A Global Commitment

In 2013 we set a global target that we would, where reasonably possible, physically audit all of our main raw material suppliers by end 2015.  For all raw materials we would complete a quality and food safety risk assessment based on the inherent risk posed by the raw material, an investigation into the quality controls of the manufacturer and the amount and spread of the raw material use in our product range.  This builds on our commitment in 2012 to retain samples of all our key raw materials (where feasible), requirement for certificates of analysis and confirmatory in-house analysis of raw materials. We will report on our progress annually.

Quality

The quality of our raw materials is critical to the quality of our product and thereby the reputation of the Devro brand. We have always made careful checks of our raw material supply through questionnaire, certificates of analysis, in-house confirmatory analysis, retained samples and where necessary physical site audits, especially for major ingredients and for new suppliers. In 2013 we had a review of our current practices around the group to harmonise our approach to assuring the quality and integrity of our raw material supply. As a consequence, we agreed all current major raw material suppliers should be physically audited and subsequently audited on a regular basis, the timing being dependent on the amount of raw material used, its use across our product range and the rating the supplier received following our audit. We also agreed new suppliers should also have a physical audit prior to accepting them as a supplier.

We set an ambitious target for completion of end 2015 and have made significant progress at our sites, especially our main plants (Scotland, Czech Republic, Australia and China). Due to the major investment in a new manufacturing site in the US we have physically audited only a handful of key raw materials, however, we are committed to significantly increase our progress on physical audits from mid-2016.  Some of our raw material use is too small for the supplier to permit an audit or the assessed risk too small to justify a realistic need so we rely on certificates of analysis, sample retention and analysis.

Vulnerability Assessment

This year we completed vulnerability assessments for all our raw materials from manufacture, through delivery to our site at our Scotland sites and are looking to expand this across the group.

Responsible sourcing

Our responsible sourcing programme has been evolving since 2015 to include initially some aspects of environmental responsibility and consideration of expanding to social responsibility requirements to ensure our products are sourced and manufactured in a fair, ethical and environmentally responsible manner.

Environmental:

As well as our own commitment to the environment, we request all our raw materials suppliers to provide information on their environmental policies, including whether they have a formal recognised Environmental Management System such as ISO 14000, whether they are audited to that standard by a 3rd party and, if so, they provide a copy of the said certificate. We also request specific information on environmental impacts (GHG, CO2, Water use, resource utilisation, waste and pollution targets and performance) in our questionnaires and are investigating how best to include them in our physical audits of suppliers (as above), where we discuss any non-conformance and agreed actions.  We are also part of the UK Food & Drink Federation and Scottish Food Drink Federation where we lead on Environmental improvement projects across the UK food industry.

Social

With increasing regulation globally around labour practices, we now include questions on social practices into our initial supplier assessments and are developing our approach to ensuring we include social assessments into our supplier requirements. We currently request responses to labour practices around child or forced labour, equal opportunities, non-discrimination, freedom of association, labour practices (such as avoidance of excessive hours, minimum wage) and health and safety standards. Following a risk assessment our supply chain is not particularly susceptible to potential poor labour conditions, as they are from large complex production processes or larger reputable suppliers. Completion of our physical audits of all our major raw material suppliers where feasible will help with this initial assessment.

All the above parameters influence our purchasing decisions around the group.

We will continuously review our progress based on external developments, on-going risk assessment and audit findings.