10/11/2020
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 2020.

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.

BAXTERSTOREY ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT
FOR FINANCIAL YEAR ENDING 28TH DECEMBER 2018

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 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. This statement outlines the steps we have taken to date, and are continuing to take, 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 and their role in enabling 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 business can grow, develop and continue to provide fantastic food and service.

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.

Since 2019, we have continued our commitment to ensure that our business and our supply chain have taken appropriate and effective steps towards preventing modern slavery and human trafficking.

1. Governance

Our Integrity and Ethics Committee, which is responsible for overseeing the processes we are putting in place to prevent modern slavery or human trafficking from taking place in our business and/or supply chain, is fully embedded in our business. The Committee has continued to meet on a regular basis with modern slavery (and discussions around it) being a permanent agenda item.

2. Ethical Trading Initiative Base Code

BaxterStorey remains committed to ensuring that its dealings with its own employees, and with its suppliers, are conducted ethically and responsibly. BaxterStorey 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

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. We ensure that these standards are met through a supplier on-boarding process, supplier auditing and maintaining a regular dialogue with our suppliers (as described in more detail below).

Supplier on-boarding:

All new suppliers go through a detailed on-boarding process. Suppliers are then expected to update the information they provided during the on-boarding process on an annual basis for further review and approval by our supply chain team. As part of that on-boarding process, suppliers must 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.

Throughout 2019, we updated our standard supplier terms and conditions to include appropriate antislavery and human trafficking obligations and these were also rolled out across our supply chain. In addition, we extended our on-boarding process to existing suppliers to ensure that our due diligence on them remains up-to-date, relevant and appropriate.

Our ultimate target is to get to a position where we can 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.

Supplier auditing:

Our on-boarding 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. Following a site audit, we notify the supplier of any remedial action we believe is required. Throughout 2019, the continued development of our auditing systems, increase in number of audits conducted, and creation of bespoke audits for different types of goods and services supplied to our business, has meant that we have a more robust method for identifying and mitigating ethical challenges in our supply chain. We have also carried out an initial high-level desktop risk assessment of modern slavery across our supplier base.

In 2019, we plan to take the following steps:

(a) carry out tailored assessments for those suppliers identified as having a higher proportion of
low-paid, unskilled labour, particularly where this is likely to be transient or agency labour;
(b) review those suppliers who are likely to use sub-contracted services and labour;
(c) identify our goods and services which have the highest spend as well as those suppliers who
are business-critical;
(d) consider which suppliers are supplying from, and/or goods or services are ultimately sourced
from, countries with a high risk of modern slavery; and
(e) undertake full traceability mapping on key products and suppliers (identified from the above
steps), assessing the modern slavery risk for such products and suppliers.

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. We see it as our responsibility to work with our suppliers to achieve 100% compliance, and if noncompliance or refusal to adhere is presented, we will work to find suitable, compliant alternatives.

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 with those employees who have the potential to come in to 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. To date, we moved towards this by training on our purchasing and supply chain teams and our Integrity and Ethics Committee. In 2019, we created an ethical trade and modern slavery module (both online and paper-based). This training is intended to help the business to understand our expectations of ethical trade, to recognise the signs of modern slavery and unethical working practices and to know how
to report any concerns. We plan to roll-out this module to other functions beyond those responsible for procurement throughout 2020.

Other policies specifically relating to employees and other stakeholders human rights include but are not limited to:

Whistle blowing
Transgender
Shared Parental Leave
Flexible Working
Diversity & Inclusion
Dignity at Work
Dependent Care & Emergency Leave
Adoption Policy

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 on-line.

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.

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 implementation of its Human Resources Policy, the Company intends:

• To recruit and select those people who have the appropriate skills, aptitudes 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 company wide 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

All written policies state employee rights and responsibilities and their compensation and benefits. 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’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 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 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 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 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. In 2017 BaxterStorey as part of the wider WSH family committed to purchase 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. BaxterStorey is now committed t mapping the business to the UN sustainable development goals and has join UKSSD as a network partner to drive the SDGs. BaxterStorey and the wider WSH is currently developing a strategy in partnership with the Carbon Trust to develop a Science Based Target approach to carbon reduction.

Mike Hanson is BaxterStorey’s Director of Sustainability and is responsible for all aspects of environmental management as part of the wider sustainability remit.
Mike has 14 years’ 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 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 41% reduction in food waste arising, saving over £11 million since the start of the projects of the project so far equating to a carbon saving of 58,000 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 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.