Ethical Policy
The Mulberry is part of The Big Table Group.
As a responsible restaurant chain, Big Table Group is committed to ensuring that our supply chain and within our own operations, we take a robust stance in the prevention of slavery and human trafficking. We continue to work with our suppliers to strengthen our supply chain due diligence in social, environmental and ethical standards whilst recognising that many may need practical help and support in implementing these.

BTG’s Modern Slavery statement sets out the steps we have taken in understanding all potential risks, ensuring that these are addressed to support our objective of zero tolerance to slavery and human trafficking in all our business activities both in the UK and overseas.

Structure and Supply Chains

Big Table Group is one of the leading independent restaurant companies in the UK employing over 4,000 people and serving millions of meals at around 150 locations.It is a parent business to three main operating companies: Las Iguanas, Bella Italia and Café Rouge.

We have a centralised Procurement team who work with around 100 suppliers and with them we have established strong relationships based on mutual trust and transparency.

We use Authenticate, an industry leading supply chain mapping tool to understand our ingredient sourcing and our exposure in different countries. In 2020, we identified our high-risk countries as; Thailand, India, Italy, Spain and UK.

Our aim is to build best practice supply chain assurance that is resilient to any potential risks and supports us to be vigilant in all parts of our business. To this end, we require our direct suppliers to work closely with all their supply chain partners including raw material producers, distributors, wholesalers and agents to meet this aim.

Policies



Ethical Trading


All direct suppliers and their supply chain partners must comply with all EU and UK legislation
relating to ethical trading and worker welfare as a minimum. These include the following:

The Data Protection Act 1998
The Foreign Corrupt Practices Act 1977
The Proceeds of Crime Act 2002
United Nations (UN) Universal Declaration of Human Rights
The International Labour Organisation (ILO)

The Ethical Trading Initiative (ETI) whose Base Code is drawn from the scope and
standards defined by the UN and ILO.

Where applicable i.e. companies that have a turnover of £36 million or more, they should also demonstrate their own compliance with the Modern Slavery Act 2015.

In addition to this, BTG has its own Ethical Trading Policy that sets out company policies and practices to ensure our business and supply chain practices are free from slavery and human trafficking far as possible.

Our policy covers 14 key principles that reflect those in the ETI Base Code including: prohibition of slavery and human trafficking, safe and hygienic working conditions and payment of a fair wage. All direct suppliers are required to show compliance with this Policy and to provide evidence of continuous improvement in worker welfare.

Suppliers must have their own Codes of Conduct, ethical trading policies and management systems to demonstrate their approach to prevent modern slavery and human trafficking.

All first-tier suppliers are required to be Sedex members and to provide due diligence on ethical trading including self-assessment, third party audits and corrective action of non-compliances on request from BTG. BTG is also a Sedex member that allows us to access information on suppliers including latest audits undertaken and corrective action reports at any given time.

Monitoring and Reporting


BTG will continue to work with our suppliers to share responsibility with them on modern slavery and worker welfare issues in our supply chain.

Day to day responsibility for monitoring of suppliers’ audits and self-assessments through Sedex lies with our Technical Manager together with quarterly reviews which are conducted on overall progress and compliance of our policies with Authenticate.

Next Steps for 2021


A section will be included in Authenticate in line with our compliance to the Modern Slavery Act 2015 and this is a supplier questionnaire, the purpose of which is to:

Continue to raise awareness across our supplier base, particularly new suppliers, about the Modern Slavery Act and their compliance requirements.

To update our risk mapping of new and existing suppliers according to product
category and source location and to extend this to all first-tier suppliers including Property and Marketing.

To request that our suppliers confirm their own compliance to the Modern Slavery Act and their cooperation if any slavery and human trafficking incidents are found in their supply chains.

We will use Authenticate to report on how effective we have been to ensure that
slavery and human trafficking is not taking place in any part of our business including key performance indicators (KPIs) as follows:

  • % of suppliers who have been audited against ethical trading requirements.
  • % of suppliers approved.
  • % of suppliers who have had to adopt corrective action for any legislative or company requirements.

We will provide refresher training to our Procurement, Marketing and Property
colleagues to raise awareness to Modern Slavery as part of their sourcing
responsibilities.

This statement is made pursuant to section 54 (1) “Transparency in Supply Chains’ clause of the Modern Slavery Act 2015 and constitutes BTG’s modern slavery and human trafficking statement and will be reviewed and updated annually.

Signed

Alan Morgan
CEO, The Big Table Group Limited