Since 1997 when we opened our first store in Chelsea, itsu has always strived to provide beautiful food to its customers that is delicious, healthy and most importantly, ethically sourced. We work with a diverse and far reaching supply chain, and this gives us the flexibility to react to the ever-changing demands of our customers, the market we operate in and allows us to provide our customers with the most beautiful Asian-inspired eating experience possible. People are fundamental to the way we operate as a business and our success couldn’t be achieved without the teams working in our shops through to the suppliers producing our raw materials. Upholding their human rights is an essential part of our operation. We know that as a growing business the challenges of modern slavery are complex and can affect all businesses big and small. We are committed and passionate about the eradication of unacceptable and unethical practices and we are working tirelessly to ensure that this is a cornerstone of our business and underpins the way we do business. This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015.
Our Business and Supply Chain
We work with suppliers of all sizes to source over 180 ingredients, from small farms in the UK to multinational operators. We also strive to ensure that our fresh products such as chicken, fish and fresh produce are sourced from within the UK when possible. Due to seasonality and macro-impacts on availability, this is not always possible. itsu has developed a strong and longstanding relationship with a number of suppliers that have been on the journey with us from our very first store in 1997, right through to the 70+ shops we now operate from. These suppliers are highly trusted and our business wouldn’t be achieving such success without them. New suppliers are also encouraged to develop a strong sense of partnership with itsu and this is done through mutual trust and respect. Ensuring the integrity of this supply chain is vital to our business and we are constantly working on ways to prevent, identify and react to the risks of modern slavery.
As a growing business, we are in the process of reviewing our policies in order to make sure that our suppliers understand our expectations with regards to human rights across all areas of our supply chain. Our internal itsu operational HR policies are robust and readily available to all staff and form part of the itsu induction conducted at our dedicated Academy based in London. itsu actively encourages employees to report any activity that they believe is in breach of company standards, and a 24-hour confidential helpline is available to report any issues.
Due Diligence & Identification of risk
itsu is fortunate to work with several suppliers that are the leading manufacturers within their product categories. Many of these suppliers already have robust Due Diligence measures in place. As part of the ongoing improvement to all itsu’s policies and standards, we are ensuring that we have a more comprehensive approach to risk assessment and identification of risk. We visit all food suppliers within our supply chain to assess them from a food safety perspective, but also an ethical standpoint to ensure they are a suitable partner for itsu. Given our trading & supply chain geography, we are committed to understanding all aspects of these often-complex supply chains. Any suppliers that do not meet our high standards are removed from our supplier portfolio and not revisited until we feel confident that they meet our high expectations of a supplier to itsu.
Next Steps [to ensure we remain ahead]
itsu is committed not only to creating beautiful food but also that we do business in a beautifully responsible way. We will ensure that we have the correct, suitable and robust policies in place to reduce the risks of modern slavery in our supply chain and operations. Our key next steps to tackle and minimise risk are as follows; 1. Review our current ethical trading policies and update accordingly. 2. Review and risk assess our operation and supply chains and review these on a regular basis. 3. Ensure that all new suppliers into the itsu supply chain meet our minimum ethical expectations. 4. Further invest in training for our Senior Leaders and all relevant head-office and store colleagues. 5. Roll out a new quality assurance framework across to ensure ethical standards are adhered to across our stores, our partner run stores and global supply chain. 6. Engaging with like-minded, best-in-class operators in our sector and other industries to share and learn best practice across all ethical trading standards. This statement was prepared by the itsu modern slavery working group and approved by our Executive Senior Management team and Founder.
itsu [grocery] ltd recognises and understands the responsibility that all businesses have to drive an improvement in human rights and to prevent and mitigate the risks of modern slavery. itsu [grocery] is committed to ensuring we are doing everything possible to eliminate modern slavery risks and will work collaboratively with our suppliers to ensure they support us on this journey. This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015 and CORE Coalition.
1. Organisational Structure and supply chains
Ensuring the integrity of our supply chains is vital to our business and we are constantly working on ways to prevent, identify and react to the risks of modern slavery. We work with an extensive and diverse range of suppliers spanning multiple continents. Over years of collaborative working with our suppliers, we have created strong working relationships. We work closely with our suppliers in food manufacturing, packaging and storage and distribution and have full traceability of our supply chains. As an agent and broker, we do not own any of these sites ourselves, however, we require all of these suppliers to be members of Sedex, abide by local laws and act in accordance with our ‘Supplier Human Rights Policy’. We also expect high standards from our service suppliers, and we therefore ensure that we work with credible and reputable companies across our consultancy an services.
2. Governance Structure and Strategy for Modern Slavery:
At itsu [grocery], we take pride in sourcing the best products and services from suppliers around the world in a socially and environmentally responsible way. Our commitment to responsible sourcing starts with the itsu [grocery] team, ensuring they have the relevant training and support to drive adherence to our Supplier Human Rights Policy within our supply chain. The Management Team is ultimately accountable for human rights within our business. The Procurement Manager and Sustainability Advisor work to embed skills, knowledge, and processes across the business. All relevant teams receive training on Modern Slavery when they start employment and on an annual basis. (see Training section below). This includes all members of the team who are responsible for human rights relating to the business activities that are carried out by itsu [grocery].
3. Policies in relation to slavery and human trafficking
itsu [grocery] has developed a ‘Supplier Human Rights Policy’ to outline our expectation for suppliers on human rights. This is based on the ETI Base Code which is itself founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice. It contains a specific requirement for suppliers to identify and tackle cases of modern slavery and applies to food manufacturing sites, food co-packing sites, storage and distribution providers and packaging suppliers. itsu [grocery] also has internal policies which apply to our employees in head office, including the Whistle-Blowing Procedure, Diversity and Inclusion Policy, Employee Code of Conduct, Disciplinary Policy, Grievance Policy, and Reporting Wrongdoing Policy. Additionally, we have 4 trained mental health first aiders who are available to support any employees within the business.
4. Assessment of Modern Slavery Risk Within Our Supply Chain
itsu [grocery] uses the results of the Sedex (the Supplier Ethical Data Exchange), Self-Assessment Questionnaires (SAQs) completed by suppliers, and the Sedex Radar Risk Assessment tool to undertake risk assessments of our supply base. itsu [grocery] uses Sedex Advance to manage our
supplier’s responsible sourcing information, which enables our suppliers to share their information in a consistent and confidential way. The use of the Sedex Radar Risk Assessment allows more targeted actions to be taken to manage risk. Additionally, the Sustainability Advisor creates a quarterly report with any audit or risk rating updates and an overview of any new suppliers that have been linked with in the past quarter. This is shared with the relevant members of the team.
All itsu [grocery] suppliers must complete a Sustainability SAQ, this includes a section of questions on ethical factors, which is risk-assessed for each supplier. These suppliers are then categorised as high, medium, or low risk. To minimise risk of Modern Slavery further, we ensure that no products or ingredients are sourced from Xinjiang, China.
5. Due Diligence process
itsu group is an AB member of Sedex, which means we have visibility of sustainability performance in our business and supply chain and are part of a global network of like-minded leaders in ESG. itsu [grocery] requires all food and packaging manufactures, co-packers and storage and distribution suppliers to be members of Sedex and all suppliers must review their SAQ’s annually to ensure all responsible sourcing data is up to date. Any high-risk suppliers are required to have a third-party unannounced SMETA audit every 3 years. SMETA audits are conducted by qualified, approved auditors and the audit covers a site’s labour and health and safety policies as well as environmental performance and ethics. itsu [grocery] conducts regular supplier visits. The purpose of these visits include: initial introductory visits, relationship building, food safety audits, first production and trials to understand the operations of the supplier. In the past couple of years, some visits to our international suppliers have been difficult due to COVID-19. However, so far in 2023 we have been able to complete 34 supplier visits across the UK, Europe and Asia. We aim to work in partnership with our suppliers to deliver on our responsible sourcing commitments. We encourage them to be open and transparent about their risks, challenges, and issues so we can provide support and guidance where needed. itsu [grocery] has identified some raw materials which are high risk for environmental and social issues, requiring additional third-party certification. All palm oil used in our products must be RSPO certified, and all cocoa ingredients used in our products are Rainforest Alliance certified. This allows for transparency of our raw materials, and support for farmers and workers on eliminating forced labour, child labour, and improving gender equality.
6. KPIs to measure effectiveness of steps being taken
We use the following Key Performance Indicators to measure the effectiveness of our approach to modern slavery:
By November 2024:
• itsu [grocery] will complete an annual webinar to update suppliers on ESG topics, including human rights.
• 100% of itsu [grocery] approved food and packaging suppliers will have registered on Sedex and completed their SAQ.
• All itsu [grocery] suppliers rated as high risk on Sedex will have scheduled or completed a SMETA audit in the last 3 years.
• itsu [grocery] will train all internal teams who work directly with suppliers on how to identify human rights risks, including forced labour, and how to report any issues identified.
• itsu [grocery] will add a section to technical audit checklist to include human rights questions, including forced labour.
7. Training on modern slavery and trafficking
We recognise the importance of training, both our internal teams and our suppliers, to ensure that they can identify human rights risks, and have the tools to act if any concerns are raised. In June 2023, we hosted a webinar for all our suppliers and trained them on our new Supplier Human
Rights Policy, allowing time for any questions from our suppliers. This was to ensure our suppliers felt they are supported, had time to raise any concerns, and to reassure them that open communication is particularly encouraged surrounding human rights. itsu [grocery] also ran an internal training course on our Supplier Human Rights Policy, for all the
members of our teams who are involved directly in working with suppliers and conducting supplier visits. It was focused on what to look out for when visiting and communicating with suppliers, and how to raise any concerns.
8. Effective action taken to address modern slavery
All itsu [grocery] employees are encouraged to speak up if they are aware of wrongdoing. The processes for this are laid out in our Grievance Policy and Reporting Wrongdoing Policy. itsu [grocery] is committed to ensuring that there are multiple channels for employees to confidentially raise concerns with the knowledge that effective systems are in place for investigation and resolution. itsu [grocery] has a dedicated phone number and email address for suppliers to report any human rights malpractice that may occur. Any information will be treated confidentially and promptly investigated. We have had no cases of forced labour or child labour raised through the whistleblowing procedure in 2022.
9. Next steps
We are aware that our work is not yet done, and we strive to keep making improvements year on year. In the future, we aim to:
1. Create a responsible sourcing working group, comprising of a multi-functional team.
2. Strengthen our due diligence processes on high-risk supply chains through the use of SMETA audits.
3. Deepen our engagement on modern slavery with suppliers through visits and further training.
4. Include our service suppliers in our training webinars and Sedex requirements.
This statement was approved by the itsu [grocery] management team on 11th December 2023.