Palm oil is an extremely versatile oil that has many different properties and functions. It is also an incredibly efficient crop, producing more oil per land area than any other equivalent vegetable oil crop. To get the same amount of alternative oils like soybean or coconut oil would require anything between four and 10 times more land, which would shift the deforestation problem to other parts of the world and threaten other habitats and species (1). This is why we are committed to sourcing only sustainable, Roundtable on Sustainable Palm Oil (RSPO) certified palm oil which protects the environment and the local communities who depend on it for their livelihoods, so that palm oil can continue to play a key role in food security. BM TRADA, the leading independent certification body, has certified all of our sites that handle palm oil as having RSPO-approved traceability systems, which means they are capable of guaranteeing the use of palm oil from sustainable sources. We are delighted to have maintained 100% RSPO (Roundtable on Sustainable Palm Oil) certified palm oil throughout the year.

License number: 4-0019-06-100-00. Check our progress at https://rspo.org/members/103/ Premier-Foods- Group-Limited

^{(1) Source '8 things to know about palm oil', WWF, available at: https://www.wwf.org.uk/ updates/8-things-know-about-palm-oil].}

We continue to support and promote the production of sustainable soy through our Round Table on Responsible Soy (RTRS) membership, through which we play our role in promoting zero deforestation and respecting the rights, customs, and culture of different communities and indigenous populations around the globe. Our goal is to ensure that 100% of the soya we buy, both directly and indirectly, meets RTRS standards by 2025. This year, as a first step, we have ensured that 100% of the small amount of soya we buy directly as an ingredient meets RTRS standards. We have also used the Soy Footprint calculator to help drive greater understanding and transparency of soy embedded in our indirect purchases and found that the vast majority is being used within animal feed.

It is a minimum requirement that all the paper and carton-board packaging we use is compliant with the EU Timber Regulation which makes it a crime to place illegally harvested timber and timber products on the EU market. But we go further...

Wherever possible we aim to use paper and board packaging from certified sustainability managed forest resources. To date, 100% of our corrugated packaging is from Forest Stewardship Council (FSC) certified sources.

We use animal-based ingredients such as milk, eggs, and meat across a range of our products. We believe all animals should be treated responsibly and with dignity, and we work with our suppliers to ensure that high standards of animal welfare are met.

We continuously advocate for greater awareness of animal welfare issues across our supply chain, and regularly engage with our suppliers to understand their practices and challenges. We seek to improve the lives of farm animals by increasing the visibility and extending the development of good animal welfare practices across our whole supply chain, including within our primary producers and indirect users of animal-derived ingredients.

Our Animal Welfare Policy embraces the Farm Animal Welfare Committee’s stated Six Freedoms, identified to safeguard, and improve the welfare of livestock. They are:

• Freedom from hunger and thirst - by ready access to fresh water and a diet to maintain full health and vigour.
• Freedom from discomfort - by providing an appropriate environment including shelter and a comfortable resting area.
• Freedom from pain, injury, or disease - by prevention or rapid diagnosis and treatment.
• Freedom to express normal behaviour - by providing sufficient space, proper facilities, and company of the animal's own kind.
• Freedom from fear and distress - by ensuring conditions and treatment which avoid mental suffering.
• Freedom to undergo positive experiences - by providing appropriate conditions to experience positive emotions and encourage natural behaviour.

You can find all our policies and reports for 2021 at this link

As a business, we ensure the ingredients we buy are sourced to high standards:

• 100% of our dairy products are assured to various assurance schemes such as: Red Tractor (UK), RSPCA Assured (UK), Board Bia (Ireland), Sustainable Dairy Assurance Scheme, or Origin Green and Organic.
• 100% of our eggs are from cage-free hens (see for instance Mr Kipling).
• 100% of our eggs are KAT certified. KAT is seen as a higher animal welfare scheme.
• 100% of all other species are audited under various assurance schemes such as Red Tractor, RSPCA assured, EU standards or NZ standards.

Watch video interview of farmer Andrew Bray who supplies milk for Ambrosia

Whilst we were delighted to see this work recognised through a Tier 2 ranking by BBFAW in 2019, we continually seek to improve and so have set ourselves stretching intermediary goals to reach in 2023 and have included animal welfare goals in our Joint Business Plans with suppliers. We have also extended our work to reach the most difficult parts of our supply chain and rolled out our annual animal welfare survey to our animal derivatives suppliers to understand their practices and challenges. This work was recognised with our BBFAW score improving this year and retaining our Tier 2 ranking providing all our stakeholders with the independent verification and confidence in our commitments and practices.

We require all suppliers supplying products of animal origin to complete a set of questions on their approach to the management of animal welfare issues, as well as reporting on performance on various criteria. As part of this process, suppliers must confirm that they comply to the Premier Foods Animal Welfare Policy. In addition, we have incorporated animal welfare objectives into the joint business plans of our key suppliers to drive outcomes forward. In the event of non-compliance with the requirements of our animal welfare policy, our team will agree appropriate and time-bound, corrective actions with the supplier. Our supplier audit team will also arrange to visit the supplier's premises to review the process and suggest improvements to meet specification / animal welfare policy. If the supplier is then still unable to comply with our policy, we will serve notice and source from an alternative supplier that can meet our requirements.

In 2019, we have signed and agreed to the principles and policies of the Food Industry Initiative on Antimicrobials (FIIA). We sit on the Strategic Delivery Board of this body which brings together retailers, manufacturers, processors, and foodservice companies, to promote and support responsible antimicrobial use and action on antimicrobial resistance. This means that the farmers we work with stop using antibiotics as a proactive, preventative measure and only use critically important antibiotics, as defined by the European Medicines Agency (EMA), as a last resort to safeguard their animals’ welfare where no alternative treatment option is available.

For more information, please visit: https://www.farmantibiotics.org/progress-updates/retail-foodchain

We continue to champion high ethical labour standards throughout our supply chain and ask all of our ingredients and packaging suppliers to become members of Sedex, a not-for-profit membership organisation dedicated to driving improvements in responsible and ethical business practices in global supply chains. We use the Sedex platform and assessment tools to help us analyse and manage risk in our supply chains and to develop a supplier risk-based compliance audit programme, which drives greater transparency across our supply chains. By the end of the financial year, 88% of our direct suppliers were registered with Sedex, which represents 98% of all annual spend with direct suppliers.

All supplier food safety audits include ethical standards and labour practices, and where concerns are identified, we will carry out a SMETA audit, one of the tools of SEDEX. The SMETA audits enable us to assess the suppliers based on their organisation’s standards of labour, health and safety, environment, and business ethics. We assess suppliers by considering the supplier SEDEX risk rating, geographic sourcing region and nature of the product supplied. Where this assessment deems it necessary to complete an ethical audit, these are carried out by a member of the compliance team or our thirdparty auditing company. Due to the unprecedented current situation caused by Covid-19, our auditing plans have been disrupted and we were not able to travel to audit supplier premises. Whilst many of our standard food safety audits have now been completed remotely, we have only been able to complete two out of the four planned SMETA social audits across highrisk suppliers and are hoping to complete the remaining two in the 2021/22 financial year, once restrictions are lifted.

Premier Foods is committed to tackling all forms of hidden labour exploitation, including slavery and human trafficking. We have policies and procedures in place to help identify and eradicate these practices within our business and to reduce and eliminate risks in our supply chain.

To mitigate the risk of labour exploitation throughout our supply chain, we have established an Ethical Trading Policy, which is based around an internationally recognised code of labour practices. Each year, a copy of our Ethical Trading Policy is sent to our active suppliers, encouraging them to follow our practices. We support the Stronger Together initiative, a multi-stakeholder group of colleagues, labour providers, workers and their representatives, focused on addressing modern day slavery and thirdparty exploitation. All of our manufacturing sites were audited to support compliance with our policy, and we intend to continue to audit them regularly to maintain our focus on this important issue.

Key members of the HR and supply chain teams have received specific >training on modern day slavery and trafficking, designed to raise awareness of the issues and to empower them to recognise and respond to indicators of human rights abuse within the supply chain. All new employees joining our Procurement team receive this training as part of their formal induction process.

All our Modern Day Slavery policies and statements are available to view here

We take a risk-based approach to assessing and managing health and safety and work closely with our co-manufacturers in order to drive greater standards across our supply chain. This year, we had set a target to conduct eight detailed H&S compliance audits across co-manufacturers and onsite suppliers and to put in place targeted improvement plans if required. Unfortunately, due to Covid-19 restrictions, we have not been able to gain access to relevant vendors, so were unable to complete this task. We will continue to review restrictions linked to Covid-19 and understand when the audits can be rescheduled.

The safety and quality of our products is of paramount importance to us. Our internal technical quality compliance team focuses on controls across all of our manufacturing sites to ensure standards are maintained, supporting a range of initiatives, and driving continuous improvement and quality programmes. We operate a Food Safety and Quality Management System based around the British Retail Consortium (BRC) Global Food Standard version 8, with all sites (excluding Charnwood Foods) audited by an independent accreditation body to this standard. This year, adapting to the Covid-19 restrictions, BRC allowed greater flexibility in the audit processes – previously always unannounced, the audits were either unannounced, announced, or the sites saw their certification extended. Our current audit BRC status is rated at B or above, with 88% achieving A, AA, A+ or AA+ ratings.

We conduct food safety and compliance audits on all direct supply manufacturing sites and co-manufacturers, that are measured at medium or high risk. This risk is determined by performance, assessment of the supplier’s accreditation, geographic sourcing region and nature of the product supplied. These audits are carried out by a qualified and experienced member of the Premier Foods compliance team or our third-party auditing company. All suppliers in the lower risk category are assessed through a detailed remote audit. A particular focus for the business is the authenticity of the materials we purchase. We have been heavily involved in the establishment of the Food Industry Intelligence Network (‘FIIN’) where we sit on the Governing Board and chair their Technical Steering Group. This is a UK food industry initiative to share intelligence and data on food authenticity following the industry horse meat scandal of 2013. The group includes 43 members across food retail, foodservices and manufacturing, representing a very significant element of the UK food industry.

We have a targeted authenticity and safety surveillance programme in place for raw materials and have carried out circa 800 tests in the last 12 months. To support our food safety and quality standards, we have an internationally recognised laboratory, Premier Analytical Services (‘PAS’) carrying out research and analysis of food ingredients and packaging, employing around 48 scientists and performing approximately 100,000 tests per annum.