Modern Slavery Policy


Hughes Group (K Hughes & Co. Ltd & Howden Enterprises Ltd) are committed to developing and adopting a proactive approach to tackling hidden labour exploitation and to driving out acts of modern-day slavery and human trafficking within our business and supply chain. This includes our Labour Providers, contractors, suppliers, and sub-contractors.

Hidden labour exploitation involves job applicants or workers being exploited by third party individuals or gangs other than the employer or Labour Provider. This includes rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as forced use of accommodation. It is often well hidden by the perpetrators; victims, if they perceive of themselves as such, are often reluctant to come forward.

Hughes Mushrooms acknowledges the Modern Slavery Act 2015 and will ensure transparency within the organisation and within our supply chain.

Statement for 2024/25

  • In September 2017 we embarked on a programme to ethically audit our suppliers via the Sedex online platform. For those suppliers who are not on Sedex we asked them to complete a self-assessment questionnaire that follows the ETI Base Code. These questionnaires, once returned, are then risk assessed in line with our internal procedure by our experienced HR Department.
  • Suppliers failing to comply with the basis of the ETI base code will be contacted and coached accordingly. Where the risk is too great, they will be removed from our supplier list following consultation.
  • We have supplied all our suppliers with a copy of our Bribery Policy, Labour Policy and our Ethical Policy and information on how to become a ‘B member’ under Sedex.
  • We will also be providing them with a copy of this policy and provide regular education where they feel it is required in order to assist them to comply.
  • We have also undertaken training with Departmental Managers to ensure compliance with the act and ensure everyone in the business through our induction knows how to spot modern slavery in action and more importantly, how to report this.
  • This training has now become part of our management development training programme and is key on the leadership agenda for the forthcoming year.
  • All new starters will only be paid into a bank account they can access and in their own name. This will be discussed with the new Employee upon joining the organisation and when bank details are changed. We have requested this process also from our Labour Provider.
  • All workers have access to telephone numbers and are provided with information on how to report human trafficking.
  • We provide information on the legal minimum and living wage that workers should be paid on our noticeboard to ensure they are always being paid the legal minimum hourly rate applicable.
  • We are committed to paying the national living wage where applicable. At our Howden facility, we are committed 100% to paying the national living wage.
  • We also provide information to our workers on how to calculate their wages in order for them to understand what they should be paid.
  • We regularly question our workers to ensure they have access to their bank accounts and are not under the control of a modern gang master.
  • We have placed the ‘Stronger Together’ campaign posters on our noticeboards.
  • We have implemented a ‘Labour Provider Audit’ and will conduct biannual labour provider audits, which will include the viewing and auditing of payslips, interviewing workers, utilising the ‘Stronger Together’ campaign alongside the GLA Supermarket Protocol.
  • We will publicly report any instances of Modern Slavery found and support those who find themselves subjects of modern slavery through our extension coaching and resource programmes.
  • Our HR Department have attended the Stronger2gether workshops and will continue to ensure their support.

Key Performance Indicators for 2024/25

  • To have ethically audited and risk assessed all of our suppliers.
  • To have an ongoing programme of assessment for our suppliers and have complete compliance with the ETI base code.
  • Labour Provider to achieve less than 40 minor non-compliance issues in their annual audit.


This policy applies to all sites of Hughes Group and their suppliers.


The Head of HR has overall responsibility for this policy, including auditing labour suppliers and ensuring the welfare of staff on site is at the highest standard possible. The HR Department also have a responsibility for communicating this policy to staff and to provide training for Line Managers. Line Managers have a responsibility to report any issues to the HR Department without delay for investigation.

Supplier Due Diligence & Auditing

As part of the company’s due diligence processes into slavery and human trafficking the supplier approval process will incorporate a review of the controls undertaken by the supplier. This will be achieved by linking to suppliers on the Sedex platform online or by completion of our in-house supplier audit questionnaire, which follows the basis of the ETI Base Code. Imported goods from sources from outside of the UK and EU are potentially more at risk from slavery/human trafficking issues. The level of management control required for these sources will be continually monitored. The company will not deal with any business knowingly involved in slavery or human trafficking.


Hughes Mushrooms shall:

  1. Accept that job finding fees are a business cost and will not allow these to be paid by job applicants.
  2. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
  3. Ensure that all staff responsible for directly recruiting workers are aware of issues around third-party labour exploitation, signs to look for and have signed appropriate compliance principles.
  4. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
  5. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and Police.
  6. Provide information on tackling “Hidden Labour Exploitation” to our workforce via posters, leaflets, inductions, and Line Manager specific training.
  7. Encourage workers to report cases of hidden third party labour exploitation; provide the means to do so and investigate and act on reports appropriately.
  8. Positively encourage and support employees and agency workers to report exploitation which may be occurring within their communities by reporting this to the HR Department.
  9. Require labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with the above.
  10. Encourage training to Line Managers and ensure all Workers, whether temporary or permanent are made aware of the Stronger Together campaign and the prevention of human trafficking, including understanding where to report issues.
  11. We also actively encourage suppliers to support our policy on the prevention of slavery and human trafficking and report any issues to the relevant authorities.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Hughes Group modern slavery and human trafficking statement.

Approved by the Board of Directors of Hughes Group on 1st of January 2024 and signed on its behalf by Ciaran Og Hughes, Chairman and approved by the Board of Directors of Hughes Group.