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Modern Slavery Act

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Modern Slavery & Human Trafficking Statement

This statement sets out Hallgarten  Wines’ actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.  This statement relates to actions and activities during the financial year 1 January to 31 December 2021.


The Company acknowledges its responsibilities to the Modern Slavery Act 2015 and the relating definitions set out therein.


Organisation Structure and Supply Chain


Hallgarten Wines is a leading UK based wholesale distributor of wines.  We sell to premium restaurants, national grocers, hotels and independent retailers nationwide.  We also sell to a number of International customers. Our extensive supply chain is sourced from the premium producers around the world, from a mix of developed and developing countries.


Our Policy


We have a zero tolerance approach to Slavery & Human Trafficking and have direct control over our commercial activities in the UK. We are happy to give a 100% assurance that every person directly employed within our business is done so legally. We only work with specified, reputable agencies to source staff and we run checks on new employees including eligibility to work in the UK to safeguard against human trafficking or any individual being forced to work against their will.


We are reliant upon third party organisations in two key areas of our operations:


  1. Wine producing businesses across the world – currently 24 countries and 192 suppliers


  1. Transportation of wines from source (normally outside the UK) to the UK, storage of the same wines in UK warehousing and finally onward delivery of these wines to our customer-base nationwide.


With these third party organisations, we have systems in place to identify and mitigate risk which include:


  • Ensuring that all wine suppliers comply with our Code of Conduct which includes a statement from them confirming that they abide by the Modern Slavery Act.
  • Remaining a member of SEDEX.
  • Engaging with our key (high volume) logistics suppliers to convey our Anti-Slavery policy to gain written assurance from them that they abide by our Code of Conduct. This group of suppliers includes three major service providers: London City Bond (contracted to warehouse and deliver all of our UK stocks), Wineflow (responsible for the majority of our European shipments to the UK) and Albatrans (responsible for the majority of our deep sea shipments to the UK)
  • Protecting any whistleblowers internal or external to our company
  • Putting in to place a rolling programme of review which includes visits to suppliers (taking into account COVID-19 restrictions)


Other Relevant Policies


Supplier Code of Conduct

Whistleblowing Policy


Additional Statement:  It is worthy of note that the majority of wine producers world-wide are reliant upon employing a large number of casual seasonal workers during the highly labour-intensive period of harvest each year.  This fact – common across our industry - presents challenges to Hallgarten Wines in terms of being able to systematically verify that all seasonal pickers and workers employed by our suppliers are done so legally and subject to the terms and spirit of the Modern Slavery Act.  Nevertheless, Hallgarten, is seeking assurances from all suppliers and working with them to identify how best to give us the level of assurance that we require. We believe this policy is appropriate to our business.


This statement has been approved by the organisation’s Board of Directors who review and update it annually.


Signed: Howard Falk, Director, 30 June 2021