Modern Slavery
J. Pao & Co. Ltd
Introduction
This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015 and sets out the J. Pao & Co. Ltd approach to understanding and addressing any potential slavery and human trafficking risks within its business and supply chains.
J. Pao & Co. Ltd is committed to conducting business ethically and with integrity. We recognise the serious issue of modern slavery and human trafficking, and take proactive steps to ensure that these practices have no place in our operations or supply chains. This policy outlines our approach to identifying, preventing and addressing any risks related to modern slavery, in compliance with relevant legislation including the UK Modern Slavery Act 2015.
We expect all employees, workers, agency workers, suppliers, contractors and business partners to share our commitment to human rights and to uphold the principles outlined in this policy. Through ongoing vigilance, training and collaboration we aim to foster a transparent and responsible business environment that respects the dignity and freedom of all individuals.
- The term ‘modern slavery’ refers to various types of abuse and encompasses:
- Human trafficking
- Forced work, through mental or physical threat
- Being owned or controlled by an employer through mental or physical abuse, or the threat of abuse
- Being dehumanised, treated as a commodity or being bought or sold as property
- Being physically constrained or to have restriction placed on freedom of movement
This statement explains the steps that J. Pao & Co. Ltd has taken to ensure that slavery and trafficking are not taking place in any part of its own business, or in any part of its supply chains. The information included in this statement refers to the financial year 2025/2026. J. Pao & Co. Ltd will review and publish an annual slavery and human trafficking statement, signed and approved by a director.
Our Business
J. Pao & Co. Ltd employs over 80 staff across two sites (Dunstable and Cheshire). Using high-tech processes, J. Pao & Co. Ltd grows and packs around 350 tons of beansprouts per week, operating 7 days a week, 364 days a year. Deliveries are made to the UK retail, catering and food processing sectors using company-owned refrigerated vehicles and selected third-party transportation providers.
Our Commitment
J. Pao & Co. Ltd acknowledges its responsibilities in tackling modern slavery and is committed to complying with the Modern Slavery Act 2015. The company is dedicated to the ongoing review of its internal practices regarding ethical standards and labour practices, as well as those within its supply chains.
J. Pao & Co. Ltd does not enter into business with any organisation, in the United Kingdom or abroad, that knowingly supports or is found to be involved in slavery, servitude, forced or compulsory labour.
No labour employed or provided through an agency is obtained through slavery or human trafficking. The company strictly adheres to its responsibilities under relevant UK employment legislation.
The company’s main supply chains relate to the sourcing of raw materials, specifically mung beans, from Myanmar, Uzbekistan, South Africa and China. Other supply chains involve goods and services required to operate the business, such as engineering equipment, machinery, stationery, IT equipment, packaging materials, pallets etc., primarily sourced from the United Kingdom, with some engineering parts from Japan and the Netherlands.
We understand that some supply chains are tiered: Tier 1 suppliers are required, regardless of spend, to confirm their commitment to abolishing modern slavery and provide evidence of compliance with relevant laws and within their own supply chains.
Policies
J. Pao & Co. Ltd review policies annually or as needed to adapt to changes. In addition to the Modern Slavery policy, J. Pao & Co. Ltd has the following policies: Whistleblowing; Employee Code of Conduct and Equality; Diversity and Inclusion.
Potential Exposure
J. Pao & Co. Ltd considers its main exposure to the risk of slavery and human trafficking to exist within its supply chains, particularly where labour is provided in countries with limited human rights protections. Overall, the company considers its exposure to slavery and human trafficking to be relatively low.
Process for Managing the Risk
J. Pao & Co. Ltd carries out due diligence to ensure slavery and/or human trafficking does not occur within its operations or supply chains. This includes reviewing the controls of its suppliers.
To the company’s knowledge, it has not conducted business with any organisation found to be involved in modern slavery. In accordance with Section 54(4) of the Modern Slavery Act 2015, the company has taken the following steps to ensure modern slavery is not taking place:
- Membership with SMETA, which conducts Sedex Ethical Trade audits to identify and assess potential ethical risks in supply chains and drive continuous improvement
- Reviewing supplier contracts to include termination clauses in the event that a supplier is, or is suspected to be, involved in modern slavery
- Taking actions to embed a zero-tolerance policy towards modern slavery
Training
As part of our compliance with the Modern Slavery Act, J. Pao & Co. Ltd provides training during employee induction and through this policy to ensure identification, prevention and reporting of any potential risks of modern slavery within our operations and supply chains.
Raising Concerns
Employees are encouraged to raise concerns regarding modern slavery through our Whistleblowing policy.
