Modern slavery statement

Modern slavery statement for financial year 2023


This statement sets out the actions of Zorba Delicacies (the Company) to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year [01 January 2023 to 31 December 2023].

The Organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking,

The Organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a xero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, agency workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

Organisational structure and supply chains

This statement covers the activities of the Company:

Zorba Delicacies Ltd is a manufacturer of fresh, ready to eat dips, deli fillers and soups, based in South Wales. We supply to some of the biggest grocery retailers and food service providers.

Countries of operation and supply

The Organisation currently operates in the following countries:

  • United Kingdom — we have a site based within the Rassau Ebbw Vale. We employ approximately 450 employees, and we manufacturer all products at this

The following is the process by which the Organisation assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
Our high risk areas are labour and supply chain. We have a robust system of policies and procedures to check all right to work documentation of new starters and we regularly review (GLA) certificates. We have a dedicated point of contact on site for any concerns regarding Modern Slavery. Confidential helpline numbers are advertised around site and accessible to all employees.

Our supply chain only uses approved suppliers and we have due diligence policies to ensure our suppliers conform to Modern Slavery Act standards.

High-risk activities

The following activities are considered to be at high risk of slavery or human trafficking:

  • Labour – recruitment and selection and the use of temporary labour suppliers
  • Supply Chain — purchasing ingredients and materials


In order to fulfil its obligations regarding anti-slavery initiatives, the Company uses:

  • Policies: The senior management team is responsible for implementing all policies relating to human rights and modern slavery at Zorba Delicacies Limited. These are reviewed annually to ensure legal compliance and best practices standards are achieved, and the policy remains effective.
  • Risk assessments: The business completes checks on suppliers who are members of SEDEX, and/ or any other relevant ethical trading Copies of the ethical trading policies are requested and reviewed, and audits completed. The results of the audit are discussed and reviewed at the annual HACCP meeting, however, any concerns which are identified are actioned immediately in accordance with the Company’s policies and procedures, and legal compliance.
  • Investigations/due diligence: In the first instance the HR department is responsible for actioning any investigations in relation to known or suspected instances of slavery and human trafficking, and they will appoint an appropriate manager to support the investigation Both parties will act as impartial investigators to determine the facts in relation to the allegations, and ensure that a thorough investigation is completed. Any breaches will be escalated and manage in accordance with the Company’s policies and procedures, and will be reported in accordance with UK law.
  • Training: We are committed to providing regular training to our HR and Supply Chain teams to ensure that they understand Human Rights and the signs of Modern Slavery, and what to do if they suspect a breach of this policy or any associated policies and procedures.

Relevant policies

The Organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy The Organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form. There is a post box located in the locker area, by the canteen in Unit 13. This is checked once per week by the Human Resources Department.
  • Employee code of conduct The Organisation’s code makes clear to employees the actions and behaviour expected of them when representing the Organisation. The Organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its suppJy
  • Ethical Trading Policy The Organisation is committed to ensuring that its suppliers adhere to the highest standards of Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Organisation works with suppliers to ensure that they meet the standards of the policy and improve their worker’s working conditions. However, serious violations of the Organisation’s Ethical Trading Policy will lead to the termination of the business relationship. The Ethical Trading Policy is issued to all new and existing supplier. Regular customer audits are completed by our Technical and Supply Chain teams.
  • Recruitment Policy The Organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that Prior to engagement with an agencywho will be responsible for supplying labour, the Organisation will ensure that they hold a GLA Certificate. Booking forms, detailing the agreed terms of the role, are agreed for each new job role, and comparable to full time employees, before or on achievement of 12 weeks’ continuous service.
  • Equal Opportunities Policy The Organisation ensures that the policy is applied throughout the business, and ensure fairness and consistency to all employees.

Due diligence

The Organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Organisation’s due diligence and reviews include:

  • mapping the supply chain broadly to assess particular products or geographical risks of modern slavery and human trafficking;
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits or assessments through the Organisation’s own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • using SEDEX registration, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship. Sanctions could include revoking ol orders until the improvement standards are met, a fixed penalty or termination of the business relationship for serious breaches or failure to meet the required standard, after such improvements have been identified and notices for improvement served.

Performance indicators

The Organisation has reviewed its key performance indicators (KPIs). As a result, the Organisation is:

  • requiring staff working in supply chain, managers and HR professionals to have completed training on modern slavery by March
  • developing a system for supply chain verification expected to be in place by March 2024, whereby the Organisation evaluates potential suppliers before they enter the supply chain; and
  • reviewing its existing supply chains expected to be completed by March 2024, whereby the Organisation evaluates all existing suppliers.


The Organisation requires staff working in supply chain, managers and HR professionals within the Organisation to complete training on modern slavery.

The Organisation requires staff working in supply chain, managers and HR professionals to complete at least one training session which is being run during the year and this should be completed by March 2024.

The Organisation’s modern slavery training covers:

  • our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the Organisation;
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • what steps the Organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Organisation’s supply chains.

Awareness-raising programme

As well as training staff, the Organisation has raised awareness of modern slavery issues by distributing putting up posters across the Organisations premises.

The posters explain to staff:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Organisation; and
  • what external help is available, for example through the Modern Slavery