Anti-Slavery and Human Trafficking Statement

1. Organisation Structure, Business and its Supply Chains

Concordia is a registered charity which, among other activities, places workers in
seasonal work on horticulture enterprises across the UK. The workers are employed
directly by the businesses where they are placed. Concordia’s mission is to help
individuals by providing work placements and similar opportunities to enable them to
develop their skills and character and develop their cross cultural understanding.
Concordia is led by its Chief Executive. The Operations team is responsible for the
farm placement programme, with 5 office based staff, and 1 field staff led by the
Operations and Development Manager. The executive is overseen by a board of trustees/directors
responsible for strategic oversight and governance.
Concordia has longstanding relationships with a number of GLAA licensed businesses
in other EU countries which it uses as representatives to support its recruitment.
Concordia advertises vacancies on its website but the majority of recruitment is carried
out through its third party agents in the European Union.

2. Policy in Relation to Slavery and Human Trafficking

Concordia does not tolerate slavery, human trafficking nor any form of labour
exploitation and takes proactive measures in its policies, practices and procedures to
ensure modern slavery is not present in its supply chain. These measures are
highlighted in this document.

3. Due Diligence Processes in Relation to Slavery and Human Trafficking
in the Business and Supply Chains

The following are the measures Concordia undertakes to minimise the risk of
exploitation in its supply chain for recruiting seasonal workers in horticulture:
a) Obtains proof of nationality/right to work and retains scan of ID.
b) Conducts annual audits of third party agents processes focussing on GLAA
requirements and the recruitment process.
c) Utilises third party representatives who speak the same language as the worker
and is therefore better able to support them when they are in the UK.
d) Employs field officers to visit farms and office staff to answer calls regarding
issues, with a team specifically employed to support workers and growers.
e) All employing farms are visited and checked by a Concordia field officer
before labour is supplied to ensure that suitable work and accommodation
conditions are provided.
f) Farms are checked by Concordia in respect of quality of working and living
conditions.
g) Concordia produces own language posters regarding optional third party
representative fees & pastoral support.
h) Travel insurance is provided for non UK resident workers to add to their
security.
i) Farms working with Concordia must offer accommodation to workers, thus
removing the risk of exploitation in the local rental housing market.
j) People recruited via Concordia are employed directly by farms and not by
intermediaries such as gangmasters or agencies, thus minimising the risk of
financial exploitation.
k) Concordia work placements are provided to give continuity of work, as
opposed to a short period of a few days, again minimising the risk of
exploitation.
l) A Pastoral fund is available to fund travel for workers when issues arise.
m) Worker experience is monitored by questionnaire and Field Officer discussion
with workers during visits to farms.
n) Close liaison is maintained with the GLAA and ALP in order to understand risks
and potential issues in sector.

4. Areas of Risk in Supply Chain and the Steps Taken to Assess and
Manage that Risk

Risk assessment:
a) Agent process, – All overseas third parties are audited in a face to face
visit every year to check processes and compliance with GLAA guidelines.
The audit covers measures taken to stop unofficial intermediaries acting as
unlicensed gangmasters, including not allowing large groups, limiting the
number of ‘friends’ someone can recommend and accompany,
questioning how applicants hear about the placement/agent. It also checks
there are no financial bonds or connections to a third party loan company.
Any fees charged by third party representatives are checked to confirm
they comply with GLAA licence standards, are not ‘work finding’, and are
optional. Additionally an annual agent conference is hosted in the UK
which covers recruitment processes, legislative guidelines, farm visits, and
meetings with employers.
b) Travel to UK at airport or overland – clear travel to farm instructions
are provided; third party representatives offer support with booking travel;
reporting process for non-arrival on farm.
c) Other risk of exploitation: Addressed by worker interview form issued
to personal email address.

5. Measurement of Effectiveness

Number of worker interview forms issued and returned.
All agents audited annually – 100% completion. Action plan issued
Welfare/pastoral support calls logged and measured.
Active checks – of third party representatives.
Field officer visits to farms – outcomes.

6. Training

Awareness raised at regular staff briefings and new staff induction.
Attendance at Stronger Together seminars for key staff
GLAA / University of Derby training on line course to be completed by staff – when
launched.