Modern Slavery Statement

Modern Slavery Statement 2021/2022

As in previous years, adm has continued to make efforts to ensure that modern slavery, in all its forms, is not taking place within our business or supply chain. adm is committed to and continues to act in accordance with the UN Guiding Principles on Business and Human Rights and continues to develop responsible sourcing practices to improve labour standards and human rights in our supply chains. This statement constitutes adm Group’s statement on slavery and human trafficking for 2021/2022 and encompasses all adm entities.

We operate a zero-tolerance policy in respect of all forms of modern slavery, forced/compulsory labour and human trafficking, whether in our own global operations or in our supply chains. Striving to meet our objectives for the coming year, we are strongly committed to guarding against slavery and human trafficking in our global operations. Due to our continuous growth within the territories we are present in, we have again made further improvements to our practices to ensure that modern slavery risks are managed effectively.

Established in 1992, adm is one of the largest independent marketing services businesses in the world, employing over 550 people worldwide. adm has its headquarters in London, United Kingdom and operates in 27 countries globally. adm provides global supply chain solutions to a broad spectrum of clients spanning across several diverse sectors using product supply chains which are global and extensive. adm sources and distributes products in Europe, Latin America, North America and Asia using hundreds of suppliers and strategic partners. adm’s mission is to combine great people, process, expertise and proprietary technology to deliver outstanding results and added value to clients.

Our Policies

We are continuously developing our Corporate Social Responsibility (CSR) strategy based on the UN Global Compact’s four pillars of human rights, labour standards, environmental and anti-corruption principles and with reference to the United Nations Guiding Principles on Business and Human Rights. We have further implemented an Anti-Bribery and Anti-Corruption Policy for all of our suppliers, and an Anti-Slavery and Human Trafficking Policy with the aim of ensuring that modern slavery is not taking place anywhere in our business or in any of supply chains. The Anti-Bribery and Anti-Corruption Policy was reviewed and updated in February 2020. We strive to ensure these principles underpin everything that we do, from sourcing responsibly to ensuring the rights of every worker affiliated with the adm Group are safeguarded and protected. adm has a range of HR policies which set out certain minimum standards regarding the human rights of its staff.

In 2019, our Employee Code of Conduct was updated to reflect our revised position on anti-slavery and human trafficking; setting out adm’s zero-tolerance to all forms of modern slavery, forced/compulsory labour and human trafficking and providing workers and contractors guidance on these important issues. Our Supplier Code of Conduct, which amongst other points, sets out our minimum standards in respect of the human rights of supplier staff, was also updated to clearly reflect adm’s position on these crucial matters and to provide guidance to our suppliers. These policies, coupled with our accession to the UN Guiding Principles, reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Other events in 2019, saw the introduction of adm’s Whistleblowing Policy which includes an independent global ethics helpline providing an option for anonymous reporting. The policy is designed to encourage employees to report matters either internally or to an independent body (at their option), without fear of reprisal. If reported internally, employees can speak to our Whistleblowing Officer. If externally, the helpline is provided worldwide (via international free phone numbers) and uses interpretation services for non-English speaking callers. If an employee would rather not speak to someone, they may contact the independent third party via a dedicated or generic e-mail option.
We continue to develop our portfolio of policies relating to modern slavery to ensure we are always conducting business in an ethical and transparent manner. A key initiative in 2019/2020 was the addition to our policy portfolio of our new Anti-Slavery and Human Trafficking Policy which provides extra details and guidance for those working for adm, or on behalf of adm, regarding this Statement and our continuing commitment to ensuring modern slavery does not take place within our business or supply chain.

Building on last year, this new key initiative demonstrates adm’s ongoing commitment to ensuring modern slavery in all its forms is eradicated by encouraging active risk management by all staff and business partners.

Due Diligence & Supplier Adherence

Recognising the human rights risks inherent in global sourcing and particularly given adm’s expanding global reach into certain high-risk territories, adm considers its biggest risk of modern slavery and human trafficking to be in its product supply chains. adm employs a rigorous supplier selection process including due diligence checks in the form of ethical/compliance audits (including factory audits), both prior to a new supplier being on-boarded and then on a periodic basis. The audits are performed by independent and recognised third party auditors in most regions, but may be done by our qualified, in-house auditors in Asia. The audits are then reviewed by adm, and the suppliers are graded based on the results of the audits. Our global Quality and CSR teams comprise of 40 dedicated staff.

Standard practice is for audits to be conducted every two years as a minimum by our CSR auditors or qualified auditors from accredited third parties. These audits assess compliance with adherence to adm’s Supplier Code of Conduct and adm’s standards on Human & Labour Rights and Working Conditions. adm is a member of the Supplier Ethical Data Exchange (Sedex) and administers Sedex Members Ethical Trade Audits (specifically, the 4 Pillar SMETA audits).

The 4 Pillar SMETA audits inform adm about the living conditions, wages, overtime hours and working conditions of supplier staff, and allows adm to monitor and minimise the risks of human rights abuses in its supply chain. adm has developed a CSR checklist which is used for grading its suppliers based on the audit results and its CSR objectives. If a supplier audit finds that a supplier is not in compliance with adm’s rules, adm will address such concerns with the supplier and work with the supplier to resolve the issues in order for adm to continue working with them. In certain respects, adm adopts stricter assessment of Human & Labour Rights and Working Conditions than the 4 Pillar SMETA audits requires, which reflects our zero-tolerance approach to all forms of modern slavery, forced/compulsory labour and human trafficking.

One of the cornerstones of adm’s CSR objectives is encouraging our factories to join the CSR journey with us and help them to improve their CSR compliance over time. The most important attribute we look for in a new supplier is a positive attitude towards CSR, demonstrating they are truly willing to learn and improve. We will still work with a supplier whose initial CSR results may be poor, provided that they are willing to work with us to implement changes and commit to a mutually agreed corrective action plan.

Our inhouse expertise helps guide suppliers to becoming more aware of social issues, leading to greater social compliance.


The adm Group board is responsible for ensuring adm meets its human rights responsibilities. adm’s human rights responsibilities are key elements of an annual corporate risk assessment process which is overseen by the Group General Counsel on behalf of the adm Group Board. This assessment is developed in conjunction with adm’s regional operating boards and with the participation of senior leaders within the adm Group.


adm’s online global compliance training programme includes a specific module on modern slavery. It is a mandatory requirement for all employees to complete the course on an annual basis to ensure there is a high level of understanding of the risks of modern slavery and human trafficking across the business. This course includes an assessment at the end of the module to ensure the content has been understood. adm monitors compliance levels on an ongoing basis and issues periodic communications via various means to staff to ensure compliance levels are maintained.

Labour Standards

All employment with adm is voluntary. We do not use child or forced labour in any of our operations or facilities. We do not tolerate any form of unacceptable treatment of workers, including but not limited to the exploitation of children, physical punishment or abuse, or involuntary servitude. We fully respect all applicable laws establishing a minimum age for employment, in order to support the effective abolition of child labour worldwide.
adm abides by all laws and regulations regarding pay practices and the classification of employment according to job level and status.

We respect our employees’ right to choose to join or not join a trade union, or to have recognised employee representation in accordance with local law.

Diversity, Equity, and Inclusion

Diversity is an important part of who we are. Our vision is to ensure that all of our people can reach their full potential without having any unfair barriers put in their way. Slavery disproportionately impacts those experiencing oppression on the basis of their gender, race, class, religion, or other identities.

We respect the varied diversity characteristics (including race, disability, gender, LGBTQ+, neurodiversity, religion, belief and age and anything else that’s important to people) of all of our team members and others in our networks.

As a business, we believe that our diverse mix of backgrounds, skills and experiences drives new ideas, products, and services and provides us with a sustained competitive advantage. At the time of publication, we have 550+ employees across the globe who are spread over 27 countries and represent numerous, varied diversity characteristics.
We strive to foster an equitable and inclusive culture and are committed to evolving our range of benefits and employee engagement initiatives to support our people. Through our Code of Conduct we have our suppliers sign, and the ethical/compliance audits carried out on our suppliers, we seek to ensure our partners do not discriminate against anyone and ensure modern slavery is not taking place in their businesses. Furthermore, we are fully committed to the ethical management of our supply chain, driving for social and environmental excellence.

Our Effectiveness in Combatting Modern Slavery

In 2021, adm was rated in the top 1% of over 50,000 companies assessed for CSR by EcoVadis, the leading platform for environmental, social and ethical performance ratings for global supply chains. CSR analysts reviewed adm’s global supply chain and CSR practices across the following four pillars: Environment (top 1%), Labour and Human Rights (top 4%), Sustainable Procurement (top 1%) and Business Ethics (top 1%). In addition to an overall ranking in the top 1%, adm achieved a “Platinum” score for the first year.

Our Group CSR Strategy Advisor was also chosen in 2019 as one of the members of the Human Rights Steering Committee in AIM Progress, a role they held until the end of 2021. adm’s involvement in this initiative provides a great example of adm’s continuous commitment to combating modern slavery.

adm continues to be an AIM-PROGRESS member, a forum of leading Fast-Moving Consumer Goods (FMCG) manufacturers and common suppliers, which has several strategic focuses including Business and Human Rights and is a member of its Human Resources working group. adm was the first business within our sector to be chosen as a member. Specifically, AIM-PROGRESS supports the Consumer Goods Forum’s resolution on eradicating forced labour and its priority industry principles, which seek to counter problematic and common employment practices which can lead to cases of forced labour. Members assemble to enable and promote responsible sourcing practices and sustainable supply chains. Specifically AIM-PROGRESS works through:
• the provision of a forum to exchange views and share learnings regarding responsible sourcing practices;
• leveraging synergies and supporting collaboration with other global initiatives having similar objectives/aims;
• mutual recognition of audits, where possible, reducing the impact of audit fatigue for suppliers; and
• supplier capability building events.
Being a member of this forum allows adm to keep abreast of best industry practice in management of modern slavery risks and to drive continuous improvement in our risk management practices.
As we continue to scale and move into more high-risk territories, adm deploys rigorous employee onboarding processes which help us manage our own risks of modern slavery in the workforce. Some notable aspects of our processes are:
• We benchmark pay in each region to ensure all employees are paid fairly for their work;
• A health and safety assessment is carried out in all working environments to ensure we are providing a safe working environment for all staff;
• We do not employ anyone under the statutory minimum age within each respective jurisdiction;
• Candidates either apply directly or through verified third party agencies to minimise our modern slavery risks;
• We have standards on working conditions that all employees are informed of. These include rest breaks and working hours, all of which are planned in accordance with local laws and regulations;
• Employees who are sent on secondment are sent to serviced apartments which have been checked by our Human Resources team for suitability;
• Employees are made aware of this statement and our internal and external policies regarding modern slavery and human trafficking.
In 2019, we improved our global induction program to ensure all countries are using the same criteria to onboard our employees. This provides consistency and assists us in ensuring we are using the right standards for everyone, everywhere that we have employees.
In 2020 adm published its first Human Rights Policy, in line with the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work. This emphasizes our commitment to our employees and business partners.

Looking forward
adm is proud of the steps it has taken to manage the risk of modern slavery across its business and in meeting its commitments over the years. We believe we have built a strong foundation to manage our risks of modern slavery in all its forms across our business, we continue to look out for and resolve any possible breaches within our supply chain and will continue to reduce the risks in 2021 and beyond.

This statement has been approved by the board of directors of ADM (Group) Limited on 1 February 2022.
Justin Barton Group CEO

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out steps taken by ADM (Group) Limited and the other relevant group companies during year ending 31 March 2021 to prevent modern slavery and human trafficking in its business and supply chains. References to ‘us’, ‘our’, or ‘we’ are to ADM (Group) Limited and its subsidiaries.