July 15, 2022
To our stakeholders:
I am pleased to confirm that WSH reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment, and Anti-Corruption.
In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture, and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.
Sincerely yours,

Mike Hanson
Director of Sustainable Business
WSH

Our business

WSH Limited (‘WSH’) is a leading Catering and Hospitality provider, with a strong focus on fresh and regionally sourced products prepared and served on site by well trained staff. We work with a large number of partners, stakeholders and suppliers and recognise that every entity in our supply chain has a duty to respect human rights.

Our position

At WSH, we are clear about our responsibility to prevent slavery and human trafficking. We have a zero- tolerance approach to all forms of slavery both within our own operations and across our supply chain. We recognise that modern slavery continues to be a global issue and humanitarian crises. Rising social inequality and widespread labour shortages resulting from the Covid-19 pandemic only serve to increase the risks of human trafficking and forced labour. This statement outlines the steps we have taken to date, and continue to take, as a business to prevent slavery and human trafficking in our own operations and supply chains.

Our supply chain

We buy products and services from thousands of suppliers and are immensely proud of the role they play in enabling each of our operating locations to deliver outstanding levels of service and hospitality to meet our client and customer needs. Our supply chain is complex and varied and we deliberately operate a decentralised supply chain model, providing our teams with the choice and ability to select from approved suppliers as opposed to creating and forcing centrally determined supply chain solutions. Our supply chain is predicated on fresh and regional supplier networks but our Procurement & Supply Chain function is also responsible for the goods and services we need to run our business (GNFR – Goods and services not for resale) such as HR and professional services, technology, logistics and cleaning. Our supply chain remains incredibly diverse and provides the platform from which our businesses can grow, develop and continue to provide fantastic food and service.

STEPS TAKEN BY WSH TO DATE

1. Governance

At WSH, we recognise that strong governance is essential for identifying and driving out modern slavery in our business and across our supply chain and that executive-level ownership and engagement on the issue of modern slavery is critical. The development and oversight of ethics and sustainability policies had been the responsibility of our Integrity and Ethics Committee which underwent a refresh in 2021 as we broadened its responsibilities to cover all areas classified within our Environmental, Social, and Governance (“ESG”) targets and goals. Now known as the ESG Committee, we continue to have strong membership from our enabling functions such as HR, Health and Safety, Sustainability, Procurement, Supply Chain, Legal as well as Operations. As part of developing the new ESG Committee, we also refreshed the terms of reference to clarify the purpose and role of the individual members and Chair. Reporting to the main WSH board, modern slavery continues to be a permanent agenda item for the ESG Committee as it continues to take its responsibility on developing and overseeing our ethical approach in this area as a high priority.

2. Policies and contractual controls
WSH remains committed to ensuring that its dealings with its own employees, and with its suppliers, are conducted ethically and responsibly. WSH adheres to internationally recognised human rights principles and our policies are underpinned by our adherence to a number of important internationally recognised standards including the UN Universal Declaration of Human Rights, core International Labour Organisation (ILO) standards, the Ethical Trading Initiative (ETI) Base Code and

national and international laws. The following nine clauses guide us in how we protect and respect human rights across our operations:

• employment is freely chosen;
• freedom of association and the right to collective bargaining are respected;
• working conditions are safe and hygienic;
• child labour shall not be used;
• living wages are paid;
• working hours are not excessive;
• no discrimination is practiced;
• regular employment is provided; and
• no harsh or inhumane treatment is allowed.

We expect suppliers to comply with all applicable national laws in the countries in which they operate and all relevant ILO Conventions.

3. Our suppliers

Our procurement function is responsible for sourcing the goods and services that we need to run our business. Our supply chain is extensive and, even though our focus naturally lies in the food and beverage categories given the nature of our business, our standards and policies extend to all suppliers used across our operations and we have well-established processes and policies in place to ensure that workers making and delivering the products and services we use or sell are treated responsibly.

Throughout 2021 we continued to adapt our ways of working to ensure that they remained fit for purpose in the face of the ongoing Covid-19 pandemic and the resultant issues created by pressures in the labour market, inflation, and supply chain disruption. The nature of these additional pressures continues to impact how we identify, assess, and manage risk in our supply chains as well as changing the nature and visibility of some of those risks. Whilst we continue to adapt, we endeavour to make sure that our standards are continuously met through a rigorous supplier onboarding and audit process, along with regular supplier dialogue.

Supplier onboarding:

Any supplier wishing to work with our business will go through a detailed onboarding process which requires them to agree and sign up to our general terms and conditions of trade, which include appropriate anti-slavery and human trafficking clauses. They are also required to agree and commit to full compliance with the following:

a) our Responsible Sourcing and Ethical Trading Policy which sets out our standards in relation to ethical trading;

b) our Anti-Slavery and Human Trafficking Supplier Sign-Off which relates more specifically to the Modern Slavery Act;

c) the implementation of a due diligence process within their business to ensure there is no slavery and human trafficking in their supply chain (including in relation to personnel obtained via recruitment agencies); and

d) that any contracts with subcontractors and suppliers also include human trafficking provisions that meet our requirements.

In addition to managing our requirements through the onboarding process, we also capture additional information through our supplier management portal where all eligible Tier 1 and Tier 2 suppliers are required to complete a Self Audit Questionnaire (SAQ) which formally records and captures the supplier’s key details, policies and 3rd party accreditation and certification. It is a requirement of our portal that these be refreshed and updated on an annual basis by the supplier for our Supply Chain Technical team to approve continued supply and adherence to our requirements and policies. We are committed to strengthening further our processes and controls around gathering key supplier

information in order for us to increase visibility, identify risks and improve ethical practices across our supply chain.

Supplier auditing:

Our onboarding process also enables us to determine which suppliers are most at risk of responsible sourcing challenges and, for those high-risk suppliers, we prioritise a site audit. The site audit allows us to understand more about what the supplier is really doing to protect their people and following this, we notify the supplier of any remedial action we believe is required. It has been challenging to carry out site visits and see suppliers face-to-face in 2021 but we continued to have an open dialogue with all key suppliers and managed and monitored the update of SAQs closely to ensure no deterioration in a supplier’s status in complying with our Responsible and Ethical standards and requirements. We have however made good progress with our SEDEX (Supplier Ethical Data Exchange) engagement work and self-assessment questionnaires which had been temporarily put on hold in 2020 as a result of the pandemic.

Our supplier expectations:

We maintain a regular dialogue with our suppliers and, with many of them, have a history of strong, long-standing relationships. We believe that this enables them to invest in the longer term and improve working standards for their employees. We see it as our responsibility to work closely with our supplier partners to ensure that they understand and implement our high standards and continue to comply with local legislation and regulations.

We will only continue to trade with those suppliers who fully comply with our Responsible Sourcing and Ethical Trading Policy and our Anti-Slavery and Human Trafficking Supplier Sign-Off or those who are taking verifiable steps towards compliance. Whilst we have a greater ability to influence our Tier 1 suppliers, we understand that some of our greatest ethical and human rights risks lie in our Tier 2 and 3 supply chains. Although these do not come under our direct management, we see it as a collective responsibility to work with our suppliers to understand existing and emerging risks and take appropriate action. One of the more obvious impacts of Covid-19 in our sector has been the widespread labour shortage in warehousing, processing, and driving of heavy goods vehicles and we have focussed on strengthening our due diligence in the area of temporary labour both for suppliers serving our business as well as that of our suppliers.

4. Training and awareness

We recognise that to achieve the successful implementation of any anti-slavery and anti-human trafficking culture it is vital to train and raise awareness among those employees who have the potential to come in contact with suppliers on a regular basis. Our intention is to continue to focus on identifying any potential risks or failures, thereby driving ever greater compliance with our high standards.

We remain committed to rolling out our Ethical Trade and Modern Slavery training module to our colleagues beyond those who are directly linked to managing and assessing modern slavery and human trafficking risks in our business. Throughout 2021 we continued to engage with our teams using our online platform and see this as a key area of continued development.

5. Looking ahead

With the continued development of WSH’s ESG Strategy and continued oversight of this by the ESG Committee, we hope to make further progress in 2022 to further reduce the risk of Modern Slavery by working towards, or achieving, the following goals:

a) collaborating with our top strategic suppliers across Tiers 1 and 2 to ensure that a minimum of 80% have a Human Rights Policy in place by the end of 2023.

b) achieving 100% SEDEX or equivalent registration for all suppliers with fully completed SAQs by end-2025;

c) redeveloping and launching our Supplier Code of Conduct and updating our Ethical Trading and Sustainability policy by the end of 2022;

d) reviewing our supplier onboarding process and platforms, along with our standard terms and conditions, to ensure that supplier expectations and standards are clear, understood, and reflect the changing needs of our clients and customers in the areas of ethical trading and human rights;

e) growing awareness of human rights through additional e-learning tools and platforms across all our businesses with the aim of having every colleague undertake annual online training by end-2023;

f) exploring the option to partner with a charity or supplier supporting the survivors of Modern Slavery;

g) enlisting and instructing the services of an independent third party to complete comprehensive audits of all agencies providing temporary labour provision into our businesses by end-2022; and

h) acknowledging that modern slavery is a systemic issue requiring greater collaboration and support from external partners and industry bodies, we will register and sign up to work with a verified, independent, body to help us develop our modern slavery prevention strategy.

2021 continued to highlight the many inequalities and imbalances that exist in our society and around the world and whilst responding effectively to the direct needs within our business for wellbeing and colleague welfare, we continue to recognise that the responsible and ethical sourcing of products and services is of paramount importance as we recover both from the social and economic consequences of the Covid-19 pandemic and face increased volatility in the labour market and across our supply chain.

We remain dedicated to the implementation, measurement and raising of awareness and standards on modern slavery across our business and supplier base and will continue to build on the activities and progress we have made to date.

Other policies specifically relating to employees and other stakeholders’ human rights include but are not limited to:
Whistleblowing
Transgender
Shared Parental Leave
Flexible Working
Equality, Diversity & Inclusion
Dignity at Work
Dependent Care & Emergency Leave
Adoption Policy

What we said we would do:

To recommence audits and incorporate SEDEX criteria into the standard supplier SAQ in order to improve our visibility of those suppliers registered with SEDEX as well as identify those who are yet to register.

How have we done:

Achieved

What have we done:

We have amended and added to our existing audit schedule of questions and can now identify, those suppliers using our portal, who are yet to register with SEDEX.

What we said we would do:

Extend the SAQ to all suppliers who are likely to use sub-contracted services and labour;

How have we done?

Achieved

What have we done?

We have extended the SAQ to all suppliers in this category

What we said we would do:

Continue to identify our goods and services which have the highest spend as well as those suppliers who are business-critical and create tailored reports for the benefit of clients and customers.

How have we done:

Ongoing

What have we done:

This continues to be reviewed on a regular basis.

What we said we would do:

Broaden our risk assessment for those suppliers who may be sourcing from areas with an elevated risk of modern slavery inc. higher risks of worker exploitation, representation, and small-holder livelihoods.

How have we done:

Progress made

What have we done:

By focussing on our most critical suppliers in terms of spend and risk with our SEDEX engagement we are now able to evaluate this far more effectively.

What we said we would do:

Continue to investigate the marketplace for digital options to enable us to undertake full traceability mapping on key products and suppliers enabling us to assess the modern slavery risk for such products and suppliers.

How have we done:

Behind schedule

What have we done:

Fresh options have been considered along with using our incumbent systems providers to trial supplier and product mapping. Early attempts to look beyond Tier 1 have proven difficult although we recognise that external factors and resource challenges in our Supply Chain are likely to be major contributory factors.

What we said we would do:

To increase the number of suppliers linked to our business via the SEDEX platform focusing on all nominated and high-risk suppliers.
How have we done:

Progress made

What have we done:

We have engaged with key suppliers to register with SEDEX and expect to have captured data for the top 80% spend by end-2022

If the company was made aware or became aware of any human rights abuses whether employee, stakeholder, or supplier the appropriate director would be informed plus the CEO and chairman.

All employees and suppliers are regularly reviewed which includes discussions on welfare, business activities, and relationships within the organisation.

These reviews are shared with and reported to senior management as required. Annual employee surveys are conducted online.

WSH fully embraces the ILO conventions.
- Employment is freely chosen
- Freedom of association and the right to collective bargaining are respected
- Working conditions are safe and hygienic
- Child labour shall not be used
- Living wages are paid
- Working hours are not excessive
- No discrimination is practiced
- Regular employment is provided
- No harsh or inhumane treatment is allowed
WSH operates under the remit of robust labour-related policy including harassment policy, equality & dignity policy, maternity, paternity, flexible working opportunity etc.
The Company recognises that its employees are key to its success and is committed to creating a working environment where everyone has the opportunity to learn, develop and contribute to the success of the Company. The Company intends to be an employer of choice and to employ a diverse workforce with the skills, abilities, and attitudes to meet business goals and objectives. The Company's aim is to create an environment in which all people are valued and can be successful at work.
Through the implementation of its Human Resources Policy, the Company intends:
• To recruit and select those people who have the appropriate skills, attitudes, and behaviours to meet business needs
• To provide terms and conditions of employment that attract, retain, motivate, and reward employees and reflect local market conditions
• To comply with all legislative requirements and align ourselves to best practice
• To define management and leadership behaviours and develop a companywide succession planning process to identify talent and safeguard business-critical roles
• To invest in the development of the company’s talent and provide training and development for all employees
• To treat employees fairly, consistently, and with respect
• To seek employees’ views and feedback using appropriate communication channels and engage in employee consultation as and when appropriate
• To define the standards of performance and conduct expected of employees

Description of concrete actions taken by the company to implement labour policies, address labour risks and respond to labour violations.
All written policies state employee rights and responsibilities and their compensation and benefits. WSH operates under the remit of a robust HR and associated labour-related policy structure. WSH trains all employees on HR-related matters including but not limited to diversity and equality.
All employees and suppliers are regularly reviewed through an appraisal system which includes discussions on welfare, business activities and relationships within the organisation. The health & safety of all employees has safeguarded through the company H&S policies which include a certified occupational H&S management system to ISO 45001.
Labour rights and policy are managed via the HR Director and then ultimately CEO and Chairman.

WSH operates a robust employee engagement and review programme based on a formal annual appraisal system framework.
WSH’s supply chain policy required all suppliers to accept and adhere to ILO conventions as above All employees and suppliers are regularly reviewed which includes discussions on welfare, business activities, and relationships within the organisation.
These reviews are shared with and reported to senior management as required.
WSH does not formally monitor ethnicity or diversity currently although this is planned as part of the new ESG framework, there are however voluntary questions at engagement time however these are not collated currently.
WSH operates a rigorous grievance procedure as laid out in the policy. WSH holds the classification of ‘world class’ for Hospitality Assured from the Institute of Hospitality which includes employee engagement, HR issues, and welfare.

Our Sustainable Business Strategy starts with a robust baseline assessment spanning all aspects of operational activity on your sites. The baseline assessment process follows the structure as determined by our ISO 14001:2015 accredited EMS including a site-specific review of aspects and impacts that are focused within our proposed services on two key areas; resource efficiency and waste management programmes in these areas cover everything from basic good housekeeping, through to more technical and potential financial investment to allow greater efficiency and savings in the longer term assuming an acceptable ROI plan is in place.
Once we fully understand the key aspects and impacts of our service provision, we can set in place robust and challenging objectives and targets built up from the monitoring and measurement of each manageable facet of the operations. In some instances, simple processes for the recording of data can be implemented such as weighing and costing both kitchen and plate food waste and reviewing against a functional unit such as production volume or turnover can affect a significant focus on waste minimisation – in our experience from simple segregation and weighing we have seen up to a 25% reduction in food waste and therefore environmental impact and cost.
Our environmental policy forms the foundation of our EMS and it is from this we have established Environmental Best Practice documentation for food service operations, Energy efficiency House Rules and the first three of our Green Flash Training programme; MSC Sustainable Fish Chain of Custody, Energy & Water Efficiency in your Location and Food Waste Prevention.
WSH has also achieved accreditation for its energy management system to ISO 50001 which is the business’ chosen route to compliance with ESOS and also provides a framework for energy efficiency across the business and adds value to the client proposition. In 2017 WSH as part of the wider WSH family committed to purchasing 100% renewable electricity by the end of 2020, this was actually achieved by the end of 2019. Also, in 2017 WSH achieved certified carbon Neutral status for fleet and business travel. WSH is now committed t mapping the business to the UN sustainable development goals and has joined UKSSD as a network partner to drive the SDGs. WSH is proud to have committed to net zero through a science-based approach by signing the Business Ambition for 1.5 degrees in May 2021 and joining the UN's Race to Zero.

Mike Hanson is WSH’s Director of Sustainable Business and is responsible for all aspects of environmental management as part of the wider sustainability remit.
Mike has 16 years of sustainability experience and worked previously as a professional catering operator in roles from chef to area manager; this brings Mike a unique insight into the issues around sustainability and CSR in the food service environment.
Mike is qualified with an MSc in Corporate Environmental Management.
In August 2014 we began a project to segregate, weigh and report nationally, the food waste arising from our entire business. In over 1,200 sites we are now segregating food waste by plate waste, production waste and spoilage waste and reporting through our online accounting system, following significant enhancements to functionality.
We now have the ability to monitor actual food waste by weight, cost and environmental impact on a daily basis and also as a percentage of food and beverage purchases. The segregation, weighing and reporting process along with an interactive purpose-built training session; part of our in-house modular environmental and behavioural change training programme ‘Greenflash’, has resulted in a 41% reduction in food waste arising, saving over £14 million since the start of the projects of the project so far equating to a carbon saving of 61,000 tonnes CO2e based on full life cycle footprint, in real terms the equivalent of taking 15,000 cars off the road for a year! This has not only reduced costs in terms of food and beverage purchases but also delivered massive savings related to the cost of waste disposal or recycling.
Where we have been able, we have a programme for tracking energy consumption using distribution board real time monitoring (AMR). When we do this, it is essential to monitor against a functional unit to take account of sales variations and seasonality. At NatWest as an example, we elected to use the amount of energy consumed to generate one pound of sale, this gave us a baseline that allowed us to drive efficiency and savings. In the first eleven months of the collaborative project, we have seen a 27% saving in energy consumption.
Our collaborative relationships with our suppliers deliver real benefits in delivering the highest service standards & support for chefs relevant to each client. Our supplier agreements ensure that our Premier Partners deliver real innovation to our units and the freshest of produce arrives with the lowest number of road miles to deliver it. We purchase goods and services from a large number of suppliers (79% of which are SMEs); we operate under a decentralised buying model, whereby our chefs have the autonomy to purchase from any supplier within our dual supply framework. We have a team of experienced purchasing managers who cover defined product groups and manage the supplier relationship within those groups. We pride ourselves in our long-term supplier partnerships ensuring food security, quality and consistency. We also monitor the environmental performance of our suppliers using our Supplier CSR questionnaire. We also have a purchasing analyst who assists in the selection of local suppliers who can provide sustainable, locally sourced, fresh and seasonal ingredients to our locations. Alongside this, consideration is also given to the key pillars of sustainable business. New suppliers are introduced through various sources. A formal supplier approval process is in place to ensure that these suppliers meet our expectations with regard to food safety, health & safety, quality, financial stability and that commercial aspects of their business are suitable.
New suppliers will complete our Food Contractor and Supplier Appraisal Questionnaire which includes questions on food safety, health and safety and quality. We require our suppliers to have a third-party accreditation e.g., BRC, ISO 22000, IFS, NSF, EFSIS etc. For small, local suppliers, with an annual turnover of less than £1 million, we are happy for SALSA accreditation to be in place. For a new supplier in their first year of supply to WSH, this may alternatively be provided by an audit arranged through our nominated external auditing company, the European Safety Bureau (ESB) (Now called Navitas). We also require details of product specifications to be provided so that ingredient and especially allergen details can be made available to our locations. We will in addition carry out a programme of supplier audits, depending on our risk assessment of suppliers. WSH is committed to ensuring that all dealings with our suppliers are conducted in line with the guiding principles of ethical and responsible trading. We adhere to the Ethical Trading Initiative Base Code.

As part of WSH’s ISO 14001 accredited EMS and ISO 50001 EnMS, the business operates a legal register to ensure compliance and has robust plans regarding emergency preparedness. The management board regularly reviews the systems and outcomes and is influential in developing environmental plans and strategies for the coming period.

WSH operates a robust Anti-Corruption and Bribery policy which is managed by the ethics committee and as such has risk assessed the risk of corruption when doing business.
Discussion and or text around Anti-corruption and ethical behaviour form part of all contract negotiations with clients and suppliers.
As part of WSH’s Anti-Corruption and Bribery Policy, all employees are bound to the procedures as laid out in the policy and all internal activities and procedures are bound by that policy
WSH takes its responsibility as a business to prevent slavery and human trafficking very seriously. As such, the Integrity and Ethics Committee is working closely with Supply Chain, HR, and Legal to ensure that there are sufficient policies and procedures in place and that their published statement is meaningful to the public, clients, and customers.

WSH operates a robust Anti-Corruption and Bribery policy which is managed by the ethics committee and as such has risk assessed the risk of corruption when doing business.
Discussion and or text around Anti-corruption and ethical behaviour forms part of all contract negotiations with clients and suppliers.
As part of WSH’s Anti-Corruption and Bribery Policy all employees are bound to the procedures as laid out in the policy and all internal activities and procedures are bound by that policy.
A key role of the ethics and integrity committee is to develop a training strategy for all employees to include all areas of ethics, integrity, risk, bribery, and corruption.
The Bribery Act Compliance Committee was established with the approval of the Board on 6 June 2011. The functions of the committee were to (i) meet to discuss progress against a step plan and (ii) be involved in the ongoing monitoring of anti-bribery policies and procedures. In 2015 the remit of the committee was extended to include data protection, competition law, other legal risks as well as the Bribery Act, PCI compliance, and integrity.
WSH’s business ethos is to “do the right thing” and act ethically, and with integrity. As a result, the Bribery Act Compliance Committee was re-named the Integrity and Ethics Committee and most recently the ESG Committee.

The ESG committee is engaged in measuring outcomes and is responsible for reporting to the WSH board on all issues and reports regarding ethics and integrity.