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Responsible Sourcing Policy

1. INTRODUCTION

The Jamie Oliver Group Responsible Sourcing Policy (RSP) sets out our commitment to be a responsible, transparent and sustainable business. As a purpose-led business, we aim to put people and the planet before profit, whilst driving towards our ambition of revolutionising what we eat, one meal at a time, making it healthier, more sustainable, and fairer for all.

We build long lasting relationships with our global suppliers and partners and are fully committed to respecting and protecting workers throughout our value chain. We want to collectively work with our suppliers and partners to ensure human rights are safeguarded and that our impact on the environment is continuously measured and mitigated.

Our policy sets out our commitments to measuring, monitoring and mitigating human rights and sustainability impacts across our own operations and value chain. It also sets out our expectations of our suppliers and partners, including but not limited to; Franchise Restaurants, Licensed Products and Food, Food and Beverages Suppliers, Own Operations, and Third Party Services.

The principles covered within this policy align with the United Nations 17 Sustainable Development Goals (SDGs), the Ethical Trading Initiative (ETI) Base Code, the United Nations Guiding Principles on Business and Human Rights (UNGPs), Universal Declaration of Human Rights (UNHD), and conventions defined by The International Labour Organization (ILO). This Responsible Sourcing Policy and any supplementary policies provide minimum standards that should be exceeded where possible.

OUR PURPOSE

At The Jamie Oliver Group, celebrating healthy lifestyles and a healthy planet underpins everything we do, every day. As a business we take our responsibility to reducing our environmental impact seriously, whilst also ensuring we continue to support and work with local communities to drive social impact. Our ambition is to be Net Zero by 2050, reducing our carbon footprint in line with science, whilst also ensuring any Jamie Oliver related product, process, or food and drink, is sustainably and transparently sourced, with zero waste to landfill. We support the local community and provide opportunities for disadvantaged people. We seek to eliminate modern slavery and promote high human rights standards across our complete supply chain

This policy compliments other standards and frameworks, such as our Food Standards, Restaurants Due Diligence Framework, Sustainability & Social Impact Strategy, and B Corp Certification. Please do ensure you have read through/complied with these where applicable.

2. Human Rights

Our suppliers and partners are expected to establish effective management systems for implementing the below human rights commitments as well as maintain records demonstrating compliance. Suppliers and partners must also comply with all relevant national and other applicable laws and are encouraged to exceed the standards set within this document to drive continuous improvements within their business and supply chain related to human rights due diligence across their business operations and supply chains.

1. Employment is freely chosen

1.1 There is no forced, bonded or involuntary prison labour.

1.2 Workers are not required to lodge "deposits" or their identity papers with their employer and are free to leave their employer after reasonable notice.

2. Freedom of association and the right to collective bargaining are respected

2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.

2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.

2.3 Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.

2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.


3. Working conditions are safe and hygienic

3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

3.2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.

3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.

3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

3.5 The company observing the code shall assign responsibility for health and safety to a senior management representative.

4. Child labour shall not be used

4.1 There shall be no new recruitment of child labour.

4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; “child” and “child labour” being defined in the appendix.

4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.

4.4 These policies and procedures shall conform to the provisions of the relevant ILO standards.

5. Living wages are paid

5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.

5.2 All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

6. Working hours are not excessive

6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below, whichever affords the greater protection for workers. Sub-clauses 6.2 to 6.6 are based on international labour standards.

6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed national laws or international standards.

6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment.

6.4 The total hours worked in any seven day period shall not exceed 60 hours, except where covered by clause 6.5 below.

6.5 Working hours may exceed 60 hours in any seven day period only in exceptional circumstances where all of the following are met:

  • this is allowed by national law;
  • this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce;
  • appropriate safeguards are taken to protect the workers’ health and safety;
  • the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.

6.6 Workers shall be provided with at least one day off in every seven day period or, where allowed by national law, two days off in every 14 day period.

7. No discrimination is practised

7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

8. Regular employment is provided

8.1 To every extent possible work performed must be on the basis of recognised employment relationships established through national law and practice.

8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

9. No harsh or inhumane treatment is allowed

9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

10. Anti-slavery and human trafficking due diligence

10.1 You must ensure effective due diligence processes are continuously carried out in relation to tackling modern slavery. This includes conducting annual staff training to identify and prevent human trafficking, as well as ensuring the availability of a whistleblowing hotline or secure communication channel for employees.

10.2 All supply chains and business operations must be regularly risk assessed and managed in relation to modern slavery, and any high-risk suppliers and business operations audited.

10.3 Any breaches to the Modern Slavery Act UK, or equivalent, must be communicated immediately to your Jamie Oliver representative (within 48 hours of the incident occurring or having been brought to attention) and an action plan formed to effectively address and remediate the issues in a timely manner.

DEFINITIONS

Child: Any person less than 15 years of age unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply. If however, local minimum age law is set at 14 years of age in accordance with developing country exceptions under ILO Convention No. 138, the lower will apply.

Young Person: Any worker over the age of a child as defined above and under the age of 18.

Child Labour: Any work by a child or young person younger than the age(s) specified in the above definitions, which does not comply with the provisions of the relevant ILO standards, and any work that is likely to be hazardous or to interfere with the child’s or young person’s education, or to be harmful to the child’s or young person’s health or physical, mental, spiritual, moral or social development.

3. Environmental Commitments

Our suppliers and partners are expected to establish effective management systems for implementing the below environmental commitments as well as maintain records demonstrating compliance. Suppliers and partners must also comply with all relevant national and other applicable laws and are encouraged to exceed the standards set within this document to drive continuous improvements within their business and supply chain related to environmental due diligence across their business operations and supply chains.

1. Environmental Management Systems

1.1 An environmental management system is in place, and updated periodically, to identify and take practical steps to reduce issues related to water, wastewater, energy, gas and waste management.

1.2 Targets and projects are in place to track, monitor and reduce consumption of energy, wastewater, water and gas and waste management, whilst increasing sustainable solutions (i.e. switching to 100% renewable energy where possible).

1.3 Due diligence policies and processes relevant to national and international sourcing requirements are in place and are implemented as required by applicable laws and regulations, and as advised or requested by The Jamie Oliver Group prior to purchase, or as otherwise agreed in contract.

1.4 All required data is shared with The Jamie Oliver Group where needed to allow us to comply with reporting and disclosure requirements of any relevant human rights, environmental protection and supply chain due diligence laws.

1.5 Partners and Suppliers will acquire, and file all permits, and waste receipts required by local and national law.

1.6 A system is in place to ensure any hazardous substances are continuously measured, recorded, and tracked to ensure all chemicals used comply with applicable global legislation, whilst taking steps to reduce the use of hazardous substances and, where possible, replacing them with safer alternatives

1.7 Where further chemical or hazardous substance testing or documentation is required, suppliers will provide evidence in the form of safety tests reports, declaration of conformities, declaration of holding technical documentation etc. when and as requested

1.8 Controls are in place to ensure any operations do not negatively impact access to safe water for the community.

1.9 Practices and procedures are in place to measure, record, and mitigate any air emissions generated by operations. Where appropriate, suppliers will treat all emissions to air before they are released if they have the potential to adversely affect human health and/or the environment.

1.10 A system is in place to ensure the safe handling, movement, storage, recycling, reuse, or disposal of waste, and suppliers will set targets to reduce solid waste production and start a programme to achieve the reduction.

2. Climate Action

2.1 There is a process in place to effectively measure and actively reduce greenhouse gas emissions and align with recognised international strategies to measure, reduce and report on Scope 1,2, and 3 emissions, in line with the emissions reduction trajectory of the Paris Agreement and the GHG Protocol Corporate Accounting and Reporting Standard or similar (i.e., Science Based Targets Initiative).

2.2 Upon request, suppliers shall share annual carbon emissions of the products or services provided to The Jamie Oliver Group.

3. Raw Materials, Food Standards & Packaging

3.1 Suppliers will maximise efficiency of non-renewable material use to avoid unnecessary consumption of resources, as well as set targets and projects to increase the use of renewable, sustainable and responsibly-sourced materials.

3.2 There is a system in place to trace raw materials, including material sources and chemicals, back to where they were manufactured, ensuring all raw materials used are compliant with both local law and relevant global requirements.

3.3 Where packaging materials are used, these will be designed to be fully reusable, recyclable or compostable wherever possible, with a preference for using certified or recycled materials for packaging first.

3.4 There is a system in place to track packaging material data including but not limited to; weight, product type and material. This includes whether the packaging is made from recycled content, or has the ability to be reused, recycled or composted in your local area or country.

3.4 The preferred approach is to ensure that no non-hazardous waste is sent to landfill sites or incineration without energy recovery.

3.5 Where relevant, all suppliers must meet Jamie Oliver’s Food Standards, including the purchase of higher-welfare meat, cage-free eggs and sustainable seafood.

3.6 For suppliers where food waste is material, a commitment is made to reduce food waste as much as possible, in direct operations, and setting a target where possible.

3.7 Any partners or suppliers that develop and design buildings must aim to collaborate with the Jamie Oliver group to utilise more sustainable design and construction processes and materials.

4. Biodiversity, Deforestation and Nature

4.1 Suppliers of agricultural materials identify and implement plans to manage and mitigate biodiversity and ecosystem risks, working with the industry and us to implement and identify positive nature based solutions.

4.2 Stakeholders across the value chain are engaged to improve biodiversity and ecosystem performance within and beyond site boundaries.

4.3 There is an effective due diligence process to ensure that any operations do not directly contribute to or are actively involved in any form of deforestation or loss of biodiversity.

4.4 Suppliers will conduct due diligence and assure that all their products comply with all relevant applicable international, national, federal, state or local laws and regulations.

4.5 All suppliers will respect the rights of indigenous communities and the local populations in the places where they operate as well as in their supply chains. Suppliers apply the UN principle of free, prior and informed consent.

5. Standards and Processes

5.1 Partners and Suppliers will complete The Jamie Oliver Group’s Supplier Due Diligence Questionnaire’ as and when requested.

5.2 A review of sustainability practices and environmental management systems is undertaken regularly with support from experts to determine if appropriate policies and procedures are in place and effective.

5.3 You will ensure that there are effective strategies and processes in place across your value chain to drive sustainable commitments and reduce negative environmental impacts.

4. Our Commitment

At Jamie Oliver, we recognise that responsible sourcing is a shared responsibility between buyers and suppliers. Our approach is rooted in collaboration, transparency, and continuous improvement to uphold human rights and ethical standards across our supply chain.

1. Buyer Responsibilities & Commitments

1.1 As buyers, we are committed to responsible purchasing practices that support fair and ethical working conditions throughout our supply chain.

1.2 We strive to provide reasonable lead times, stable order volumes, and transparent payment terms to support suppliers in maintaining ethical labour conditions.

1.3 When discontinuing a supplier relationship, we are committed to engaging in a responsible exit process, mitigating negative impacts on workers and communities.

1.4 We work alongside our suppliers to identify risks, share best practices, and strengthen human rights due diligence through ongoing dialogue and capacity-building efforts.

2. Joint Commitment to Human Rights Due Diligence

2.1 We expect suppliers to actively assess and address human rights risks, with our support where possible, rather than making blanket guarantees about conditions in their operations.

2.2 We foster an environment where suppliers can openly share challenges and work with us to implement effective solutions.

2.3 In cases of human rights violations, our shared focus is on providing remediation and support for affected workers, rather than solely addressing legal or reputational concerns for the buyer or supplier.

By embedding these principles into our sourcing decisions, we aim to drive meaningful improvements in human rights and ethical business practices across our supply chain.

Collectively working together

We are committed to working collaboratively with our partners and suppliers to achieve the standards as confirmed throughout this policy, whilst also recognising that we have a responsibility to uphold and safeguard our own practices, working across the industry to enable continuous improvement and collaboration when it comes to responsible sourcing.

We strongly encourage collaboration through partnerships and stakeholder engagement (within the bounds of competition law) to drive best practice, developing robust benchmarking and standards, and enabling new technology and innovations across sustainability and human rights solutions. We also ask, that where needed, you will openly provide any relevant data, audits and or information of how your company is mitigating any human rights issues or measuring and reducing environmental impacts within your value chain and business operations.

Please sign below to confirm you understand and will comply with our Responsible Sourcing Policy:

Supplier partner name:

Name and position of signatory:

Signature:

Date:

Should you require any further details about our Responsible Sourcing Supplier Policy, or our wider Sustainability and Social Impact, please contact: [email protected]