Modern Slavery Policy

Carluccio’s Ltd is a single brand serving Italian food and drink operating over 90 locations across the UK and Ireland.

We operate with a turnover in excess of 110m and employ over 2750 people across our business.

Our supply chains include the provision of food and drink products, using over 100 suppliers, along with various other support goods and services such as waste collection and IT suppliers, to enable us to provide food, drink and retail products to our guests.

We take great care in selecting our sourcing and supply chain partners. We source from a broad range of suppliers from around the world, with a view to ensuring the best ingredients feature in our menus and have been produced in the right environment.
We have produced and issued a Code of Conduct for Suppliers – we expect full compliance with this. This is been based upon the Ethical Trading Initiative (ETI) Base Code for ethical sourcing and reflects all relevant International, EU and UK legislation including the UK Modern Slavery Act 2015. This Code contains requirements that:

• Employment is freely chosen
• Freedom of Association is respected
• Working conditions are safe and hygenic
• Child labour is not used
• Living wages are paid
• Working hours are not excessive
• No discrimination is practiced
• Regular employment is provided
• No harsh or inhumane treatment is permitted

We have completed the initial stages of our supplier mapping and aim to have this fully completed in time for our next policy review. We will continue to ensure that our suppliers have committed to the principles laid out in our Code of Conduct.

We are proud of our fair and consistent approach to recruitment that aims to ensure that all candidates have a fantastic experience with us from start to finish. It is the policy of Carluccio’s to select candidates and offer promotion based on individual ability to undertake the role.
We are committed to working in accordance with the following legislation which prohibits discrimination in employment (including the recruitment & selection process); Equal Pay Act 1970, Sex Discrimination Act 1975, Race Relations Act 1976 / Amendment Act 2000, Parental Leave Regulations 1999, The Disability Discrimination Act 1996, 2005, 2006, EU Directive 1000/78/EC on Equal Treatment in Employment, Equality Act 2006 and Work and Families Act 2006. In using objective criteria related to the requirements for the role, candidates are given the opportunity to demonstrate their abilities regardless of their:

Additionally, we remain committed to ensuring all our employees have the correct right to work documents, ensuring that the successful candidate is eligible to work in the UK. In accordance with the amendment to the Immigration, Asylum, and Nationality Act 2006, effective from 29 February 2008, we are required to provide proof of the Right to Work in the UK and we work hard to ensure we have robust processes in place to uphold this legislation.
Furthermore, we remain committed to ensuring every employee is given the training to equip them with the knowledge and skills to carry out their role successfully & work in accordance with all company policies, including our modern slavery policy.
In our continuing effort to ensure our teams are set up for success and work in accordance with all policies, we will be introducing a new Elearning platform in 2019.

Carluccio’s is committed to achieving the highest standards of openness, integrity, honesty and accountability and therefore we expect everyone who works in our business to demonstrate the same standards and values in everything we do.  In order to maintain these standards, we encourage our teams to report any public interest concerns that show serious malpractice or wrongdoing.

The law provides protection for employees who raise legitimate concerns about specific matters. A “qualifying” disclosure is one made in the public interest where there is a belief that one or more other following matters is either happening, has happened or is likely to happen:

• A criminal offence
• Carluccio’s not obeying the law (e.g. not having the right insurances);
• A miscarriage of justice
• A Health and Safety danger
• Damaging the environment
• Covering up wrongdoing
• Deliberately concealing information relating to any of the above.

We remain committed to ensuring concerns raised are investigated thoroughly and without prejudice.

Carluccio’s is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Carluccio’s has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

Carluccio’s will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.

Carluccio’s recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.

The relevant issue expert develops our policies and the Directors share responsibility. All policies are approved by the Chief Financial Officer and will undergo annual reviews to ensure they remain effective and legally compliant.
Signed: Andrew Campbell
Position: CFO
Dated: August 2018
Date of next review: July 2019

Registered under Carluccio’s and C12014.