking as a key area of importance at group level and we have strengthened our commitment to prevent slavery and human trafficking.
Tackling slavery and human trafficking is a high priority for us and we have put new measures in place to enable us to work towards preventing slavery and human trafficking in our supply chains. Whilst we are proud of the steps we have taken so far, it is our aim as a business to continue to develop our approach and strategy so that we can strengthen how we deal with slavery and human trafficking.
This statement sets out information about our business and supply chain, what steps we have taken to combat modern slavery and what our key priorities will be for the next financial year.

2: Structure of the organisation
Wismettac Harro Foods Limited is a wholesaler and distributor of foods to restaurants and takeaways. Our business primarily supplies Japanese food products and we are in the process of expanding into different food areas. We are part of the Nishimoto Wismettac Group (the ‘Group’), which is a global group of companies operating in the food sector. The Group employs 1,700 employees across the world and we employ around 100 employees.
To find out more about the nature of our business, please click http://harrofoods.com/
In order to supply food products, we work with a range of suppliers both in the United Kingdom and overseas. As is the case for many food suppliers, our supply chains are fluid and many of our suppliers in turn source products from other suppliers. It is our hope that the measures we have put in place and will continue to put in place, will have a positive effect in relation to our supply chains as a whole.
In addition to suppliers of food, we also work with suppliers of goods and services relating to our offices.

3: Our policy
As part of our commitment to combating slavery and human trafficking, we have implemented the Wismettac Harro Foods Anti-Slavery Policy (the ‘Policy’) which ensures that we have effective systems and controls in place to reduce the risk of slavery and human trafficking in our supply chains.
The Policy has been made available to our employees and it forms an important part of the policies we require our employees to be aware of and adhere to.
We also make sure our suppliers are aware of our Policy, and require that they adhere to the same high standards.

4: Preventing modern slavery and human trafficking in our business
In addition to our Policy (which is described above), we have in place procedures to reduce the risk of slavery and human trafficking in our own business. This includes:
a) carrying out checks to make sure that our own employees and workers have the legal right to work in the United Kingdom;
b) ensuring that we engage only with reputable recruitment agencies and requiring them to carry out checks on workers; and
c) encouraging employees and workers to notify management if they have any concerns connected to modern slavery so that we are able to investigate and deal effectively with potential issues.

Supplier questionnaires
We developed a supplier questionnaire in 2021 and achieved over 80% participation in the first year, exceeding our initial target of 50%. For our new suppliers, we ask that a questionnaire is completed.
The purpose of the questionnaire is to help us to establish what systems and controls suppliers have in place to prevent slavery and human trafficking in their businesses and their own supply chains which enables us to assess if there is a risk of slavery and human trafficking.
Assessing risk in this way is critical to addressing slavery and human trafficking as it gives us greater visibility over our supply chains and enables us to decide on a case by case basis whether putting particular measures in place for individual suppliers is justified and whether there are reasons why we should not deal with a supplier.

Sedex
We are a member of Sedex, which is an online platform designed to improve conditions in supply chains. It is our endeavour to utilise the Sedex platform to promote transparency about our company and suppliers.

6: Risk and compliance
Wismettac Harro Foods Limited regularly evaluates the nature and extent of its exposure to the risk of slavery and human trafficking occurring in our supply chain. We intend to continue strengthening our approach over the coming financial year by considering whether circumstances warrant us carrying out audits of suppliers for their compliance with our Policy.
We also intend to assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts. Using our risked-based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Policy, which sets out the minimum standards required to combat slavery and trafficking.
We ensure all our suppliers adhere to our Policy. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find evidence of a failure to comply with our Policy we will immediately seek to help them identify areas for improvement within a defined timeframe.

7: Effectiveness and KPIs
Wismettac Harro Foods Limited uses key performance indicators (KPIs) to measure how successful we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains. In 2021, we implemented and achieved the following:
• Modern slavery and human trafficking awareness training for all staff; and
• Over 80% participation rate for our supplier questionnaire.
In 2022, we intend to continue and refresh awareness training for staff; and review and survey our suppliers again to track progress.

8: Training
We have developed a training programme which aims to educate our staff to recognise the risks of
modern slavery and human trafficking in our business and supply chains. Through our training
programmes, employees are encouraged to identify and report any potential breaches of our Policy.
Employees are also taught the benefits of stringent measures to tackle slavery and human
trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our
business and supply chains.
We started the training programme early in early 2021 and we intend to continue it in 2022.

9: Further actions and sign-off
Following our review of our actions this financial year to prevent slavery or human trafficking from
occurring in our business or supply chains, we intend to take the following further steps to tackle
slavery and human trafficking:
(a) continue our employee training programme; and
(b) continue to work together with other companies in the Group to tackle modern slavery.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Wismettac Harro Foods Limited's slavery and human trafficking statement for the financial year ending 31 December 2021

This statement was approved by the board of directors on 22 March 2022.

Kazunori Hayashi, Managing Director
Wismettac Harro Foods Limited
Date: 22 March 2022

Modern Slavery Statement for the year ended 31 December 2020

1: Opening statement from senior management
Wismettac Harro Foods Limited is, and will continue to be, committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chain. As such, we impose the same high standards on our suppliers. We are aware as a business, which is part of a global group, that we have obligations to do what we can to prevent slavery and human trafficking in our supply chains and we take a zero-tolerance approach slavery and human trafficking.
Since our previous financial year, we have undergone some changes to our group structure and, following this, we are now working together as a group to approach the issue of slavery and human trafficking. We have identified slavery and human trafficking as a key area of importance at group level and we have strengthened our commitment to prevent slavery and human trafficking.
Tackling slavery and human trafficking is a high priority for us and we have put new measures in place to enable us to work towards preventing slavery and human trafficking in our supply chains. Whilst we are proud of the steps we have taken so far, it is our aim as a business to continue to develop our approach and strategy so that we can strengthen how we deal with slavery and human trafficking.
This statement sets out information about our business and supply chain, what steps we have taken to combat modern slavery and what our key priorities will be for the next financial year.

3: Our policy
As part of our commitment to combating slavery and human trafficking, we have implemented the Wismettac Harro Foods Anti-Slavery Policy (the ‘Policy’) which ensures that we have effective systems and controls in place to reduce the risk of slavery and human trafficking in our supply chains.
The Policy has been made available to our employees and it forms an important part of the policies we require our employees to be aware of and adhere to.
We also make sure our suppliers are aware of our Policy, and require that they adhere to the same high standards.

5: Due diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted due diligence procedures that are designed to:
• establish and assess areas of potential risk in our business and supply chains;
• monitor potential risk areas in our business and supply chains;
• reduce the risk of slavery and human trafficking occurring in our business and supply chains; and
• provide adequate protection for whistleblowers.

Supplier questionnaires
We are in the process of developing a supplier questionnaire. For both our existing and new suppliers, we will ask that a questionnaire is completed. The purpose of the questionnaire is to help us to establish what systems and controls suppliers have in place to prevent slavery and human trafficking in their businesses and their own supply chains which will enable us to assess if there is a risk of slavery and human trafficking.
Assessing risk in this way is critical to addressing slavery and human trafficking as it will give us greater visibility over our supply chains and to enable us to decide on a case by case basis whether putting particular measures in place for individual suppliers is justified and whether there are reasons why we should not deal with a supplier.

Sedex
We are a member of Sedex, which is an online platform designed to improve conditions in supply chains. It is our intention to utilise the Sedex platform to promote transparency about our company and suppliers.

6: Risk and compliance
Wismettac Harro Foods Limited regularly evaluates the nature and extent of its exposure to the risk of slavery and human trafficking occurring in our supply chain. It is our intention to strengthen our approach over the coming financial year by considering whether circumstances warrant us carrying out audits of suppliers for their compliance with our Policy.
We also intend to assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts. Using our risked-based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Policy, which sets out the minimum standards required to combat slavery and trafficking.
We ensure all our suppliers adhere to our Policy. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find evidence of a failure to comply with our Policy we will immediately seek to help them identify areas for improvement within a defined timeframe.

7: Effectiveness and KPIs
Wismettac Harro Foods Limited uses key performance indicators (KPIs) to measure how successful we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains. For the financial year ended 31 December 2021, these are as follows:
• we will provide modern slavery and human trafficking awareness training for all staff; and
• we will require at least 50% of our suppliers to complete questionnaires.

8: Training
We have developed a training programme which aims to educate our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees will be encouraged to identify and report any potential breaches of our Policy. Employees will also be taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our
business and supply chains.
We intend to commence the training programme early in early 2021.

9: Further actions and sign-off
Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking:
(a) implement our employee training programme; and
(b) continue to work together with other companies in the Group to tackle modern slavery.

This statement was approved by the board of directors on 10 January 2021.

Kazunori Hayashi, Managing Director
Wismettac Harro Foods Limited
Date: 10 January 2021

Modern Slavery Statement for the year ended 31 December 2019

1: Opening statement from senior management
Wismettac Harro Foods Limited has recently undergone major changes to our group structure. These changes were a strategic priority for us during the financial year to which this statement relates and, as a result, our focus as a business has been to implement the changes. As a result of these changes, we are now in a position to prioritise addressing modern slavery and human trafficking within our supply chains and to build upon the steps we have already taken. It is our intention to continue to strengthen our efforts towards tackling slavery and human trafficking and this will be reflected in our next annual statement.

2: Structure of the organisation
Wismettac Harro Foods Limited is a wholesaler and distributor of foods to restaurants and takeaways. Our business primarily supplies Japanese food products and we are in the process of expanding into different food areas. We are part of the Nishimoto Wismettac Group (the ‘Group’), which is a global group of companies operating in the food sector. The Group employs 1,700 employees across the world and we employ around 100 employees.
To find out more about the nature of our business, please click http://harrofoods.com/.
In order to supply food products, we work with a range of suppliers both in the United Kingdom and overseas. As is the case for many food suppliers, our supply chains are fluid and many of our suppliers in turn source products from other suppliers.
In addition to suppliers of food, we also work with suppliers of goods and services relating to our offices.
3: Preventing modern slavery and human trafficking in our business
We have in place procedures to reduce the risk of slavery and human trafficking in our own business. This includes:
a) carrying out checks to make sure that our own employees and workers have the legal right to work in the United Kingdom; and
b) ensuring that we engage only with reputable recruitment agencies and requiring them to carry out checks on workers.

This statement was approved by the Board on 10 January 2021.

Kazunori Hayashi, Managing Director
Wismettac Harro Foods Limited
Date: 10 January 2021