Rowse Honey Limited Modern Slavery Statement

2024/2025 MODERN SLAVERY STATEMENT MADE BY ROWSE HONEY LIMITED (on behalf of itself & its subsidiaries)

1. Introduction

This is a statement made by Rowse Honey Limited on behalf of itself and its subsidiary companies, Kettle Foods Ltd and Valeo Confectionery Limited who trade together under the name Valeo Foods UK (“Valeo Foods UK” “we” “our” “us”). It is published in accordance with the provisions of the Modern Slavery Act 2015 and covers the period from 1 April 2024 to 31 March 2025.

2. Our Structure

Valeo Foods UK is part of the Valeo Foods Group which is based in Dublin, the Republic of Ireland. We are a food manufacturer operating in the honey, snacks and confectionery sectors.

Parent Company:
Rowse Honey Limited’s (“Rowse”) a private limited company incorporated and registered in England and Wales with company number 01024018 whose registered office is 9 Perseverance Works, Kingsland Road, London, E2 8DD with its principal place of business at Moreton Avenue, Wallingford, Oxfordshire, OX10 9DE. Rowse blends and packs bottled honey, maple & agave syrups, fruit curds and sauces. In addition to supplying supermarkets for consumer purchase, Rowse also provides bulk orders to restaurants, caterers, wholesale and manufacturing companies. Rowse employs circa 310 employees.

Rowse’s Subsidiaries:
Kettle Foods Ltd (“KFL”) a private limited company incorporated and registered in England and Wales with company number 2238320 whose registered office is 38 Barnard Road, Bowthorpe Employment Area, Norwich, Norfolk, NR5 9JP.
KFL is a snack manufacturer of potato chips, tortilla chips, vegetable chips, rice cakes and popcorn. KFL employs circa 400 employees.


Valeo Confectionery Limited (“VCL”) a private limited company incorporated and registered in England and Wales with company number 02025064 whose registered office is 38 Barnard Road, Bowthorpe, Norwich, Norfolk, NR5 9JP. VCL manufactures sugar and chocolate confectionery. VCL employs circa 1200 employees.

3. Our Supply Chains
Valeo Foods UK EntityNumber of Active SuppliersSitesTypes of Raw Materials SourcedOrigin of Raw Materials SourcedProducts Produced
RowseCirca 310WallingfordHoney, maple, agave syrups, chocolate, fruit juice concentrates, frozen fruits, dairy products, egg liquid, flavourings liquid and packagingUK, China, EU, Argentina, Brazil, New Zealand, Mexico, Turkey, Uruguay, Vietnam, Canada, Australia, Egypt, India, Isreal, Mexico, Peru, Thailand & USAHoney, natural syrups, curds & sauces
KFLCirca 500NorwichPotatoes, popcorn kernels, seasoning & packagingUK & EUPotato Chips & popcorn
GatesheadMasa flour, seasoning & packagingEUTortillas & rice cakes
VCLCirca 1150Pontefract, Blackpool, Blackburn, Cleckheaton, YorkSugar, chocolate and packagingUK & EUSugar and chocolate confectionery

KFL sources its vegetable chips from its co-manufacturing partner, Yellow Chips B.V. (a company owned by the Valeo Foods Group) in the EU. The root vegetables for this product are sourced from reputable sources.

At the date of this statement:

  • All Valeo Foods UK suppliers are either registered on SEDEX or assessed using an ethical audit;
  • KFL’s UK potato suppliers maintain high ethical practices and sources its labour force, including seasonal workers, from approved agencies. Each UK supplier is contractually obliged to be a member of The Assured Produce Scheme and shall have passed its annual audit with one hundred percent (100%) compliance and are audited to the satisfaction of the Red Tractor or Global Gap Audits; and
  • Valeo Foods UK has no issues with any of its suppliers that should be disclosed pursuant to the Modern Slavery Act 2015.
4. Our Policies & Memberships

Our commitment to ensuring no Modern Slavery or human trafficking in any part of our business is reflected in our policies and procedures including but not limited to the following:

NumberDOCUMENT/PROCEDURE/REQUIREMENTDETAILS
1Valeo Foods Group Supplier Code of ConductThis Code covers matters including without limitation: human and labour rights, health and safety and ethical business practices
2Employee Code of ConductThis policy sets out our internal standards, expectations and accountability. It incorporates an understanding of the risks of modern slavery and human trafficking within our business and supply chains. Employees who breach our Code of Conduct and any related policies may be subject to disciplinary proceedings.
3Ethical Working & Whistle Blowing ProcedureThe Ethical Working Policy outlines our commitment to taking action to minimise the risk of modern slavery within our business and supply chains and encourages appropriate working conditions amongst workers within our field of influence. The Whistleblowing Policy enables employees, suppliers and third parties to raise any concerns about working practices that they believe breach the law or company policies. The helpline is advertised on our premises and is available 24/7.
4SEDEX MembershipWe are an active member of SEDEX (Supplier Ethical Data Exchange) a not-for-profit membership organisation and is required to undertake regular, semi-announced audits based on the ETI (Ethical Trade Initiative) Base Code which is founded on the conventions of the International Labour Organisation and its internationally recognised code of labour practice. The Ethical Trade Initiative Code of Conduct sets out the standards we expect our suppliers, regardless of the legal requirement under the MSA and recognises our commitment to the Ethical Trade Initiative (ETI base code) and compliance to the ILO conventions.

Governance:

Responsibility for the preparation of our Modern Slavery Statement sits with our HR team and is approved by our board of directors. The Procurement, Technical, and Operations teams are responsible for carrying out the implementation of all applicable policies and procedures.

5. Due Diligence

Our due diligence procedures include the following:

  • We use the globally recognised platform SEDEX to assess business practices within our own operation and we require all processors to become members and complete the SEDEX SAQ to ensure we have visibility of our supply chain. We also issue an ethical self-assessment questionnaire to our suppliers for completion which incorporates all aspects of the ETI base code. These sources of information enable us to risk assess our supply base. During the period covered by this statement, we have not been made aware of any actual or suspected cases of modern slavery in our business or supply chain.
  • We work collaboratively with our direct customers to ensure we fully comply with their ethical codes of conduct, and we participate in a bi-yearly independent audited SEDEX Members Ethical Trading Audit (SMETA). At the date of this Statement, we have no outstanding non-conformances.
  • The risk of using agency staff at our sites, is mitigated by using only specific, approved and reputable employment agencies. All labour agencies are registered members of the Gangmaster Licensing Authority.

Risk Assessment and Management:

We have identified migrant workers, minority groups and contract/agency/temporary workers as potentially vulnerable to the risks of modern slavery. Our HR Team is trained to be mindful of this and the following indicators of concern when dealing with workers who fall into one of the above categories:-

  • A worker without their own passport;
  • A worker with little or no control over their finances;
  • A worker who doesn’t have access to a bank account.

Any concerns are immediately referred to the Employee Relations Team may contact the police, home office or any other body as appropriate.

We also have several pre-emptive measures in place including:

  • We do not accept any communication through a third party on behalf of an employee;
  • We do not pay an employee’s salary into a third-party bank account;
  • We will not raise a cheque in another person’s name even if requested by the employee;
  • We do not prevent membership of a union or representative body; and
  • We have in place easily accessible grievance procedures available to all employee and workers.

Supplier Relationships:

The Procurement Director/Divisional Head of Procurement and Head of Technical are responsible for maintaining an approved supply base. If there are concerns over performance relating to modern slavery, these individuals will decide whether to continue to do business with the relevant supplier and take any further appropriate action which may include (but is not limited to) the following:

  • Reporting concerns to the appropriate authorities;
  • More frequent audits; and
  • Termination of the supplier relationship.

Audit Programme:

Audits are principally conducted by the Technical and Procurement teams.

During the period covered by this statement, the Rowse team has audited a total of 33 suppliers and the KFL & VCL teams have audited a total of 13 suppliers.

As part of our SEDEX membership, and our conditions of supply with several of our key customers, we are required to undertake regular semi-announced SEDEX Members Ethical Trade Audits (SMETA). These audits are undertaken by our HR Team.

All suppliers are required to complete our Supplier Questionnaire and Risk Assessment every 2 years.

As a SEDEX member ourselves, we are also subject to SEDEX audits. For Rowse, a SEMTA audit was carried out during the period April 2024 and March 2025. KFL is subject to a SEMTA audit every 2 years, the last audit was carried out in 2023. VCL is subject to the SEMTA audit programme and will undergo an audit within the appropriate window.

Key Performance Indicators:

To monitor the effectiveness of the steps that we have taken to combat modern slavery and human trafficking in our business and its supply chains, we used the following key performance indicators (“KPI’s”) during the period covered by this statement:

No.KPIPeriod coveredPercentage achieved or narrative on compliance
1Evaluate our current due diligence and onboarding process including its effectiveness to ensure it remains fit for purpose. Implementing any changes if required.April 2024 to March 2025We are constantly evaluating the due diligence checks we undertake respecting our suppliers and our onboarding process. Any improvements are implemented as required. It is therefore not possible to affix a percentage achieved to these actions.
2All departments to review its policies and procedures, updating where necessary, providing copies to the Legal Department in order to maintain the central record.April 2024 to March 2025We undertake regular reviews of our policies and procedures and implement any changes as required and/or recommended. This is an ongoing process, and it is not possible to affix a percentage achieved.
3Our Supplier Code of Conduct will be included in the Risk Assessment of all new supplier and such suppliers will be asked to agree to comply with its provisions.April 2024 to March 2025All new contracts contain an obligation on our suppliers to comply with our Supplier Code of Conduct. No percentage figure is available.
4All employees received annual modern slavery training.April 2024 to March 202540% completed.

6. Training

We conduct training and assessment as part of the induction into the organisation for all new employees via e-learning with a test to demonstrate understanding of the concepts taken at the conclusion of the session with employees expected to gain 80% and above. Additionally, annual refresher training for all office-based employees has been rolled out via the company’s intranet and annual toolbox talks are conducted for all production employees.

7. Going Forwards

We will continue to work with our suppliers to identify and tackle hidden labour exploitation. However, we recognise that there is still much to do. During the next financial year we will:

No.KPIHow KPI will be measured
1Valeo Foods UK will roll out its Stronger Together initiative which is a training programme designed to help employers, recruiters and suppliers to recognise, prevent and respond to risks of modern slavery, forced labour and hidden exploitation in the workplace and supply chains. Training for all employees on the initiative will be rolled out on a staged basis starting with the senior leadership team of each site (level 1), followed by line managers and team leaders at each site (level 2) and then the wider workforce (level 3). During the financial year 2025/2026, the aim is to ensure training is completed for all level 1 employees.Percentage of level 1 employees who have completed the training.
2Annual audit of labour providers.Percentage of providers audited.
3Suppliers who supply ingredients and packaging to Valeo Foods UK employing more than thirty (30) people at their manufacturing site/s must complete SEDEX/SAQ to one hundred percent (100%) annually.Valeo Foods UK’s aim is that 100% of its relevant suppliers are SEDEX complaint and it will create a process to help achieve this.

8. Publication

Our Modern Slavery Statements are published:

  1. https://rowsehoney.co.uk/; https://kettlefoods.co.uk/modern-slavery-statement/, & https://www.valeofoods.co.uk/.
  2. The UK government’s Modern Statement Registry at: https://modern-slavery-statement-registry.service.gov.uk/.
9. Conclusion

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st March 2025. It was adopted by the board on 29 September 2025.

Kevin Moore, Chief Executive Officer, Valeo Foods UK

Date: 30 September 2025

Previous Modern Slavery Statements

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