To our stakeholders:
I am pleased to confirm that BaxterStorey 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,
John Bennett
Co-CEO, BaxterStorey

BaxterStorey fully supports the Universal Declaration of Human Rights and is a proud supporter of the UN Global Compact.
BaxterStorey is supported through robust board approved policy’s including Harassment Policy, Equality & Dignity Policy and an overarching HR policy.
BaxterStorey’s Supply Chain policy states the company’s commitment to human rights in the supply chain specifically the Ethical Trading Initiative Base Code. This Code contains nine clauses that reflect the most relevant international standards with respect to labour practices (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
BaxterStorey has a large and diverse supply chain, sourcing primarily UK produce. It is BaxterStorey’s intention to develop reporting strategies to review risk associated with human rights to at least tier two supplier level during 2017.
As part of the wider WSH family BaxterStorey is a key part of the ethics and integrity committee developing our strategy towards the requirements of the Modern Slavery Act and ongoing work on bribery and corruption. A position is to go beyond compliance.

Our Modern Slavery Statement is below:

Our Business
BaxterStorey Limited (‘BaxterStorey’) 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 BaxterStorey, we take our responsibility as a business to prevent slavery and human trafficking extremely seriously. We have a zero tolerance approach to all forms of slavery both within our own operations and across our supply chain. This statement outlines the steps which we have taken to date, together with our continuing efforts to ensure that slavery and human trafficking cannot take place in any part of our supply chain and/or business.
Our Supply Chain
We are immensely proud of our supply chain and family of suppliers who allow each of our operating locations to source products and services to meet individual client and customer needs. 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. It is incredibly diverse and provides the platform from which our businesses can grow, develop and continue to provide fantastic food and service.
Steps Taken By BaxterStorey To Date:

1. Integrity and Ethics Committee
Our parent, WSH, has an Integrity and Ethics Committee (the “Committee”) made up of senior members and directors of our businesses. This Committee meets on a regular basis and oversees the processes which we have been putting and we will put in place to ensure there is no slavery or human trafficking in our business and/or our supply chain.

2. Ethical Trading Initiative Base Code
BaxterStorey respects and adheres to internationally recognised human rights principles and in particular the Ethical Trading Initiative Base Code. This Code contains the following nine clauses which are founded on the conventions of the International Labour Organisation and are an internationally recognised code of labour practice:
•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
BaxterStorey is committed to ensuring that all of its dealings with suppliers are conducted in line with such ethical and responsible trading requirements.

3. Due Diligence on New Suppliers
We require our new suppliers to go through a detailed on-boarding process. Suppliers are expected to update the information provided during the on-boarding process on an annual basis for further review and approval by the supply chain team. This annual review process is to be extended to all existing suppliers to ensure that our due diligence remains up to date and relevant.
As part of our supplier on-boarding process, all new suppliers are expected to acknowledge and commit to comply with:
a) our Responsible Sourcing and Ethical Trading Policy which sets out our standards in relation to ethical trading; and
b) our Anti-Slavery and Human Trafficking Supplier Sign-Off which relates more specifically to the Modern Slavery Act.
These commitments have to be made as part of the Self Audit Questionnaire which formally records and captures the supplier’s key details and capabilities.
We maintain regular dialogue with our suppliers to ensure that they understand and implement our high standards and they continue to comply with local legislation and regulations. Our on-boarding process also allows us to determine which suppliers are most at risk for responsible sourcing challenges and, for those high risk suppliers, we will prioritise a site audit. Following a site audit, we will notify the supplier of any remedial action required. 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.
Our target is to ensure that 100% of our suppliers have agreed to our Responsible Sourcing and Ethical Trading Policy and our Anti-Slavery and Human Trafficking Supplier Sign-Off. Whilst we would hope to have completed this work by the end of December 2017, we anticipate a number of challenges within our supply chain partners around communication and understanding of the Modern Slavery Act that may extend this deadline. We see it as our responsibility to work with our suppliers to achieve 100% compliance, and if non-compliance or refusal to adhere is presented, we will work to find suitable, compliant, alternatives.

4. Training
We recognise that to achieve the successful implementation of any anti-slavery and anti-human trafficking policy it is vital to train and raise awareness with those employees who have the potential to come in to contact with suppliers on a regular basis. Our focus will be to continue to help the business to identify any potential risks or failures thereby driving ever greater compliance with our high standards. To date, we have focused our training on our purchasing and supply chain teams. Through 2017, we plan to extend this training to the wider business.

We see the implementation, measurement and raising of awareness and standards across our business and supplier base as being an ongoing project. We will continue to draw on industry best practice and evolve our supply chain in the best way possible to ensure that we are continually assessing the effectiveness of preventing slavery and human trafficking.

Approval

This statement has been approved by BaxterStorey’s Board of Directors. BaxterStorey intends to review and update this statement as necessary on an annual basis.
STEPS TO BE TAKEN IN FUTURE
BaxterStorey Modern Slavery Act Implementation plan
Issue Statement on MSA
Extend Ethical and Respsonsible Sourcing policy to no-core suppliers
Review and amend contract terms and conditions with suppliers
Complete desktop risk assessment
Extend risk assessments from desktop exercise to physical/unannounced audits
Aim to achieve visibility over deep tiers of Supply Chain
Develop ethical audit program encompassing Human Rights, sourcing principles and Supply Chain transparency
Developing best practice encompassing industry codes of conduct (CIPS) and audit standard (SEDEX)
2017
2027
Implementation Timelines
BAXTERSTOREY ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT 2016/17
Andy Milner
WSH Procurement and Supply Chain Director
Amanda Underwood
WSH Human Resources Director
Alastair Storey
Chairman
BaxterStorey Limited
John Bennett
Co-CEO BaxterStorey Limited
Noel Mahoney
Co-CEO
BaxterStorey Limited

All BaxterStorey staff in client locations, mobile workers or at the support offices are afforded safe and sanitary work place facilities. Support office facilities are provided by BaxterStorey and location facilities are client owned.
All BaxterStorey staff are protected from workplace harassment, including physical, verbal, sexual or psychological harassment abuse or threats via robust and enforced policy.
Within BaxterStorey policy there is allowance for ‘whistle blowing’ and is explicit in that there will be no recriminations following such reports as long as they are justified and accurate.
BaxterStorey take all expected measures to prevent injury or harm coming to any of their employees or stakeholders resulting from any business activities or associated operations
BaxterStorey is fully accepting of the Modern Slavery act and is currently ensuring full compliance throughout the supply chain

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.

BaxterStorey 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
BaxterStorey operates under the remit of robust labour related policy including: harassment policy, equality & dignity policy, maternity, paternity, flexible working opportunity etc.
All written policies state employee rights and responsibilities and their compensation and benefits.
BaxterStorey’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

BaxterStorey operates under the remit of a robust HR and associated labour related policy structure.
BaxterStorey trains all employees on HR related matter 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 is safeguarded through the companies H&S policies which include a certified occupational H&S management system to ISO 18001.
Labour rights and policy are managed via the HR Director and then ultimately CEO and Chairman.

BaxterStorey operates a robust employee engagement and review programme based on a formal annual appraisal system framework.
BaxterStorey do not formally monitor ethnicity or diversity, there are however voluntary questions at engagement time however these are not collated currently
BaxterStorey operates a rigorous grievance procedure as laid out in policy
BaxterStorey 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 accredited EMS including a site specific review of aspects and impacts that are focussed 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 effect 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.
BaxterStorey has also recently achieved accreditation for its energy management system to ISO 50001 which is the business’ chosen route to compliance to ESOS and also provides a framework for energy efficiency across the business and adds value to the client proposition

Mike Hanson is BaxterStorey’s Head of Sustainable Business and is responsible for all aspects of environmental management as part of the wider sustainability remit.
Mike has 8 years’ experience in the field 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 950 sites we are now segregating food waste by plate waste, production waste and spoilage waste and reporting through our on-line 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 an 39.41% reduction in food waste arising, saving over £7 million since the start of the projects of the project so far equating to a carbon saving of 37,659 tonnes CO2e based on full life cycle footprint, in real terms the equivalent of taking 10,000 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 RBS 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 SME); 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 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). 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.
BaxterStorey 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 BaxterStorey’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 review the systems and outcomes and is influential in developing environmental plans and strategies for the coming period.

BaxterStorey 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 BaxterStorey’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
BaxterStorey take their 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 is sufficient policies and procedures in place and that there published statement is meaningful to the public, clients and customers.

BaxterStorey 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 BaxterStorey’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.
BaxterStorey’s business ethos is to “do the right thing” and act ethically, with integrity. As a result the Bribery Act Compliance Committee was re-named as the Integrity and Ethics Committee

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