OUR 2024 MODERN SLAVERY STATEMENT
Introduction
At Bloom & Wild Group, we want to be the destination for making life a little more thoughtful and beautiful. And we pride ourselves on doing business thoughtfully, so we take great care at all stages of our supply chain. We know that modern slavery and human trafficking still persist in the UK and worldwide, so we’ve made an ongoing commitment to make sure that everyone involved in our business and supply chain is treated fairly. This statement outlines the steps we take to identify and mitigate the risks of modern slavery and human trafficking in its operations. This statement relates to actions and activities during the financial year 1 April 2024 to 31 March 2025.
About us
We’re a UK based, online flower delivery company. Founded in 2013, we created the first bouquet that could be posted through the letterbox. Today, our range now includes letterbox and hand-tied flowers, along with plants, Christmas trees and other gifting categories. We ship across the UK, Ireland, Germany and Austria We also own the international brands bloomon and Bergamotte which operate in Germany, UK, Netherlands, Denmark, Belgium and France
We have a head office in London, UK and a production warehouse in Nuneaton, UK. We also have a bloomon office in Amsterdam, The Netherlands, a warehouse in Amstelveen, The Netherlands, a Bergamotte office in Paris, France and a warehouse in Clichy, France. Most of our workforce is directly employed by us, but we also use contractors and temporary staff, particularly around peak gifting seasons like Christmas, Valentine’s Day and Mother’s Day.
To ensure that everything we sell is of the highest quality, our suppliers are based in various locations around the world. The majority of our suppliers are flower growers. The majority of our flowers come from Europe and Africa, particularly the Netherlands and Kenya. We take this diverse approach so that we can - as far as possible - reduce our carbon footprint and avoid carbon intensive activities like using heated greenhouses in winter. For more on this, see our sustainability reports. Depending on the geography and sector our suppliers operate in, we have various requirements to monitor social sustainability risks.
Our policies
We continually review and update our policies. We have policies in place that are intended to provide clear guidelines and rules on how we tackle modern slavery. These policies are aimed internally for our employees as well as externally towards our suppliers.
Please find below our policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
Whistleblowing - speak up policy
We encourage all our employees, customers and other business partners to report any concerns related to our direct activities, or our supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our speak up procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use one of our speak up channels.
Employee code of ethics
Our code makes clear to employees the actions and behaviour expected of them when representing the organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
Supplier code of conduct
We ask our suppliers to either acknowledge our Supplier Code of Conduct or to share their own version with at least the same standards, which will be reviewed by us. This asserts our intentions to combat modern slavery and our suppliers’ obligations to do the same. Specifically, the code of conduct includes sections on: No Child Labour, No Discrimination, No Precarious Employment, Fair Remuneration and Living Wage, Decent Working Hours, Occupation Health and Safety and more.
Agency workers policy
We use only specified, reputable employment agencies to find temporary additions to our team and always verify the practices of any new agency we are using before accepting workers from that agency.
Equal opportunities policy
Our equal opportunities policy sets out the duties of the Company and all its staff and representatives concerning Diversity, Inclusion and Equal Opportunities. It covers how we ensure equal opportunities, and eliminate discrimination, in our terms of employment and our recruitment and selection processes. It provides information on what would be considered discrimination, how employees can escalate this and how the business will respond.
Our Due Diligence Processes
As a part of our due diligence process, we formulate an annual sustainability strategy. This strategy is informed by stakeholder consultations and input from experts, to identify our overall sustainability risks. As a part of this, we review what parts of our operational model, supply chains, and partners are most at risk of modern slavery violations.
We have undertaken an assessment whereby we have considered the following factors:
Risk of the activity
Materiality of this activity / size of our business
Scope of control
In other words: we look to prioritise the highest risk areas, with our biggest business volumes or number of people involved, particularly in areas where we have a direct business relationship.
For us, this means we have a number of focus areas:
Flower sourcing Some of our flowers come from countries with elevated risk. We are informed by frameworks and expert organisations on this, such as SEDEX, ILAB of the Bureau of International Labor Affairs, the Floriculture Sustainability Initiative (FSI) and others.
In order to address this, we require social certifications with a high degree of credibility (as designated by FSI) of our flower growers in higher risk countries. We monitor this every month, to understand what activities they are undertaking and what certifications or processes to certify are in place.
Production We use labour agencies to support our fluctuating people needs in our production facilities. Due to the pandemic crisis in 2020, there was a shift in consumer shopping behaviours, leading to a heightened preference for swiftly delivered online goods. Consequently, the warehousing sector has emerged as a fast growing industry, witnessing an unprecedented demand for its services. This surge in demand has created increased pressure to hire workers in a sector characterised by intricate supply chains and intense seasonal peaks, consequently elevating the risk of labour exploitation.
To address potential risks, all agency suppliers are required to have sufficient practices to mitigate the risk of modern slavery that align with the country specific requirements which include policies, certifications (e.g. GLAA for the UK) and effective response plans. To ensure adequate knowledge and awareness about modern slavery, we train our workers where relevant, including agency workers, to identify the signs of modern slavery and to inform them on how they can report any suspicions. General due diligence with key suppliers We use our code of conduct, due diligence questionnaire and more extensive modern slavery questionnaire during supplier onboarding and engagement.
Areas of highest risk
We’ve carried out - and documented - a risk assessment on slavery, and wider human rights abuse, in our supply chain.
The areas of highest risk we have identified are:
Overseas flower growers Some of our flowers are grown overseas. And some in economically developing countries. While the benefits of this include increased employment opportunities and financial investment, we’re aware that the risks of human trafficking in these areas could also be higher. Where possible, we select suppliers who go above and beyond the minimum requirements, and our key Kenyan grower partners are accredited in line with FSI requirements. We are proud to work closely with these grower partners, who prioritise the wellbeing of their workers. Among other things, they support gender equality through equality committees, and offer ethical awareness training, subsidised food and canteen facilities for staff and health awareness training. Various members of our senior leadership team, including our CEO and COO, have also visited our main growers overseas. And we’re in constant conversation with the senior leadership teams of these growers in order to understand their recruitment and employment practices and how they are mitigating any associated risks.
Contractors and temporary staff The majority of our workforce are directly employed. But we, and our suppliers, frequently use contractors and temporary staff. When contractors and temporary staff are sourced through agencies (rather than directly by ourselves), we’ll only use agencies with practices that are consistent with our sustainable supplier policy (more details below). We also try to mitigate the risk by being actively present at our suppliers’ premises during peak times when use of agency workers is highest - and regularly outside of peak times - along with having active dialogue with the workforce of our suppliers.
Overseas manufacturers Some of our hardware (vases, plant pots etc) are manufactured overseas, so it’s harder for us to have full visibility of such suppliers’ recruitment and employment practices. We are working on a process whereby in such cases we require a recognised accreditation and/or carry out our own due diligence by interviewing suppliers, researching them, and assessing audit reports.
Supply Chain Requirements
We continually assess the risk of human trafficking and slavery within our supply chain and will not enter into business with any suppliers who are knowingly involved in such activities. This commitment is communicated to all employees, partners, suppliers and contractors. And we also aim to cascade our ethical standards throughout our supply chains.
Our pre-qualification questionnaire for suppliers helps us understand their employment and recruitment practices - and their own risk assessment methodologies - as well as making sure we understand the full supply chain from end to end. We continue to risk assess each of our partners on an ongoing basis or when the respective risk profile changes.
At a minimum, we require our suppliers to adopt the following principles:
Employment must be freely chosen
Child labour must not be used
Staff must be paid legal minimum wages
Working conditions must be safe and hygienic
The Employer Pays Principle (no worker should pay for a job)
We’re now putting these principles in contract with any new key supplier. And we’re currently in the process of redrafting our contracts with existing suppliers too. We reserve the right to audit and review the controls of our suppliers (including unannounced visits) and to work with them to address and resolve any issues we find.
We work to have as much dialogue and interaction about these issues with the senior leadership teams of our suppliers and also their employees, which helps us better understand and identify any risk ourselves.
Lastly, we have a Modern Slavery Steering Committee, which meets regularly to consider how we can work with our suppliers to mitigate any risks in our supply chain.
Training
We adhere to all relevant employment legislation when it comes to hiring, onboarding and training our employees. On top of this, we always work to support the mental and physical wellbeing - and professional development - of our team.
We’ve developed an Equal Opportunities & Diversity policy which guides our People Team (and all employees) on the avoidance of discrimination at work. We also give mandatory training on diversity and inclusion, which covers conscious inclusion, race and ethnicity and LGBTQ+ topics. We also have policies in place to protect employees at Bloom & Wild Group throughout their employment. And all employees have access to our policies online, which include a code of ethics, anti-harassment and bullying, anti-bribery and corruption and speak up whistleblowing policies. All employees experience a rigorous induction process which covers all of these points and ensures they have a clear understanding of what's expected of them when representing the company from the very beginning of their employment.
We have implemented a robust training program specifically tailored for the front-line workforce, recognising their crucial role and heightened exposure to potential risks. Our training encompasses key aspects such as awareness, identification, and prevention of modern slavery, and equipping employees with the knowledge to respond effectively to suspicious activities. Moreover, we emphasise the importance of taking immediate action if slavery or human trafficking is suspected. Employees are trained on the initial steps to be taken, including reporting concerns through designated channels and not attempting to intervene directly where there might be a risk to safety. Furthermore, our training addresses the escalation process for potential slavery or human trafficking issues, detailing how employees can promptly and securely escalate concerns to the relevant parties within the organisation.
Members of the People Team as well as our most senior managers based in our warehouse locations and those responsible for some of our larger supplier relationships, have all undergone specialised training in collaboration with Stronger Together, ensuring they possess the knowledge and skills necessary to lead by example and foster a culture of vigilance within their teams. Through targeted training sessions, visual posters around the warehouses, and continuous education, our workforce is equipped with the tools to identify and report potential instances of modern slavery. Collectively we are committed to building a resilient front-line that actively safeguards against modern slavery risks.
Reporting Concerns
If you have a concern, report these to us without delay. You can find our speak up channels in our Whistleblower Policy. It’s always best to voice any concerns before they turn into anything more serious, or even a violation. These speak up channels are open to our employees, agency workers, suppliers, customers and anyone else to use. If you need advice or are unsure about whether to report something, please connect with speakup@bloomandwild.com. Review and Evaluation We will regularly review and evaluate the effectiveness of its measures to ensure compliance with the Modern Slavery Act.
Approval and Review This policy was approved by our CEO Aron Gelbard. It will be reviewed annually and updated as necessary.
