As a responsible food producer Kavli recognises its responsibility to deliver safe food.

Product quality and food safety have very high priority throughout our organization, and we are continually seeking to improve our standards further.

We maintain the same product quality and safety standards regardless of where the product is produced or sold and we place great demands on our production sites to ensure they employ quality and food safety standards to the requirements of the Global Food Safety Initiative.

HACCP (Hazard Analysis Critical Control Point)

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Kavli is committed to ensuring that our products are safe throughout the whole food chain – from raw materials to finished products. To ensure this is done, we employ risk assessments based on HACCP (Hazard Analysis Critical Control Point) principles as the basis for all product manufacture and supply.

HACCP is a method of risk assessment aimed to identify hazards potential in production process in order that they can be prevented, eliminated or reduced to an acceptable level.

Kavli use the HACCP (Hazard Analysis Critical Control Point) food safety management system to maintain product safety. This management system is a globally recognised method of risk assessment, aimed at identifying potential hazards in the production process so that they can be prevented, eliminated or reduced to an acceptable level.

Kavli use multidisciplinary teams to create, approve and implement procedures for quality control and risk assessment based on these HACCP principles. These routines apply from supply and storage of raw materials through manufacturing, distribution of finished products and traded goods

Allergens

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Some foods and ingredients can be allergenic. Wherever possible Kavli will avoid using ingredients known to be associated with allergenic reactions in consumers.

Kavli wants as many people as possible to be able to consume our products. At the same time, we know that some people can adversely react to certain ingredients used in food production. These ingredients are called allergens and Kavli seeks to avoid using known allergens where there are suitable alternatives.

This includes all food products produced or supplied by Kavli, as finished packaged products merchandised commodities.

All Kavli businesses have in place procedures for allergen management to be able to control the risks associated with allergy-causing substances and all Kavli products that contain allergens will be clearly and accurately labelled in compliance with regulatory requirements.

Food fraud

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Kavli is committed to protecting the consumer from counterfeit commodities and food and has therefore incorporated practices and procedures to ensure that that fraudulent activity is prevented in its supply chain.

Food can be the effect of unethical actions or false representation with the purpose of financial gain. This may however pose a threat to consumers and a business’s viability.

As a leading manufacturer of food products Kavli is a commitment to producing safe, legal and healthy products that match or exceed the customers ‘ expectations of quality.

Kavli therefore conduct risk assessments in relation to the threats and vulnerabilities within our supply chain to ensure that our products and consumers ae protected. Kavli to do this, by making sure that all supplies of the raw material are sufficiently audited and tested for potentially fraudulent actions, such as the deliberate substitution, dilution, addition or misrepresentation of materials.

Kavli also ensure that its facilities, processes and distribution chain is designed and maintained in such a way that prevents the intentional addition of counterfeit materials in our products or merchandise.

Foreign objects

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Kavli employs current best practice routines and equipment to detect any potential foreign materials from contaminating our products.

Raw material quality and packaging material.

Product quality is dependent upon the quality of raw materials, processing and packaging. Kavli has established procedures for the approval of the suppliers and the receiving control of raw materials and packaging to ensure the best possible standards are maintained.

All Kavli businesses employ equipment and routines to prevent, identify and detect foreign objects in products so that end users are not exposed to the risk of injury from foreign bodies in our products.

The selection of equipment to detect possible foreign objects is done on a product risk basis that considers the nature of the product and the process of manufacture.

All such equipment undergoes a documented approval processes to ensure that it is fit for purpose.

Emergency preparedness

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Kavli has established defined routines that should will be followed if specific events occur, so that the customer and the consumer should not be affected by such events.

As a manufacturer, it is important that we can deliver the goods in the right quantity and quality every time.

In the event of a serious incidents or disasters, it is crucial that Kavli can restore their production and return to normal operations as quickly as possible. In order that such crises and events are handled quickly and efficiently Kavli employ clearly defined procedures and protocols that seek to restore normal operations as soon as is practically possible.

Kavli have established plans for crisis management within all of its plants.

As a supplier of food products Kavli have a responsibility to contribute to a healthy and varied diet. Kavli therefore take into account the health aspects of the consumer in the development of new and existing products. We are responsive to what customers think and the consumer’s attitudes and wishes where we believe this is appropriate and possible.

At Kavli we believe in the following:

GMO

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Kavli does not use genetically modified ingredients in its products.

Kavli undertakes to only use raw materials and ingredients that are produced using traditional production methods and we will ensure that we do not use ingredients derived from genetically modified organisms (GMOs) as ingredients in our products. Kavli has strict rules in place with its suppliers with regard to the specification and supply of ingredients to ensure this.

Kavli is aware that it is possible that very small amounts of genetically modified material may enter materials by accidental cross contamination in the supply chain. The maximum proportion of such trace contamination tracks from genetically modified material sources will be such that it does not require GMO labelling as required by European GMO legislation.

Palm oil

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Kavli will only use sustainably produced palm oil in its products.

Palm oil has properties that make it suitable for use in a variety of food products. To ensure that the shipment of palm oil and the palm oil contained in compound ingredients used by Kavli does not have a negative impact on the local environment or the community where palm oil is grown, we aim to use only sustainably produced palm oil that does not have a negative impact on the region where the Palm trees are grown or the people who live there.

We will therefore only buy palm oil from:

  • plantations that operate in line with local laws and regulations;
  • plantations that are developed in the preserved areas;
  • plantations that grow with the permission of the local communities.

Soy

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Soy is one of the world’s most important commodities. Kavli only use soy produced in accordance with environmental and ethical good practice according to RTRS (Round Table Responsible Soy)

Soy is one of the world’s most important crops with respect to the production of protein and fat. Most of the commercially produced soybean is used for animal feed, but it is also a common ingredient in the production of meat, milk, eggs and farmed fish.

When sourcing soy for use in products, Kavli will take responsibility for soy consumption and undertake to only use soy that is produced in a sustainable way, from sources that are produced with respect for people, animals and the environment as defined by the “Round Table on Responsible Soy (RTRS)”.

Sugar, fat and salt

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Kavli recognise that Health Authorities would like to reduce the intake of sugar, fat and salt in the population. It is our intent to help in this work by customizing our products where possible to reduce the levels of these components in our products.

Many government agencies recommend consumers to reduce their intake of added sugar, fat and salt in the daily diet. A varied diet and a healthy lifestyle is crucial to reduce the risk of diseases such as cardiovascular diseases and diabetes.

Kavli supports the view that the intake of sugar should be limited in line with the advice of health authorities and from organizations such as the WHO (World Health Organization), but believes that some added flavour and sweetness is important for the taste and enjoyment of our products.

Kavli has committed to keep the level of added sugar as low as possible whilst at the same time maintaining the great taste of our products. Kavlis’ goal is to reduce sugar levels in products, and where possible replace sugar (fully or partly) with other suitable and approved sweeteners.

Kavli also aims to reduce the use of saturated fat and to avoid the use of trans-fats in the raw materials which are included in our products by carefully selecting the ingredients we use.

Sodium is a natural component of many raw materials. Sodium chloride as salt, will affect a product’s taste and can also be important in to maintain the product’s consistency and structure.

Sodium also has preservative properties and is found in several different types of salts, including sodium phosphates which are used by Kavli to give our products their creamy consistency.

Kavli supports the’ view that the intake of sodium should be limited in line with the recommendations of the WHO (World Health Organization). At the same time, we know that the level of salt will affect a product’s taste as well as other properties. Kavli is committed to keeping the sodium level of products as low as possible whilst maintaining the flavour, consistency and preservation of the product. Kavli will only select ingredients for use in our products that comply with all applicable food labelling regulations.

Food contaminants

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Kavli is committed to producing safe food and will ensure the ingredients they use meet all necessary regulatory requirements with respect to the content of possible contaminants such as residues of the veterinary medicine, pesticides, heavy metals and other contaminants.

Kavli has a responsibility to produce food that is healthy and safe to eat and does not contain traces of hazardous chemicals. We will therefore ensure that the ingredients we use meet all applicable regulatory requirements for food products.

We will ensure our products meet all appropriate legislation for the presence of contaminants such as heavy metals, pesticides, residues of the veterinary medicine or similar contaminants, and make sure or suppliers comply to strict specification to comply with this.

Irradiated material

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Kavli does not use irradiated ingredients in its products.

Kavli recognizes that our customers are concerned that we should not use ingredients that may have been exposed to ionizing radiation. To ensure this Kavli have in place strict supplier practices with regard to the specification of the ingredients and approval of suppliers.

Raw material quality and packaging material

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Kavli has specific requirements for receipt and control of incoming raw materials and packaging, based on industry best practices.

These requirements define the procedures that we implement to ensure that we operate in line with all appropriate laws, and that the safety and quality of our products is not compromised by the use of the wrong materials in our production.

All Kavlis’ businesses have an effective vendor management and surveillance system to ensure that the potential risks in relation to the authenticity, quality and legality of the end product - from raw material to finished packaging, are identified and managed in order to minimize any risk to the consumer.

Production sites conduct a documented risk assessment of each commodity or commodity group and packaging to identify possible threats for product safety, legality and quality.

Slavery Statement (1/3)

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KAVLI UK MODERN SLAVERY STATEMENT 2021 (1/2)

This is Kavli UK’s fourth Modern Slavery Statement issued under the Modern Slavery Act 2015, which requires large employers to be transparent about their efforts to eradicate slavery and human trafficking in its own business and in its supply chain.

As a responsible food producer Kavli UK recognises its responsibility to deliver safe food. Product quality and food safety have a very high priority throughout our organisation, and we are continually seeking to improve our standards further.

We maintain the same product quality and safety standards regardless of where the product is produced or sold, and we place great demands on our production sites to ensure they employ quality and food safety standards to the requirements of the Global Food Safety Initiative.

In accordance with the Act, our statement outlines the steps we take as a business to prevent slavery and human trafficking in our own operations and supply chains. To ensure that we have the most effective responses to prevent any negative impact on human rights, we continue to review our practices and improve where necessary. 

Kavli UK is committed to treating all people in our business and supply chain fairly. 

ORGANISATIONAL STRUCTURE – KAVLI UK 

Kavli UK is part of the Kavli Group. The Kavli Group has been operating in international markets for more than 100 years. Today our products are present in more than 20 countries around the world. With products and product expertise from all the Kavli companies, the Kavli Group offers nutritious, quality food for consumers on all five continents of the world.

The UK was one of the early export markets for Kavli and its Primula Cheese brand was first sold in the UK in 1929. The first UK factory was opened in 1936 near to Newcastle-upon-Tyne and under the leadership of Knut Kavli, the UK business was established and is now situated on the Team Valley in Gateshead. In 1997 Kavli UK acquired the Castle MacLellan pâté business located in Kirkcudbright in South West Scotland. In 2013 Kavli UK acquired the St Helen’s Farm goats’ milk business located close to York. Kavli UK currently has around 260 employees across its three sites and makes a range of food products including cheese spreads, snacks and dips under the Primula brand. Chilled pâté is made under the Castle MacLellan brand and goats’ milk products under the St Helen’s Farm brand. Kavli UK also manufactures a range of private label products for UK supermarkets. 

OUR POLICIES 

Kavli UK takes a zero-tolerance approach to slavery and human trafficking. We aim to educate our colleagues and supply chain by working closely with the Gangmasters and Labour Abuse Authority (GLAA) and by keeping up to date with current legislation. We have several policies that have underpinned the basis of our statement, including:

  • Ethical Trading Policy
  • Dignity at Work Policy
  • Whistleblowing Policy

Our Ethical Trading Policy adheres to local legislation with at least the National Living Wage being paid and adhering to working time regulations, including employment being freely chosen. We are also committed to ensuring no colleague is treated inhumanely or experiences harsh treatment. 

Our Dignity at Work Policy was developed to ensure we care for all colleagues and take a firm stance against harassment and bullying, whether by internal colleagues or anybody external to the business such as customers or suppliers. 

In addition, our Whistleblowing Policy is displayed throughout the business and is a means for all colleagues to be able to report suspicions of misconduct relating to the business or an individual’s life or health. This is a confidential means for colleagues to report if they feel this is necessary and enables the business to investigate any issues accordingly. 

 

DUE DILIGENCE 

Kavli UK believes that by maintaining links with organisations such as Clearview, SEDEX, Gangmasters and Labour Abuse Authority (GLAA) and Stronger Together we have created a firm basis for future due diligence.  Stronger Together plays a key role in providing Kavli UK with the knowledge needed for effective implementation of a modern slavery strategy within its own supply chains, and by helping us to understand how we might identify modern slavery.

Labour Providers

As a company we use labour providers to supply a percentage of our workforce throughout the year.  As such, Kavli UK ensures that our labour providers hold a valid GLAA licence and that they follow the provisions of the Gangmasters Licencing Act 2004, adhering to all their standards protecting workers from poor treatment and exploitation. 

 

The GLAA license covers the following protections for workers: 

  • Fair working hours
  • Adequate and appropriate training 
  • National Minimum Wage
  • Transport
  • Health & Safety
  • Workers terms and conditions

 

Audits are conducted including GLAA checks for current trusted agencies used, and new agencies are audited prior to consultation.

Kavli UK will continue to review both its own and its labour providers’ involvement and membership of Clearview, to ensure global social certification with the objective to drive responsible recruitment practices in our supply chains. The Clearview Technical Advisory Committee focus on the proactive measures that labour recruiters and providers have implemented to ensure that workers are not subjected to debt bondage, forced labour or other forms of hidden exploitation. 

Supply Chain

In 2019, as part of our due diligence, Kavli UK reviewed the controls put in place by our supply chain to establish, assess and monitor areas of potential risk. This assessed our supplier’s adoption and dissemination of the ETI Ethical base code allowing us to scope for future support and collaboration in line with our commitment under the Modern Slavery Act 2015. Criteria focused on supplier’s commitment to creating shared values, sustainability, and compliance. 

Kavli UK will also undertake due diligence when considering contracting with new suppliers. Where necessary, suppliers (new/current) are sent a Supplier Assessment Questionnaire (SAQ) and Specification for completion and approval, these are resubmitted to suppliers for update every 3 years as a minimum.  Kavli UK will not maintain business relationships with any suppliers that we know violate the human rights of its own colleagues. 

 

Slavery Statement (2/3)

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KAVLI UK MODERN SLAVERY STATEMENT 2021 (2/3)

AREAS OF RISK

Our supply chain review provided a risk assessment which allows Kavli UK to implement an auditing and monitoring programme commencing with the higher risk suppliers. Kavli UK is a member of the Supplier Ethical Data Exchange (Sedex) and all Kavli UK businesses are regularly audited by third parties who publish our results, thereby ensuring visibility to our customers and suppliers.

In 2020, the UK group purchased raw materials, packaging, goods and services totalling approximately £27 million.  In total, the UK group has over 300 suppliers, 32 of which represent approximately 80% of the UK group’s total procurement costs.  Important purchase categories for Kavli UK are dairy, other food ingredients, and packaging. Most of our suppliers are based in the UK and Europe. 

Another input cost for Kavli UK is agency labour.  Our approach to modern slavery risks arising from our agency labour provider is documented within Due Diligence.  Annual spend with our agency labour supplier is c.£0.3m and consequently does not come into our top 32 suppliers when classified by annual spend.  However regardless of annual spend, because of its nature we consider agency labour to be a higher risk supply to the Kavli UK Group.

Assessing the UK group’s supplier base on an annual spend basis, allows focus on the largest suppliers representing the highest risk.  For the 32 suppliers making up 80% of annual spend, we are in the process of creating a detailed supply chain mapping, documenting supplier details, the country in which they operate in, and the checks we have undertaken on their efforts and commitments to tackle modern slavery.  The mapping also includes links to our higher risk suppliers Modern Slavery Statements.  

PERFORMANCE INDICATORS 

Kavli UK is not aware that any of our supply chain businesses have been identified as being at risk of incidents of forced or compulsory labour. Nor is Kavli UK aware of incidents of child labour being used. We have not received any human rights-related grievances in relation to our business or those of our supply chain.

Kavli UK has a long-standing relationship with the GLAA which plays a role in our supply chain. 

As members of SEDEX, we may be required to undergo SMETA audits (SEDEX Members Ethical Trade Audit). We welcome these audits to ensure a regular independent review of our policies and practices, ensuring the most effective responses are in place to prevent any form of modern slavery, both in our site operations and through our supply chain.  

Our audit at our Castle MacLellan Foods Ltd site in early 2021 has allowed us to identify areas for continuous improvement in line with our Kavli UK values.

As part of our key performance indicators for the coming year and beyond, we will arrange independent ethical audits at our production sites in the UK for us to be able to publish key findings in our statement in the following year.  In addition, we will also continually monitor the following key performance indicators:

Modern slavery training:  

  • We will ensure that all our staff inductions introduce employees to the topic of modern slavery 
  • To ensure employees can spot the signs of modern slavery, and how to report issues, we will undertake an internal awareness campaign annually to all employees
  • All our employees who have roles dealing with suppliers (i.e., our Procurement Team) will receive periodic updates on modern slavery 

Supplier engagement: 

  • Where necessary, new suppliers will undergo a sustainability assessment during our onboarding process
  • All suppliers will be issued with a copy of our Modern Slavery Policy which will be documented and recorded

TRAINING 

Members of the HR team have undergone Stronger Together training. Stronger Together is a UK multi-stakeholder collaboration between supermarkets, the Association of Labour Providers, Clearview and the GLAA. Kavli UK has embraced the Stronger Together programme across all our UK sites. Kavli UK will educate our colleagues to recognise the risks of modern slavery and human trafficking in our business and supply chain through incorporating the Stronger Together video/training package as part of our induction procedures.  Further, we continue to display Stronger Together Posters throughout our UK businesses. 

Kavli UK actively encourages all colleagues to identify and report any potential breaches of its Modern Slavery Policy and have mechanisms in place to increase the visibility of issues through the Stronger Together hotline and our own confidential colleague “Whistle B” website. Colleagues are made aware of the stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate it from our business and supply chain. Kavli UK supports the principles of the Modern Slavery Act and its provisions around slavery, servitude, forced labour and human trafficking, including provision for the protection of victims.

The business is continuing to look for ways to address modern slavery.  In the last 12 months, a cross-functional group within the UK business has been assembled to place more significant focus on modern slavery in the workplace. This is so we can continue to learn and adapt to the impact modern slavery has on the industry. 

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes Kavli UK’s Slavery and Human Trafficking statement for the financial years 2020/2021. 

 

Slavery Statement (3/3)

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KAVLI UK MODERN SLAVERY STATEMENT 2021 (3/3)


NEXT STEPS FOR 2021/2022

 

 

Date Set

End Date

Commitment 

Status

Comment

Training and Awareness

2021

2021

Create a project group within Kavli UK Ltd to focus on modern slavery – reviewing and updating the statement for 2021, and creating a road map for future initiatives to implement in the coming years

Complete

Project group created containing key contacts across HR, Supply Chain, Finance and Sales 

2021

2022

Kavli UK Ltd to publish an internal ‘Modern Slavery Policy’ to all employees and publish this on the business websites

New

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2021

2022

To raise awareness further within the business, modern slavery will be raised as an agenda point at our tertial staff briefings on all production sites to ensure all staff have information on contact points for raising concerns and reporting. Information presented will then also be displayed on noticeboards throughout the businesses

New

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2021

2022

Increase number of key stakeholders within the business who have undertaken the ‘Stronger Together’ training 

New

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2021

2022

Create a modern slavery email mailbox for employees to contact regarding any slavery concerns

New

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Supplier Focus

2021

2022

Positively encourage all our suppliers to register with SEDEX to ensure a clearer view of our full supply chain and consider upgrading Kavli UK’s SEDEX membership to ‘AB’

New

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2021

2022

Upon completion and publishing of our Modern Slavery Policy, issue this out to all suppliers and document this to ensure they are aware of our standards and expectations.

New

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Whistleblowing

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Whistleblowing can be used to report a concern about something that is not in line with our corporate values and business ethics, and that may affect our company or a person’s life or health.