Modern Slavery Statement

SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR

TATA CONSUMER PRODUCTS GB LIMITED &

TATA CONSUMER PRODUCTS UK GROUP LIMITED

FOR THE FINANCIAL YEAR ENDING 31 MARCH 2024

BUSINESS STRUCTURE AND SUPPLY CHAINS

This Slavery and Human Trafficking Statement (“Statement”) for the financial year ending 31st March 2024 is being made by Tata Consumer Products GB Limited (Tata Consumer Products GB / “we” / “GB”) and its immediate UK parent holding company Tata Consumer Products UK Group Limited (“UK Group”) pursuant to Section 54(1) of the Modern Slavery Act 2015 (MSA). GB and UK Group are both part of the Tata Consumer Products Group (“TCP”). This Statement includes information about the business of GB and UK Group that is only relevant since 31st March 2024.

Tata Consumer Products GB is a British beverage manufacturer and food distributor, and this Statement sets out the steps both we and UK Group are taking to combat any risks of slavery and human trafficking taking place within our and UK Group’s operations and supply chains.

Our Brands

In the UK we have three core tea brands: Tetley, teapigs and Good Earth which are sold in the UK and other markets around the world.

In line with our ‘For Better’ philosophy all our products are sourced responsibly. Each year our buying and blending team source close to 32 million kilogrammes of tea from more than 350 different suppliers. Africa is our most significant sourcing region, with around 60% of our teas sourced from Kenya and 15% from Malawi, the rest is sourced from different countries around the world, including India. Once raw tea has been sourced, tea is brought from origin to market via a tightly controlled supply chain including shipping, blending, packing, transporting, and supplying product to supermarkets and other sales channels.

UK Group’s US subsidiary, Tata Consumer Products US, Inc. (“TCP US”), operates a coffee business under another TCP core brand, Eight O’Clock Coffee, with the coffee procured via intermediary brokers from many different countries of origin around the world, from Vietnam to Brazil.

In addition to these core brands, GB sells tea under an Indian tea brand Tata Tea which is part of our authentic World Foods Portfolio. It is produced and exported from India by our ultimate Indian parent company, Tata Consumer Products Limited (“TCPL”), along with Tata Salt, Tata Sampann spices and pulses, Tata Raasa Indian foods and Joyfull Millets cereal, a new range tailored for western markets.

The majority of our teas are packed at our UK factory in the North-East of England. Raw teas for this factory are imported into the Port of Tyne, where we have a dedicated warehouse, and exported from there to multiple customers around the world, including to customers of UK Group’s Canadian, Australian, and US subsidiaries. Tata Tea is produced at TCPL’s factory in Cochin and is also sent to customers around the world, including to our UK customers, and to customers of UK Group’s US, Canadian and Australian subsidiaries. UK Group’s Bangladeshi subsidiary, Tata Consumer Products Bangladesh Limited, buys all its tea for domestic sales from the Chittagong Tea Auction. GB also utilises two co-packers, Halssen & Lyon in Hamburg, Germany, packing teapigs, and Multeafil in Poland for Good Earth. Joyfull Millets are produced at TCPL’s production facility in India close to Bangalore in Bidadi, and Raasa products are produced at TCPL’s facility in India in Sri City.

The location of our staff is split between our tea factory in the North-East of England and our offices in Greenford, and Hanwell in Greater London, plus some staff are home based.

OUR POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING

Tata Business and Human Rights Policy

The Tata Consumer Products Group has affirmed its commitment to all human rights within and outside the workplace through the establishment of a formal Business and Human Rights Policy aligned with the principles contained in the Universal Declaration of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work and the United Nations’ Guiding Principles on Business and Human Rights.

All suppliers must adhere with TCP’s Business and Human Rights Policy at all times and comply with its salient human rights including no child or forced labour; providing equal opportunity and fair wages; providing health and safety, clean air and water; considering human rights in the value chain, rights of indigenous people; migrant labour; and persons with disabilities, observing the right to privacy, and having no regard for contemporary forms of slavery. A copy of the policy can be found at https://www.tataconsumer.com/sites/g/files/gfwrlq316/files/2021-10/business-and-human-rights-policy.pdf.

UK Group’s cross-functional Business and Human Rights Working Group works to ensure we put the Policy into practice.

TRAINING ON SLAVERY AND HUMAN TRAFFICKING

Part of the Business and Human Rights Working Group’s objectives are to provide training to support awareness and understanding of those risks through the business, and the development, monitoring and review of risk assessments and audits in relation to our suppliers.

We seek to continue to educate our staff responsible for tea buying and blending and supply chain management on slavery and human trafficking. The objectives of our training programme encompass:

providing colleagues with an understanding on the scope of the human trafficking and slavery issue;
training colleagues on how to identify slavery in the supply chain;
providing examples of red flags; and
reminding colleagues of our internal reporting procedures.

Members of our Tea Buying and Blending team completed training during the year up to 31st March 2024.

OUR DUE DILIGENCE PROCESSES

Tata Code of Conduct

At the commencement of their employment, all Tata employees are required to commit to and sign the Tata Code of Conduct which reflects our commitment to act ethically and with integrity in all business relationships.

The Code of Conduct specifically states: “We shall respect the human rights and dignity of all our stakeholders. It further states: “We do not employ children at our workplaces. We do not use forced labor in any form.”

Tata carries out appropriate due diligence on all employees prior to them commencing their roles with the business. This includes checking where applicable that each employee has the appropriate right to work documentation and is of the minimum legal age to work.

Ethics and Compliance Helpline and Whistle-blower Policy

Tata recognises and respects each employee’s right to freedom of association, including the right to join trade unions. Tata encourages its employees, customers, suppliers and other stakeholders to raise concerns or make disclosures when they become aware of any actual or potential violation of the Tata Code of Conduct, policies or law, including any human rights abuses. We also encourage reporting of any event (actual or potential) of misconduct that is not reflective of our values and principles. Avenues available for raising concerns include:

immediate line manager or Human Resources team
designated ethics officers within Tata
through our confidential and independent Ethics and Compliance Helpline and Whistle-blower Policy

If any such issues were reported, Tata would undertake an immediate and thorough investigation into the concerns raised. If the investigation confirmed the concerns to be true, we would take firm action to address the issues and protect those affected. For the period covered by this Statement, Tata has not received any reports of forced, compulsory, slave, trafficked or bonded labour in our operations through its whistleblowing procedure.

Supplier Code of Conduct ("SCOC")

For our major tea suppliers this requirement is documented in our Procurement policy which the business must adhere to. Under this, suppliers commit to ensuring that working conditions for their employees are safe, healthy, and hygienic, including unrestricted access to drinking water and toilet facilities.

Suppliers must implement appropriate controls, safety procedures, and preventative maintenance and protocols for providing appropriate protective equipment in compliance with all applicable laws and regulations, they must also take all appropriate measures to prevent accidents and minimise hazards.

Of our non-tea suppliers of packaging and services, as at the date of this Statement, suppliers representing 67% of our spend in this area have signed our SCOC, and we are working towards getting 100% commitment from all our suppliers in our non-tea supply chains.

Grievance

Grievance redressal forms part of our Supplier Code of Conduct agreement. Where internal and external stakeholders identify material breaches of the Code’s requirements, whether through their employees or third parties, including Tata Consumer Products, our Ethics & Compliance Helpline Process includes the following reporting mechanisms available to all:

Phone:
India - 1800 3000 0053
US and Canada - 1-844-371-0217
UK - 0808-234-1815

Our own Internal audits also pick up any such issues as part of our reviews and any high-risk items are investigated and reported to the Board.

If we are made aware of an incident which suggests a supplier is falling short of its obligations in this area, we will contact them to understand the circumstances of the issue and the steps being taken to support those involved and impacted, and the measures being taken to mitigate risk and to protect workers.

If necessary, we will also involve the Ethical Tea Partnership to provide a third-party view of the validity and robustness of the steps being taken.

Modern Slavery and Trafficking Compliance Clauses in our Contracts

We continue to incorporate anti-slavery clauses into all our major supply contracts whereby suppliers are required to commit that:

✓ they shall comply with the Modern Slavery Act 2015;
✓ neither the supplier nor any of its officers, employees, agents or subcontractors is aware of any circumstances within its supply chain that could give rise to an investigation relating to an alleged offence under the MSA or prosecution under the MSA;
✓ they have implemented due diligence procedures to ensure compliance with the MSA in its business and supply chain; and
✓ for the avoidance of doubt, the supplier undertakes not to purchase any resource or raw materials or products that have been sourced from producers or manufacturers using forced or child labour in its operations or practices.

As part of these clauses, we are retaining the right to invoke sanctions against suppliers who fail to comply with these commitments, including the termination of the business relationship.

SUPPORTING COMMUNITIES

We are very aware of our responsibilities to the people who grow and pick our tea, and of our responsibility to help sustain the environment on tea estates. One of the ways in which we are fulfilling these responsibilities is through our collaboration with key partners including Rainforest Alliance and the Ethical Tea Partnership.

Rainforest Alliance Certification

In line with our commitment to only buy teas from estates that have been certified and independently audited by the Rainforest Alliance or Trustea in India, 100% of all Tetley branded black and green tea and red/rooibos tea, including flavoured and decaffeinated varieties, sold by Tata Consumer Products GB are Rainforest Alliance Certified™, and we are working towards ensuring our Tetley botanical range is produced from sustainable sources.

As part of the certification process independent auditors verify that the tea estates in our supply chain meet requirements for:

No form of forced, compulsory, slave, trafficked or bonded labour.
No use of prisoners or soldiers.
No debts, threats, monetary fines or penalties used.
Regular working hours do not exceed 48 hrs a week except for security guards who work 10 hrs a day and the overtime is paid. There is an hour break for every 6 hrs worked and a rest day for every 6 days worked.
All overtime is voluntary and does not exceed a total of 60 hrs a week.
All overtime is paid at the rate required by applicable law or as collectively negotiated, whichever is higher. In absence of applicable law for higher overtime pay, overtime is paid at 1.5 times the regular wage level.
Pregnant women and nursing mothers are not assigned heavy duties and once relocated to lighter duties, remuneration is not deducted.

A copy of the Rainforest Alliance Sustainable Agriculture Standard Farm Requirements can be found on the Rainforest Alliance website at https://www.rainforest-alliance.org/wp-content/uploads/2022/01/2020-RA-Sustainable-Agriculture-Standard-Farm-Requirements.pdf.

All our Good Earth teas are also Rainforest Alliance certified.

Ethical Tea Partnership (“ETP”)

We are one of the largest contributors and a founding member of the Ethical Tea Partnership, supporting multiple projects throughout the supply chain.

Since it was founded in 1997, ETP has worked on a wide range of issues that have brought about long-lasting improvements for people who live and work on tea estates. Working in partnership with the ETP we are supporting a number of projects to support tea communities.

Lighting to make a difference

Through our Kuwala project with the Ethical Tea Partnership we have given solar lamps to families working on the estates of two of our biggest suppliers in Malawi. Close to 6,000 families have received a light enabling them to meet outside after dark and do tasks that they would otherwise be unable to do once darkness falls, this includes being able to extend the trading hours of small businesses and children and adults being able to complete work after dark. The lamps are also creating jobs, with some 45 people now trained to service and repair the lamps, so they have as long a life as possible.

Savings & Loans

In Malawi, families that cannot access affordable loans can struggle to pay for basic things like school, healthcare, and everyday essentials like food or home repairs.

We are working with the ETP to support a scheme which helps families set up and run their own ‘banking system’, known as Village Savings Loan Associations (VSLA). They are like a community bank where workers get together to save money as a group. Each group has a leader who is trained on the rules of how to run the VSLA, and the group is given tips on ways to grow their income.

Once set up, savers get interest on their savings, they can access their own money and request loans to start their own business.

143 VSLAs have been formed, 50% of savers are women, 41% have been able to use their savings to buy a cell phone; and 50% have been able to add iron sheeting to their homes for the first time.

Income diversification

We are supporting a new programme with the ETP which begins with a variety of different seedlings being nurtured at a Tetley Tree Nursery.

Local smallholders will be helped to choose the types of trees that would benefit their smallholding most:

Boundary species that can thrive on less fertile land - ideal for planting on the outskirts of land where space for farming is limited.
Shade trees which can be intercropped with tea - ideal to provide protective shade against increasingly high temperatures.
Fruit trees like Avocado – that could supply additional income opportunities.
and
Utility trees that can be used for firewood - reducing the need to deforest establish trees.

In addition to the benefits gained from the trees, the project will provide access to carbon banking where payments will be made for the carbon the trees absorb when they mature.

This is a long-term investment programme for us and we look forward to monitoring its progress and understanding the impact it can have.

Supporting women

Tata Consumer Products Limited is one of the funding partners of the UNICEF-ETP project in Assam that works to improve the lives of children, young people, and women living in the state’s tea communities. The UNICEF-ETP Improving Lives programme aims to tackle the systemic issues affecting women and children in 206 tea estates across eight districts of Assam, which represents over one-fourth of formal tea estates in the region. The project has expanded to education, health and nutrition, and water & sanitation challenges

teapigs - Educational opportunities for vulnerable people in Rwanda

By working with a charity called the Point Foundation, our teapigs business continues to help fund educational opportunities for vulnerable people in Rwanda. This has ranged from support to fund schools; sponsoring vulnerable children through university education; funding vocational skills training; providing donations to help fund equipment, animals and training for local community farming projects in Rwanda. Visit https://www.teapigs.co.uk/pages/ethical-scheme to learn more about teapigs’ ethical schemes.

RISK ASSESSMENTS

Our supply chains for our Tetley and Good Earth teas that we sell into Europe, US and Canada are 100% Rainforest Alliance certified, and our teapigs supply chain, which is currently 49% Rainforest Alliance certified, is expected to be so certified to 100% within the next two years.

In relation to Tata Consumer Products Bangladesh Limited, the teas purchased at the Chittagong Tea Auction are sourced from tea gardens that are registered with the Tea Board of Bangladesh, which is under the oversight of the Bangladeshi Ministry of Commerce.

In relation to UK Group’s South African subsidiary, Joekels Tea Packers (Pty) Ltd (“Joekels”), 54% of all teas purchased by Joekels is Rainforest Alliance certified, and the rooibos tea that Joekels sources from Cape Rooibos within South Africa is processed at a plant that is audited by the Rainforest Alliance.

Our continued work with the Ethical Tea Partnership and the Rainforest Alliance supports our commitment to buy tea which has been ethically produced and sourced.

PUBLISHING OUR STATEMENTS

Our Statement is published on our UK and other websites which can be found at:

www.tetley.co.uk
www.tataconsumerproducts.com
www.goodearth.co.uk
www.teapigs.co.uk
www.joyfullmillet.com

A link to our modern slavery statement can be found on the homepages of each of the above websites. Copies of our previous statements remain on our www.tataconsumerproducts.com website and can be viewed at any time (follow the link https://www.tataconsumer.com/modern-slavery-statement--uk).

Should there be any difficulty in accessing our websites, please send a written request marked for the attention of the Company Secretary, Tata Consumer Products GB Limited, 325 Oldfield Lane North, Middlesex, UB6 0AZ.

WHAT ELSE

To learn more about Tata Consumer Products’ responsible business practices, please visit: http://www.tataconsumerproducts.com/sustainability which details our various social sustainability initiatives. This statement approved by the boards of directors of Tata Consumer Products GB Limited and Tata Consumer Products UK Group Limited on Tuesday 24th September, 2024.