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 fourth 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. In 2022, 71% by value of our direct raw materials and services were sourced in the UK, with a further 28% from the EU. 1% by value of our direct spend was sourced from further afield.
We blend individually customised food orders in our manufacturing operations, based across two sites in the UK and one site in the Netherlands. We then use third party couriers to distribute packages to our customers in the UK and Europe.
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. Our Modern Slavery Statement is published on our website and included in the UK Home Office’s online registry.
We have a supplier and a retailer code of conduct, detailing the expectations from tails.com of any partner that works with us. These are published on our website. The codes include, amongst other areas, a requirement to comply with the Modern Slavery Act. These codes have been shared with our key suppliers who have formally agreed to uphold them.
We have a sourcing process which describes the expectations of our suppliers when we onboard them. Our Responsible Sourcing Policy, shared with our internal team, establishes guidelines for buying new products and services for tails.com, which includes taking steps to ensure no modern slavery is involved in the products or services we buy.
We have compiled all our existing policy documents into a Materiality Register, where they are reviewed as a minimum annually, and we identify opportunities to strengthen these over time.
We’re currently working on the following to improve our policies:
- Responsibility to manage the risks of modern slavery across all of tails.com to be listed in all procurement team job descriptions
- Update our supplier code of conduct to explicitly prevent practices that contribute to the risk of modern slavery, and set clear expectations for effective grievance and remediation mechanisms
- Get formal commitment from all our suppliers to uphold our codes of conduct
tails.com has formed a Materiality Committee consisting of senior leadership across the organisation who ensure we’re clear on the positive and negative impacts of our business on all our stakeholders. The Materiality Committee is responsible to make sure we have policies to enhance our positive impact and reduce negative areas, that plans are in place to improve our performance over time, and these actions are carried out. This includes amongst other areas, our policies and commitment to ensure no modern slavery exists in our business or supply chain. The Materiality Committee reports progress on each impact area as a minimum annually to our investor board and stakeholders.
We take the following steps to reduce as far as possible any risk that modern slavery is present in our supply chain.
Contract Manufacturers, Courier Partners and Other Suppliers
We engage with all our suppliers to understand what they do to ensure modern slavery is not occurring in their business. We oblige them contractually to maintain our policies, and not doing so would constitute a breach of contract. We audit all suppliers, regardless of their size, 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
We work with labour agencies to employ some contract staff to work in our UK operation. Our agents are contractually obliged to ensure the regular governance and collection of:
- Proof of Right to Work in the UK, 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
- Compliance with the UK Modern Slavery Act 2015.
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 sites, we pay everyone who works for us at least a Living Wage (which is above the statutory minimum wage) with the same minimum rate for our temporary operators as our permanent ones from the first day they start with us.
At our Dutch site in Amstelveen, we pay everyone who works for us 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. All permanent staff having completed 6 months’ service receive enhanced holiday, sick pay, enhanced maternity and paternity leave, entitlement to 10 days unpaid leave, and medical cash plan benefit. They also have access to our Employee Assistance Programme and our enhanced Learning and Development programme amongst other benefits.
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 factories with the key messages
Our procurement team keeps up to date with the latest legislation and best practice via continuous professional development, and by engaging with expert partners to understand how we might work in collaboration across industry to deepen our impact to eradicate modern slavery.
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 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 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:
- Extend our supplier audits carried out by an independent assessor, to include questions to assess the risk of modern slavery
- Update our internal Supplier Relationship Management process to include regular risk assessment, as a minimum annually, for every supplier
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 third statement last year, by this statement in 2023 we have completed 73% of the best practice checklist actions. Our target over the next 12 months is to have completed 100% of the checklist, the steps we’re working on to achieve this are described in each of the sections of this statement.
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 all our production staff (temporary and permanent) anonymously once a year. We seek feedback from our suppliers on our performance via a questionnaire.
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 also have a confidential non-compliance reporting system, SpeakUp, where any team member can raise concerns anonymously and these will be independently followed up.
Tails.com has a remediation policy, which provides a practical framework for our internal team and supplier partners for how to act, and how to safeguard and provide remedy for the victim, should a case of modern slavery be found.
We’re currently working on the following to improve our reporting of issues:
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 statement, please email firstname.lastname@example.org.
Secretary, Director and Chief Financial Officer of tails.com
30th May 2023