1 INTRODUCTION FROM THE CHIEF EXECUTIVE OFFICER

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. 

Our commitments:

To act ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

To ensure transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same standards.

To improve our practices to combat slavery and human trafficking. KellyDeli Company Limited, as the holding company of the ‘KellyDeli Group’ (defined below), is taking steps to ensure compliance with legislation relating to Anti-Slavery and Human trafficking, as well as doing our utmost to go above and beyond these requirements. Although we are in our infancy as a company and in our efforts to combat these unfortunate trends, we have taken, and continue to take, these positive actions. 

2 OUR STRUCTURE

We are a global food retail and restaurant company. We are the parent company of the KellyDeli subsidiaries throughout Europe, including: France, Belgium, Spain, Italy, United Kingdom, Germany, the Netherlands Sweden, Denmark and Portugal (“KellyDeli Group”). The Group has over 522 employees throughout Europe.

3 OUR BUSINESS

KellyDeli is an innovative food company committed to bringing the best of Asia to the world, through Asian-inspired brands and over 900 kiosks across Europe. KellyDeli is a franchisor supporting a network of independent kiosk owners preparing and offering for sale Asian inspired food in supermarkets, hypermarkets and similar.

4 OUR SUPPLY CHAINS

Our supply chains include an estimated 45 suppliers throughout Europe who supply products to each of our kiosks. These suppliers range from large scale cross-country suppliers to local small-scale suppliers.

5 OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

Our Human Rights Policy and supplier questionnaire reflects our commitment to acting ethically and with integrity all our business relationships and to implementing and promoting effective systems and controls. In 2020, we will review and update our sourcing policies to improve further our requirements.

6 DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of our initiative to identify and mitigate risk we are in the process of implementing within our entire organisation both whistleblowing and due diligence service providers. We aim to:

• Identify and assess potential risk areas in our supply chains.

• Mitigate the risk of slavery and human trafficking occurring in our supply chains.

• Monitor potential risk areas in our supply chains; and 

• Protect whistle blowers.

7 TRAINING

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will be providing training to our employees in 2020. 

We are committed to respecting and protecting human rights of all who come into contact with our operations, including employees, partners and supply chain workers. We accept our responsibility to support transparency, to find and resolve problems; to regularly review our business practices; and to collaborate with others to protect the rights of workers, particularly those who are most vulnerable to abuses such as modern slavery.  

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes KellyDeli Group’s slavery and human trafficking statement for the financial year ending December 2019. It was approved by the board on 28/10/2020.

Silvano Delnegro

SIGNATURE

CHIEF EXECUTIVE OFFICER

KellyDeli Company Limited