Modern Slavery Policy and Human Trafficking Statement

Pacific Produce ltd is committed to the detection and prevention of modern slavery and 
human trafficking within the company’s activities, service providers and supply chain. The 
following statement has been issued in accordance with the UK Modern Slavery Act 2015. 
Pacific Produce believes everyone should be entitled to a safe workplace, fair employment 
and equality. We expect these values to be shared with our partners and suppliers. 

Pacific Produce ltd Structure 
Pacific Produce Ltd is an importer of fresh produce, primarily exotic and citrus fruit. The 
company was founded in 2010 in conjunction with a partner group in Peru to manage their 
European operations. The company now works with a number of growing sources globally, 
offering various routes to retail, food service and wholesale outlets within the UK and 
European continent. Pacific Produce ltd has one central office located in Thame, 
Oxfordshire. Pacific Produce consists of 16 permanent staff members. 

Policies and Procedures 
We have established the following policies and procedures within our own activities to 
monitor and identify potential modern slavery: 
 Pacific Produce employment and management obligations  
 Observance of the ETI base code  
 Pacific Produce employs staff directly (not via agency model) with individual 
contractual agreements  
 Staff awareness – training and subscription to the “stronger together” organisation.  
These policies and procedures are reviewed where necessary to improve our controls in line 
with current regulations and developments. 
We also hope with these policies and procedures we can raise awareness of modern slavery 
internally and externally and make a difference. 

Risk Assessment within the Supply Chain 
Although Pacific Produce sources produce from a number of high‐risk rated countries, we 
have not encountered any instances of modern slavery. However, we are aware there can 
be circumstances where these sources do not always meet all the requirements of the 
Ethical Trade Initiative base code, even though they adhere to local regulations and laws. 
Pacific Produce has built strong relationships within the supply base and has therefore 
developed a strong knowledge of how suppliers operate their businesses. Pacific Produce 
are committed to only working with those suppliers and partners that share the same 
values.  
Pacific Produce Ltd is an AB member of sedex. Sedex (supplier ethical data exchange) is 
widely used by the industry to capture information concerning ethical standards from 
individual businesses, either by the means of self‐assessment or third‐party auditing (smeta 
standard). This tool allows us to link to our suppliers and continually monitor ethical 
compliance, including modern slavery. The sedex risk assessment tool identifies areas of 
concern from the data and allows us to target these areas more accurately and take 
necessary actions. 
Modern slavery is also a part of our own due diligence controls. Despite long relationships 
with suppliers and service providers, we remain alert to potential developing risks, 
especially from external factors that could influence standard practices, such as migration. 
All suppliers and service providers are required and expected to monitor their own 
businesses and suppliers and warrant that measures are in place to prevent such 
occurrences as a part of our supplier approval pack. In addition to sedex, regular supplier 
visits (1st, 2nd party) will also include monitoring of such activities. 
Pacific Produce collaborates with the customer base within the UK to share knowledge and 
combat social and ethical concerns from an industry wide supply perspective. the shared 
information helps us identify common concerns and allows us to target them specifically to 
offer support and potential solutions.  
Pacific Produce also considers feedback from the supply base just as important. Constant 
communication with the suppliers is vital to understand how occurrences may arise and 
develop within the industry.  

2021 Summary 
2021 was the second Year of the covid‐19 pandemic. Again, increasing difficulties at all 
stages of the supply chain; reducing our capacity to visit suppliers, reduced worker numbers 
permitted within sites (production couldn’t meet demand). Covid‐19 proximity rules lead to 
increased sick leave levels (self isolation) reducing worker availability and possible financial 
burden for the individual workers, especially where government funding incentives were 
not available. 
This had a knock‐on effect through the supply chain, from packaging manufacturers to final 
shipping to the customer. 
On the positive side, there was a surge in supplier approval technology. This introduced new 
and easier methods of communication and capturing data online. This technology will now 
act as a significant supplement to “traditional” supplier approval which can accumulate and 
share relevant data and trends with greater ease and transparency.

2020 Target Results 
 Key staff from Pacific Produce to attend an industry related course relating to 
modern day slavery with the aim to gain a better understanding, improve current 
controls and raise awareness within the company and supply base. 
one staff member attended the “Stronger Together” UK business and supply 
chain courses in September 2019.  
 Pacific Produce staff to complete “stronger together” E‐learning training on tackling 
modern day slavery in businesses 
One staff member completed the E‐learning training (8%) 
 All farms to be registered on sedex and linked to Pacific Produce with at least the 
self‐assessment completed to 100% 
100% core farms are now registered on sedex. 94% of sites with 100% SAQ 
completion 
 Only permit packhouses from the high‐risk sources which conduct annual third‐party 
ethical compliance audits. Preferably the sedex “smeta” audit, but an industry 
recognised equivalent in line with our customers’ expectations is also acceptable.  
91% packhouses conducted a smeta audit within past 24 months 

2021 Target results 
 All sites supplying Pacific Produce to be registered on sedex and complete the self‐
assessment (SAQ) to 100%  
100% sites registered on sedex with SAQ completed to 100% 
 All programmed farms supplying Pacific Produce to be audited against at least one of 
the following ethical / sustainable standards: Grasp, Smeta, Rainforest Alliance, Fair 
Trade  
99.4% of farms have completed one of the recognised audits within past 12 months 
 All core packhouses from recognised high risk Countries to have an industry 
recognised 3rd party “ethical” audit. Preferably smeta, which gives full visibility 
through the supply chain. 
85% have smeta / siza audit 
7.5% have fair trade / rainforest alliance  
5% have grasp audit 
2.5% don’t have a 3rd party ethical audit  
 50% of staff from Pacific Produce to have completed “Stronger Together” e‐learning 
on tackling modern slavery in business. 
27% of staff have completed the course 
 Allocate extra resource to monitor supplier performance within the supply chain  
Due to restrictions, extra worker resources were not possible. 
2022 Targets 
 Maintain sedex SAQ completion at 100% of sites 
 Sedex SAQs to be reviewed at least annually  
 100% programmed farms supplying Pacific Produce to be audited against at least 
one of the following ethical / sustainable standards: Grasp, Smeta, Rainforest 
Alliance, Fair Trade  
 100% core packhouses from recognised high risk Countries to have an industry 
recognised 3rd party “ethical” audit. Preferably smeta, which gives full visibility 
through the supply chain. 
 All non conformances from site smeta audits to be verified and closed. 
 100% of staff from Pacific Produce to have completed “Stronger Together” e‐
learning on tackling modern slavery in business. 
In addition to the above, we are always open to cooperative opportunities to work with 
specialist companies at source and encourage our suppliers to attend training / seminars. 
We are also open to collaborate with likeminded UK based companies within the same 
industry to develop presentations and material that could be distributed to our suppliers to 
raise awareness within their businesses and supply chain even further. 
Following the development of the Russian and Ukrainian conflict, we are aware the 
displacement of Ukrainian nationals gives opportunity of criminal activity relating to modern 
slavery and human trafficking. Pacific Produce as a company only employs permanent staff 
directly, but as a precaution, we are insisting our partners and suppliers make extra efforts 
to identify potential exploitation of Ukrainian nationals through their recruitment / 
contracting of workforce. 
This statement has been prepared in accordance with the UK Modern Slavery Act 2015 and has been 
approved by the Pacific Produce ltd Managing Director  

Robert Cullum 

Managing Director – Pacific Produce ltd

References / resources  
Modern slavery act: MODERN SLAVERY ACT - Search - GOV.UK (www.gov.uk)
ETI base code: www.ethicaltrade.org/resources/eti‐base‐code  
Stronger together: www.stronger2gether.org/  
Sedex: www.sedexglobal.com/