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; we have now largely achieved this. In 2014 we added a requirement to include environmental questions in these audits and in 2015 added social questions regarding labour practices. For all our raw materials we also completed a quality and food safety vulnerability risk assessment based on the inherent risk posed by the raw material, the quality controls of the manufacturer and our usage of the raw material across our product range. We will continue to report on our progress annually.
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 and a policy of sample retention for all our raw materials (when feasible). Now we also conduct physical site audits for all our major ingredients and for new suppliers. In addition, we also take into consideration any third party certification held by the supplier, and in particular where that is to Global Food Safety Initiative recognised standards. Subsequent Devro audits are conducted depending on the quantity of raw material used, its use across our product range, its inherent risk and the rating the supplier received following a previous audit. This approach is now established at all our main production plants (Scotland, Czech Republic, Australia and China) and is being rolled out at our other facilities in The Netherlands and the US. Some of our raw material use is too low a risk to justify an audit in which cases we rely on certificates of analysis, sample retention and analysis and supplier questionnaire.
Vulnerability assessments have become part of regulatory and external standard requirements globally. We now have a global vulnerability assessment system, developed in Scotland, which is being used across our sites as needed. This covers all our raw materials from manufacture to delivery to our sites.
Our responsible sourcing programme has been evolving since 2015 initially including aspects of environmental responsibility and now expanded to social responsibility requirements to ensure our products are sourced and manufactured in a fair, ethical and environmentally responsible manner. Currently, these are assessed primarily through a questionnaire and confirmation at audit.
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 developing our approach as to how best to verify their position 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.
With increasing regulation globally around labour practices, specifically California and the UK, we now include questions on social practices into our initial supplier assessments and questionnaires. 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 we determined it is not particularly susceptible to potential poor labour conditions, as they are from large complex production processes or larger reputable suppliers. This element is included in our physical audits of all our major raw material suppliers, as a means to support and verify this assessment.
All the above findings influence our procurement decisions around the group.
|No. Audits (percentage)|
|2014||48||28 (58%)||0 (0%)|
|2015||72||35 (49%)||5 (7%)|
|2016||31||14 (45%)||10 (32%)|
|2017||56||50 (89%)||48 (86%)|
|2018||42||41 (98%)||36 (86%)|
|2019||54||52 (96%)||52 (96%)|
We will continuously review our progress based on external developments, on-going risk assessment and audit findings.