Tails.com Modern Slavery Statement

Introduction

Our purpose at tails.com is to improve the lives of dogs and their owners, and in doing so, our vision is to change the world of pet food for good. We are against all forms of slavery, child labour and trafficking, and we expect our teams and our suppliers to take all reasonable steps to make sure no form of exploitation takes place in our supply chain.

This is our second modern slavery statement published in accordance with the UK Modern Slavery Act (2015). Section 54 of the MSA requires every organisation with a global annual turnover of £36 million or more, which carries out business in the UK, to produce a slavery and human trafficking statement for each financial year. This statement sets out the steps we have taken to ensure no modern slavery exists in our business and its supply chain. Note that our financial year runs from January to the end of December.

Our Organisation and Supply Chain

We are an online direct-to-consumer business selling personalised pet food, founded in 2013. We use third party manufacturers to produce our food components, complementary items, and packaging. 67% by value of our food and packaging components are sourced in the UK, with a further 28% from the EU. A small amount of our supplied items come from the Far East. 

We blend individually customised food orders in our two manufacturing operations, based in the UK and the Netherlands, and use third party couriers to distribute packages to our customers in the UK and Europe.

The key changes since our last statement is that we have added our second factory in the Netherlands, and we have onboarded some new European suppliers to serve that site.

Our Policies on Modern Slavery

We have commitment from our CEO and board to take all the steps we can to make sure no form of exploitation occurs in our business, and have appointed team members responsible to carry out our obligations and improve our processes over time. 

We have a sourcing process which describes the expectations of our suppliers when we onboard them. This includes, amongst other areas, compliance with the Modern Slavery Act. 

We’re currently working on the following to improve our policies:

  • Compile our existing policy documents into a register
  • Create a Supplier Code of Conduct including specific actions relating to Human Rights and our expectations for ongoing assessment and monitoring.
  • Due Diligence

    We take the following steps to reduce as far as possible any risk that modern slavery is present in our supply chain. 

    Contract Manufacturers and Courier Partners

    We engage with our suppliers to convey our policies and to understand what they do to ensure modern slavery is not occurring in their business. We audit all suppliers before bringing them onboard via a questionnaire and a site visit where appropriate. We assess their compliance in the following areas:

  • Corporate social responsibility, ethical and environment policies in place
  • For UK suppliers, compliance with the National Minimum Wage Act 2018, or if international, employees are paid at least the prevailing minimum wage applicable within the country of operation
  • Compliance with the Modern Slavery Act 2015
  • Agency Staff

    We work with labour agencies to employ some contract staff to work in our factories and warehouses. Our agents are contractually obliged to ensure the regular governance and collection of: 

  • Proof of Right to Work in the UK or the Netherlands, and Proof of Identity for each person
  • Confirmation that wages are paid into worker personal bank account of choice
  • Compliance with the National Minimum Wage Act 2018 in the UK and Statutory Minimum Wage in the Netherlands
  • Compliance with the UK Modern Slavery Act 2015.
  • Our Team

    We ensure all our people have the Right to Work in the UK or the Netherlands as appropriate and they have their own documents to support this. We check that their wage payments are going to an individual’s nominated bank account.

    At our UK site in Heathrow, we pay everyone who works for us at or above the minimum wage at the rate for 25 year olds even if they are younger than this. We provide the same rights for our temporary operators as our permanent ones from the first day they start with us, improving on the standard entitlement for agency workers to receive parity after 12 weeks.

    At our Dutch site in Amstelveen, we pay everyone who works for us at or above the minimum wage at the rate for 21 year olds, based on a 40 hour working week, even if they are younger than this.

    All of our team receive an induction when they begin work, and receive ongoing on-the-job training to help them excel in their roles, progress their careers, and safeguard their wellbeing. Our salaried staff have access to our Employee Assistance Programme and our enhanced Learning and Development programme. 

    We’re currently working on the following to improve our due diligence processes:

  • Form a tails.com Materiality Committee to oversee impact areas of our business, and make sure we improve over time
  • Make sure that all small and occasional contractors in our factories have a robust onboarding process
  • Add our Modern Slavery Statement to the UK Home Office’s online registry, as well as publishing it on our website
  • Understand and be ready to act on our requirements under the Dutch Child Labour Duty of Care Act (Wet Zorgplicht Kinderarbeid) 2019 and / or the Bill for Responsible and Sustainable International Business 2021 when these come into force
  • Training and Communication

    To make sure that all of our team have a high level understanding of the risks of modern slavery and human trafficking in our business, we provide awareness training for everyone working for us. This includes how to recognise the signs of modern slavery and how to report issues.

  • Company induction when all permanent employees join the business
  • Awareness training for production operators included in site induction
  • Posters displayed prominently in our factory with the key messages
  • Our procurement team keeps up to date with the latest legislation and best practice via continuous professional development.

    We’re currently working on the following to improve our training and communication:

  • Provide refresher training at intervals for our teams
  • Assessing and Managing Risk

    We know that the risk of modern slavery is a dynamic and ever changing possibility in our supply chain. We are not complacent to the risk and so it is important that we have visibility of what’s happening in our supply chain and identify opportunities for improvement.  We review and take further steps to improve our handling of these issues. 

    We conduct quarterly risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can be focused on those areas.

    We conduct regular Supplier Performance Reviews, at least once per year, where we check progress against improvement projects, and whether the status in any area has changed.

    We regularly conduct unannounced audits of agency employee files to ensure compliance with our standards. 

    We’re currently working on the following to assess and manage risk more effectively:

  • Create a modern slavery risk register for all suppliers, categorising those with greatest need for monitoring and assessment, and assign appropriate action
  • Introduce supplier audits carried out by an independent assessor
  • Measuring Performance and Progress

    We have used the toolkit provided by Stronger Together to understand ways we can better tackle modern slavery via our purchasing practices. We’ve used this as a framework to identify areas for improvement and to create an action plan for the next 12 months. 

    Since we published our first statement last year, by this statement in 2021 we have completed 30% of the best practice checklist actions. Our target over the next 12 months is to have completed 50% of the checklist, the steps we’re working on to achieve this are described in each of the sections of this statement. 

    Reporting Issues

    We have an open culture of feedback and anyone can raise a grievance or an issue to any manager within the business and expect to be heard fairly and in confidence. We perform an anonymous company-wide survey twice a year for all salaried members of our team. We survey our temporary production staff anonymously once a year.

    If a team member, or person not employed by us, has any concerns about suspected modern slavery associated with tails.com or an element of our supply chain this may be reported by contacting our Head of People, or Operations Director, in confidence.

    We’re currently working on the following to improve our reporting of issues:

  • Seek feedback from our suppliers annually on our performance via a questionnaire
  • Deploy a whistleblowing / independent grievance procedure
  • Endorsement

    Ultimate responsibility for the prevention of modern slavery rests with our leadership team. This statement has been approved by our board of directors.

    If you would like to share any feedback on this document, please email hello@tails.com.

    James Davidson

    CEO, Director and Co-founder

    26th May 2021

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