GENERAL DATA PROTECTION AND PRIVACY POLICY
Thatchers Cider Company Ltd is committed to ensure that the data we have on our customers and suppliers is private and secure. The General Data Protection Regulation 2016 (GDPR) will enhance the Data Protection Act 1998.
We are aiming to achieve compliance with GDPR by 25th May 2018. Therefore, steps are now being taken to identify what personal data we hold, where it is stored and for what period.
Reviews are also being taken on our processes to ensure that we are compliant and that all data is secure. Any areas within our processes and procedures will be changed in time for the implementation of GDPR.
[THATCHERS HOLDINGS LIMITED]
[THATCHERS CIDER COMPANY LIMITED]
[THATCHERS MYRTLE FARM LIMITED]
MODERN SLAVERY STATEMENT
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps being taken by Thatchers Holdings Limited and its relevant group companies namely Thatchers Cider Company Limited and Thatchers Myrtle Farm Limited (“Thatchers Cider”) during financial year ending 31August 2017 to prevent modern slavery and human trafficking in its business and supply chains.
Introduction
Thatchers Cider is very much aware that modern slavery in all its forms, forced and child labour, servitude, slavery, human trafficking and human exploitation is a growing problem in the world. Thatchers Cider has a zero-tolerance approach to all and any aspect of modern slavery and is in the process of introducing and enforcing both practical steps and administrative policies and procedures with the intention of ensuring that both our own business and that of our suppliers both comply with but also embrace the spirit of the Modern Slavery Act 2015.
Risk Assessment
We have identified that potential areas for modern slavery exist in
– the growing and supply of apples for our juice requirement.
– the growth and supply our requirements for sugar
– the manufacture or supply to us of point of sale materials which includes clothing
– Capital construction projects.
Supply Chain
Thatchers Cider is seeking from each of our suppliers of goods and materials in those sectors written undertakings of compliance with the principles of the Modern Slavery Act 2015, and the gathering of and following up of responses is ongoing.
We are seeking to establish through terms of business with our suppliers, express rights to audit their working practices for compliance, including the working and employment conditions of their workers, and oblige them to step down compliance obligations to their own supply chain.
Within the Thatchers Cider Group itself
A total of approximately 1500 acres of fruit tree orchards in the United Kingdom are owned or farmed under contract by Thatchers Farm Limited. Despite the advent and use of modern mechanical harvesting it is acknowledged that within agriculture as a sector the risk of worker exploitation exists especially through the engagement of seasonal manual workers potentially from overseas.
We have reviewed the sources of farm labour, their working conditions and terms of employment and find no areas of concern which are suggestive of modern slavery or other exploitation in any form.
More widely, Thatchers Cider operates a group wide “whistle blowing” policy which although principally aimed at internal issues has recently been opened to our suppliers with the objective of encouraging the disclosure and resolution of modern slavery practices. The outcomes from this policy will be investigated and appropriate action taken.
Our standard terms of business and long-term contractual agreements are under review with the intention of introducing into them appropriate and relevant terms and conditions to flow down modern slavery compliance, backed up by rights to audit for compliance and require rectification.
In the absence of a dedicated Corporate Governance / Compliance Officer or HR Director, the terms of reference of the Managing Director have been extended to include modern slavery compliance issues. The Managing Director will report to the Board regularly on areas of concern and recommend appropriate action.
Conclusion
At Thatchers Cider we are continually looking for ways and means of improving our product offerings and we intend to bring this drive for perfection to our efforts to eliminate modern slavery practices from our business.
We recognise that we cannot be complacent and that there is more that can be done and as stated above we have a number of ongoing initiatives to complete which we look forward to reporting on in our next statement.
This statement was approved by the boards of directors of Thatchers Holdings Limited and Thatchers Cider Company Limited
Martin Thatcher – Managing Director
November 2017