UK MODERN ANTISLAVERY ACT 2015 - LAMEX FOOD GROUP LIMITED'S STATEMENT

Our Business

Lamex Food Group Limited, headquartered in UK, is an import/export company operating in poultry, pork, fish, fruit, vegetables and honey.

Lamex has 20 offices in 15 countries and through these entities, Lamex commercial staff operate internationally to develop sustainable product outlets for their suppliers and long-term supply solutions for their customers.

Our Supply Chain

Lamex is a diverse organization with several business segments, operating in many countries, with varying economic conditions for its operations.

The majority of Lamex's activity is carried out in the EU and in the USA which we consider to be low risk in relation to Modern Slavery. Nevertheless, Lamex's supply chain is a worldwide one with subcontracting outside UK and sometimes in high-risk countries. We recognize that slavery exists worldwide, and we take a vigilant approach regardless of the location of our supply chains.

Furthermore, the relationship with many of our suppliers has been established over several years and all new contractors must be prequalified through a series of audits.

Our Risk Assessment

We assess the potential human rights risks of our supply chains by considering the country of origin where we are sourcing products from. We use our own understanding of labour rights and human rights risks in our key sourcing sectors.

As the next stage of our risk assessment, we consider the type of work being carried out (mechanical vs. manual) and the type of labour (permanent, seasonal, agency). Stakeholders and our own experience indicate that there are likely to be higher risks of slavery where there is a manual process and that the risks can be compounded where work is seasonal rather than yearend round. Seasonal work tends to rely on labour providers which cause complexity in the supply chain. Migrant or refugee workers tend to be an even higher risk because they are more likely to lack support networks, particularly where they may not be legally registered in the country of work. We also gather intelligence about emerging risks through our strong relationships with local groups and organisations. Campaigns and media investigations can also play an important role in helping us identify where some of the biggest risks lie. This combined risk and intelligence approach helps us identify where the most salient and material risks are in our supply chain.

Our Policies on slavery and human trafficking

We believe that modern slavery is a crime and a violation of fundamental human rights. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business, with policies which contribute to that goal. We are striving to ensure that child labour, coercion and harassment, health and safety, involuntary labour, discrimination, abuse of human rights, bribery practices, have no part of our supply chain. We actively encourage fair trade principles and membership of SEDEX. Our Antislavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.

We put all our efforts to conduct our business in an honest and ethical manner. Our Board of Directors has approved a new AntiSlavery Policy as of 01.05.2018 and Anti-slavery is one of the regular items in meetings of the Board of Directors.

Our High-Risk Areas

Having assessed our structures and our supply chains we believe that the areas at highest risk of modern slavery are the growing, harvesting and processing of raw materials.

Due Diligence and Monitoring

We operate a supplier policy and maintain an approved supplier list. We conduct due diligence on all suppliers before allowing them to become an approved supplier. This due diligence includes an online search to ensure that has never been convicted of offenses relating to modern slavery, and onsite audits where feasible. We are actively encouraging suppliers and customers to obtain SEDEX registration. During 2017-18, we have continued to complete a self-assessment questionnaire. Via this risk assessment, we collected data regarding our suppliers' labour standards such as working hours, wages, children and young employees, freedom of association, non-discrimination, working conditions, safe and hygienic, forced labour and human rights. This risk assessment concluded that our biggest challenge was in our purchases from Mexico, Thailand and Brazil. We carry out audits on a at least 3 years' frequency and for those suppliers that are not SEDEX registered, they are obliged to complete our ethical trading questionnaires, which cover the m base code requirements. We regularly audit our suppliers' plants and we encourage them to be SEDEX registered.

Our Attitude to Whistleblowing

We encourage our employees to report any practice which concerns them so that we can take steps to stop it or minimize it, wherever it exists in our business and our supply chain.

Informing our employees

As we believe that our employees are crucial to helping us ensure that Modern Slavery Act is adhered to throughout our operations, business and supply chain, we are providing effective awareness training to our key UK Employees, so that they will know what to do and how to report many issues of which they may become aware. We plan to extend this programme to our Group employees.

Future measures

Lamex has no tolerance of slavery and human trafficking. In 2019, we will:

- continue our mapping of our Core and Non-Core Suppliers,
- continue encouraging our suppliers to register to SEDEX,
- perform a risk assessment,
- seek to ensure that we have no high-risk suppliers within our business,
- regularly audit our suppliers' plants,
- continue providing modern slavery awareness training to employees,
- monitor our Core and Non-Core Suppliers,
- perform due diligence and monitor our suppliers (new and existing),
-adhere to the new Anti-Slavery Policy that we have in place as of 01.05.2018 to combat modern slavery and human trafficking,
- implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.

This statement covers the UK legal entities of the group including Lamex Food Group Limited,
Lamex Foods Europe Limited, Lamex Foods Europe (N.I.) Limited, and Lamex Agrifoods Limited.
The steps taken to tackle modern slavery in the business and supply chains cover all the above mentioned Lamex entities. This statement is pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes the Group's slavery and human trafficking statement for the upcoming financial year, as it has been approved by the board of directors of Lamex Food Group Limited. The statement for the previous year can be found here.

For and on the behalf of Lamex Food Group Limited

The Group's CEO
Phillip Wallace

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