Modern Slavery Statement

1. Introduction

Our Code of Conduct, which sets out the standards we expect of all staff, makes clear that we support universal human rights. This includes equal employment, freedom of speech, freedom of association, diverse cultural, economic and social well-being. We strongly oppose illegal and inhumane labour practices including slavery, servitude, forced or compulsory labour and human trafficking.

This statement provides an overview of FARMSOC's policies and approach to slavery, servitude forced labour and human trafficking (together referred to as “Modern Day Slavery”) and is complementary to the Company's Code of Business Conduct policy. We realise that our business may be exposed to the potential risk of instances of modern slavery and human trafficking given the location and nature of its operations. FARMSOC takes a zero-tolerance approach to Modern Day Slavery and will work to continually assess the extent of this risk and to take steps to ensure that forced labour have no place in the business or its supply chain.

The Farmsoc is committed to tackling slavery through the risk assessment in our supply chain, due diligence on our suppliers, and awareness-raising activities within the Farmsoc. If you have any queries about this statement or our approach to modern slavery, please contact us via info@farmsoc.africa

Famsoc initiator approves this and signed on behalf of Farmsoc by Adewale Adegoroye, Farmsoc Founder/President.

2. About FARMSOC

Farmsoc is a social enterprise entity that operates several medium-scale farms across Nigeria in response to the nation's need to increase access to fresh & healthy food. Our members put money together for the daily operation of the farms.

We aim to be transparent, professional, democratic, inclusive, passionate, collaborative, innovative, inspiring, fun, pragmatic, promote equality and demonstrate leadership. We also take inspiration from the three ethics of permaculture: care for people, care for the planet and fair shares. Click here to learn more

3. Governance, Policy and Standards

FARMSOC is governed by its Board which guides and approves the Company's strategy and key policies, reviews financial and management performance. Our Board is committed to ensuring that the principles of good governance and Code of Business Conduct are applied in all our Company's dealings.

FARMSOC is committed to respecting and protecting human rights wherever we conduct business. FARMSOC's Code of Business Conduct prohibits the following practices and will not knowingly do business with any individual or company that participates in exploitation of children, including child labour; physical punishment; violence towards employees, specifically when based on gender, origin, religion or sexual orientation; forced or compulsory labour; unlawful discrimination in employment and hiring practices; provision of unsafe working conditions; salary payments (or deductions) that illegally leave the worker below minimum wage; and illegal overtime regulations.

We understand that in our line of business and operations, we establish and interact with suppliers, vendors, agents and third parties who provide us one form of service or the other. These “third parties” may not be subject to any regulation unlike us. It is therefore our duty that we put a mechanism in place to ensure that “third parties” we engage or engaged by FARMSOC, comply with the relevant laws and guidelines applicable to FARMSOC.

3.1 What is Slavery and Human Trafficking?

Slavery: Exercising powers of ownership over a person
Servitude: The obligation to provide services is imposed using coercion or force
Forced or compulsory labour: Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
Human trafficking: Arranging or facilitating the travel of another person with a view to their exploitation

• 3.1.1. Modern Slavery and Human Trafficking legislation in the main covers four activities.
• 3.1.2. This policy covers all four activities.

3.2 How is it relevant to us?

• 3.2.1. Modern slavery is a complex and multi-faceted crime and tackling it requires all of those working for Diversey (us, the company, owe) to play a party. At first glance, this whole subject may appear irrelevant to Diversey, but it is highly relevant, and we must all be vigilant.
• 3.2.2. At a very basic level, preventing the exploitation of people and human trafficking, and protecting our workforce and reputation makes good business sense.
• 3.2.3. Modern Slavery legislation recognizes the important part businesses can and should play in tackling slavery and encourages them to do more.
• 3.2.4. With this in mind, we need to pay particularly close attention to:
  • a). our supply chain
  • b). any outsourced activities, particularly to jurisdictions that may not have adequate safeguards
  • c). cleaning and catering sectors and suppliers
  • d). corporate hospitality

4. Responsibilities

The Farmsoc takes its commitments to preventing modern slavery and protecting human rights very seriously, and has responsibility for producing this statement. The Legal and Compliance, Internal Audit, HR, Procurement and Communications teams, and the Senior Management Group have a particular responsibility for ensuring the Farmsoc and its staff meet these standards. They also ensure our workers are protected, and that risks are identified and appropriately mitigated. All staff throughout our organisation and community at large have responsibility for adhering to the standards set out in this statement.

• 4.1. Diversey, managers and colleagues all have responsibilities to ensure that our fellow workers are safeguarded, treated fairly and with dignity.
• 4.2. Everyone must observe this policy and be aware that turning a blind eye to modern slavery and human trafficking is not acceptable and not an option.
• 4.3. The Company will:
  • a). maintain clear policies and procedures which help to prevent exploitation and human trafficking, both in our organization and in our supply chains, and which protect our workforce and our reputation;
  • b). be clear about our recruitment policy;
  • c). conduct checks within our supply chains and vet new suppliers;
  • d). lead by example by making appropriate checks on all employees, and recruitment agencies, to ensure we know who is working for us and with us;
  • e). ensure we have in place an open and transparent grievance process for all staff and operate a straightforward reporting procedure to deal with any concerns raised;
  • f). seek to raise awareness so that our colleagues know what we are doing to promote their welfare and the welfare of individuals working in our industry;
  • g). make a clear annual statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibility to our employees and our customers seriously
• 4.4 The Managers will:
  • a). listen and be approachable to colleagues;
  • b). respond appropriately if they are told something that might indicate a colleague, or any other person is in an exploitative situation;
  • c). remain alert to indications of slavery (see Identifying Slavery below);
  • d). raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do;
  • e). use their experience and professional judgement to gauge situations and respond appropriately
• 4.5 We all have responsibilities under this policy. Whatever your role or level of seniority, you must:
  • a). keep your eyes and ears open Ð if you suspect someone (a colleague or someone in our supply chain) is being controlled, coerced or forced by someone else to work or provide services, follow our reporting procedure (see Reporting slavery);
  • b). follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated;
  • c). tell us if you think there is more we can do to prevent people from being exploited.

5. The risks

The principal areas of risk we face, related to Modern Slavery and Human Trafficking, include:

• a). supply chains;
• b). recruitment through agencies or any third-party;
• c). general recruitment;
• d). customers engaged in hospitality, cleaning and catering industries.

We will manage these risk areas through our procedures set out in this policy.

6. Our procedures

6.1. Anti-Slavery statement

• 6.1.1. We will make a clear annual statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibilities to our employees, people working within our supply chain and our customers seriously.
• 6.1.2. We make the statement available to everyone on- and off-line
• 6.1.3. Farmsoc's statement will set out the following matters:
  • a). The countries in which it has a presence, the sectors within which it is active and details about our supply chains in such countries
  • b).The action we have taken to ensure that the potential for slavery and human trafficking is significantly reduced both with our suppliers, employees and contractors;
  • c). The key risk areas we face and our approach to avoiding and preventing Modern Slavery and Human Trafficking
• 6.1.4. We will continue to tell the companies we do business with that we are not prepared to accept any form of human exploitation.
• 6.1.5. We will ensure that all our supplier contracts contain anti-slavery and human trafficking clauses. The clauses, which flow down through all layers of our supply chain, will prohibit suppliers and their employees from engaging in slavery or human trafficking.
• 6.1.6. We will ensure that we can account for each step of our supply process, and that we know who is providing goods and services to us and we have mechanisms and processes in place to check, including:
  • a). mapping our suppliers;
  • b). risk assessments for suppliers and questionnaires for new and existing suppliers.

6.2. Recruitment

6.2.1. Using third-party

• a). Our HR departments will follow company policy and only use agreed specified reputable recruitment agencies. We will thoroughly check recruitment agencies before adding them to our list of approved agencies. This includes:
  • i) Conducting background checks and investigating reputation
  • ii) Ensuring the staff provided have the appropriate framework (e.g. work visas)
  • iii) Ensuring the agency provides assurances that the appropriate checks have been made on the person they are supplying
• b) We will conduct regular reviews of all third-party used.

6.2.2. General Open Recruitment

• a). We will ensure all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work.
• b). We will review the names and addresses of our staff, (several people listing the same address may indicate a high shared occupancy, often a factor for those being exploited).
• c). We will provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
• d). If, through our recruitment process, we suspect someone is being exploited, the recruitment team will follow our reporting procedures (See Reporting slavery).

7. Identifying slavery

There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a slavery or trafficking victim:

• a). The person is not in possession of their own passport, identification or travel documents.
• b). The person is acting as though they are being instructed or coached by someone else.
• c). They allow others to speak for them when spoken to directly.
• d). The person is withdrawn, or they appear frightened.
• e). The person does not seem to be able to contact friends or family freely.
• f). The person has limited social interaction or contract with people outside their immediate environment.

8. Reporting slavery

• 8.1. Talking to someone about your concerns may stop someone else from being exploited or abused.
• 8.2. If you think someone is in immediate danger, report to the police immediately.
• 8.3. Otherwise, you should discuss your concerns with your country supply chain leader (found via Workday directory) who will decide on a course of action and provide any further advice or make a report using the Integrity Line
• 8.4. Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with the supply chain leader before taking any further action.

9. Training

We believe it is important to ensure our staff understand the issues of modern slavery and our commitments, as a business, to upholding high ethical standards. Our key personnel regularly attends external events to broaden their knowledge and understanding of modern slavery and use this to raise awareness among key teams across the business.

• 9.1. We provide specialist training to those staff members who are involved in managing recruitment and our supply chains.
• 9.2. More general awareness training is provided to all staff via team leaders or managers and using online training modules.

We understand that modern slavery is not a static issue and therefore we are committed to continuing our efforts to raise awareness of the impact on slavery across the globe. We hold annual internal events to coincide with Anti-Slavery Day to raise awareness among staff, as well as rolling out additional workshops and training, both online and face-to-face. This reinforces our continued commitment to act ethically and to meet our obligations to prevent modern slavery.

All FARMSOC staff undertake an annual Code Certification process following an online training. We also obtain disclosure from staff about their compliance with the Code and its accompanying standards, procedures, and guidelines.

10. Monitoring our procedures

Our goal is not only to ensure the maintenance of our compliance with laws and regulations but also to ensure compliance by our “third parties”. We understand that this is one of the most effective ways of ensuring continuity of business and maintaining integrity of purpose. We have developed the speak-up guidelines with the aim of providing various channels to employees and stakeholders to raise concerns about suspected or actual breaches of our policies and values, as well as other unethical activities and violations of laws and regulations. Our reassurance is that all reports are treated with utmost confidentiality so that such issue or violation is addressed and effectively resolved. We also require all suppliers of goods and services to comply with our Contracting and Procurement principles and ensure compliance by their own suppliers in turn; take special care to comply with standards and procedures in the field of human rights, especially with regard to working conditions for their employees and those of their suppliers and agree to be audited to assess their compliance with these principles for purposes of continuous improvement.

FARMSOC will continue to monitor and manage the risk of servitude to the business and will continue to raise awareness of the issue among staff, suppliers, contractors, partners, and others across all our operations. Any reports of instances of Modern Slavery will be investigated, and appropriate remedial action will be taken. We will review our Anti-slavery policy regularly, at least annually. We will provide information and/or training on any changes we make.