Odysea’s Modern Slavery Statement 2024/2025

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Odysea Ltd, has a zero-tolerance approach to modern slavery and is committed to preventing and combating slavery and human trafficking in all its forms. We recognise our responsibility to uphold ethical standards, protect human rights, and create a safe and fair working environment for our employees and supply chain partners.

This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by Odysea Ltd for 2024/2025 Financial Year to prevent modern slavery and human trafficking in its own business operations and supply chains.

It applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

Organisation and Supply Chains

Odysea Ltd is a supplier of the highest quality Mediterranean food products with a host of customers from leading restaurants, hotels, and gastropubs to quality delicatessens, independent retailers and department store food halls. Odysea do not own a manufacturing site. We purchase our products from our suppliers that are manufacturing sites and not traders.

With over 30 years’ experience of working with the finest local producers in Greece and across the Mediterranean we have long standing relationships with both our customers and suppliers alike. Many of our suppliers are small businesses who we work closely with.

Policies and Processes
We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

All employees are expected to be vigilant and report any concerns related to slavery and human trafficking within the company or its supply chains to Senior Management and/or HR. We encourage open and transparent communication. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

The following policies underpin our approach to Modern Slavery are:

Anti-Slavery and Human Trafficking Policy
Anti-Corruption and Bribery Policy
Business Ethics Policy
Equality, Diversity and Inclusion Policy
Odysea’s Code of Conduct
Whistleblowing Policy
ETI Code of Conduct

Due Diligence

In order to identify and mitigate risk we monitor ethical standards across the business on a regular basis both internally and externally via external third-party audits, such as SMETA ethical audits. We are a member of the Supplier Ethical Data Exchange (SEDEX) and as such complete self assessment questionnaires and SEDEX members Ethical Trade audits on a regular basis. We also conduct supplier visits where we check and discuss any issues or concerns.

We have a supplier approval procedure, where Ethical Trading and Labour related issues are also evaluated. ETI Code of Conduct is our minimum standards for all our suppliers.

We encourage concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier to be raised at the earliest possible stage.
If an anyone believes or suspects a breach of this has occurred or that it may occur they must report it in accordance with our Whistleblowing Policy as soon as possible. We are committed to thoroughly investigating and addressing all reports.

Risk Assessments and Management

We will conduct regular risk assessments to identify and address any potential vulnerabilities to slavery and human trafficking within our operations and supply chains. This includes assessing geographical areas, business relationships, and industry-specific risks.

The Managing Director has overall responsibility for ensuring Odysea Ltd complies with our legal and ethical obligations, and those under our control. The Senior Management of Odysea Ltd, have primary and day-to-day responsibility for ensuring that our policies and processes are implemented and that adequate resources are allocated to prevent and address issues related to slavery and human trafficking

Training

Odysea Ltd, will provide training to employees and relevant stakeholders to ensure they understand the risks of slavery and human trafficking and know how to respond to and report concerns.

Future Objectives

Require all of our suppliers to register with Sedex and complete the self assessment questionnaire, including the part on Labour Standards
Continue our programme carry out risk assessment and conduct site visits of our suppliers
Create a Odysea Suppliers Code of Conduct
Commence and ESG audit programme

Review

This policy will be reviewed annually to ensure its effectiveness and relevance. Necessary changes and improvements will be made as required.

Conclusion

Odysea Ltd, is committed to the prevention of slavery and human trafficking and will strive to uphold the highest ethical standards in all its operations and relationships. This policy reflects our determination to create a world free from these crimes and to protect the rights and dignity of all individuals.