Modern Slavery and Human Trafficking Statement for financial year ending 2017



This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Big Bear Confectionery Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. This statement will continue to evolve as progress is made on the implementation of the BBCL Ethical Initiative, along with our commitment to challenge the use of forced, trafficked or child labour within our own organisation and those of our suppliers.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The company is committed to creating a zero tolerance approach to any form of modern slavery both internally and throughout the supply chain we use, to produce our product. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

This statement relates to actions, activities and agreed intentions ending financial year December 2017.


Organisational Structure

BBCL is a wholly owned subsidiary of the Valeo Group, who’s Head Office is based in Ireland. BBCL produces some of the nation’s favourite confectionery brands, within the Food Manufacturing Sector, manufacturing high quality products at our production facilities in the UK. We employ in excess of 400 employees within the UK operation, with a turnover of £45 million


Areas of Operation and Supply

Big Bear Confectionery operate and supply into the following regions of the world :

Americas          Europe             Australasia        Asia          Middle East        East Asia

Our supply chain consists of raw material ingredient producers, logistics providers, energy producers, professional services including legal, financial, audit, consultant specialists and labour supply, property management, technology, equipment and service providers.

We are currently developing the assessment process which will be used to assess the activities of our critical supply chain, in order to ensure that they do not pose a risk in relation to modern slavery or human trafficking. Once agreed, this will be communicated both internally and externally to our supply chain along with any required guidance. We will continue to engage and collaborate with our supply chain until evidence is secured that they are fully compliant with regulations and ethical trading requirements of our customers


High-risk activities

We are currently undertaking a risk mapping exercise of BBCL’s high risk areas and documenting the data that supports decisions made regarding the risk. Internal processes will be analysed and an action plan will be developed under the BBCL Ethical Initiative

The critical areas of supply will also be mapped and risk assessed. This process includes a number of levels of data gathering including questionnaires, face to face discussions and desk top audit. Risk criteria used will include the global slavery index, spend relationship, geographical location and activity. New suppliers will also be subject to an assessment to ascertain level of risk prior to use



The Senior Executive are responsible for approval of all ethical related policies within the company

The HR Director will sign all ethical related statements on behalf of the Senior Team, and will hold responsibility for the Ethical Initiative which includes the development of standards, policies, processes and associated action plan, that will enable BBCL to meet its obligations under Modern Slavery and Human Rights requirements. The HR Director will also investigate any suspected infringements of slavery or human rights related violations, within the company

The Procurement Manager is responsible for developing the necessary policies and processes to ensure that BBCL only use suppliers who adhere to or are working towards our ethical standards. The Procurement Manager will also investigate any suspected infringements of slavery or human rights related violations, within the supply chain

Information, advice and guidance will be supplied to suppliers to help them respond to the identified slavery and human trafficking risks.


Relevant policies

BBCL has developed the following policies that describe its approach and intentions, for the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations, as well as ensuring that we are conducting business in an ethical and transparent manner:

  • Human Rights Policy
  • Anti Modern Slavery Policy
  • Child and Young Persons Policy
  • Freedom for Employee Representation
  • Ethical Policy
  • Respect at Work Policy
  • Equality Policy
  • Whistleblowing Policy
  • Bribery and Corruption Policy

Ethical Reporting processes are included in the relevant policies specified above and encourage any member of staff to report any known or suspected breach of our ethical standards including slavery, human trafficking, forced or child labour, as well as wider human rights-related issues. It guarantees that any issue can be raised in confidence.

It is the intention to continue to develop any relevant policies and processes highlighted by risk assessment activities during the implementation phase of the Ethical Initiative.


Due Diligence


We have over 400 people engaged in Big Bear Confectionery and we apply the highest possible standards in the recruitment and employment of our people.

As well as ensuring that the policies set out in the Employee Handbook are complied with, we ensure that:

  • all legal obligations are complied within the recruitment and on-boarding process with a particular focus on an individual’s right to work
  • we conduct an appropriate level of due diligence on our prospective employees prior to them joining the company, including a robust selection process and taking up employment references; and
  • we recruit, promote and develop our people on the grounds of merit and capability alone and promote a diverse workforce and an inclusive culture through our actions and policies

All staff are expected to comply with our Policies, Code of Conduct and any relevant laws and standards applicable to us.

Big Bear Confectionery conforms to the living wage for its employees.



Big Bear Confectionery are currently undergoing a mapping exercise and conducting an impact assessment of its supply chain; once completed, a due diligence process will be implemented to ensure that our suppliers remain compliant with the appropriate laws and meet our ethical standards as a customer.


Performance Indicators

To ensure that the Ethical Initiative is progressing in a timely manner, a plan has been developed which includes a number of actions which are monitored. This plan will provide the baseline measurement of achievement and will be progressed by the HR Director. The plan includes, but is not limited to :

  • Impact Assessment – Human Rights & Modern Slavery
  • Roles & Responsibilities definition
  • Communication Plan
  • Training – Internal
  • Mapping Exercise – Internal and Suppliers
  • Assessment of Supply Chain
  • Supplier Processes (including New Suppliers)
  • Supply Chain Support (Awareness Raising)

In addition, we will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

  • No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.


Board approval

This statement has been approved by BBCL’s Board of Directors, who will review and update it annually.

Director’s name: Alison Bettac
Director’s Title : HR Director
On behalf of BBCLs Board of Directors

Date: 12th December 2017

Download Modern Slavery and Human Trafficking Statement (PDF, 214 kb)