Modern Slavery Policy 2023

Boparan Restaurant Group Modern Slavery Statement 2023

The document has been published in accordance with the Modern Slavery Act

2015 (MSA) and constitutes the slavery and human trafficking statement for

Cinnamon Collection Ltd and Boparan Restaurant Group plc and its

relevant subsidiaries for the financial year ended 31 December 2023. (BRG).

References in the statement to “forced labour” mean any conduct which an

offence under Part I of that Act is including slavery, servitude, any type of

forced or compulsory labour and trafficking for the purposes of exploitation.


As an employer and provider if the goods and services for the customer, we

have a role to play in the fight against slavery, servitude, forced labour and

human trafficking (Modern Slavery). Boparan Restaurant Group (BRG) has a

desired zero tolerance approach to Modern Slavery of any kind in our

operations and supply chain. It is our responsibility to prevent and identify any

exploitation and to influence and work together with suppliers and business

partners to raise labour standards in our industry. Despite being a UK centric

company many component parts of the food we serve are sourced outside the UK

and it is our responsibility to promote high standards of ethical behaviour

across our supply chain in the food we buy and the services we procure.

We do not tolerate forced labour either within our business itself or within our

supply chain. We expect our supply chain (whether direct suppliers or those

that directly or indirectly supply our direct suppliers) to share the same values.

Our business

BRG is a significant player in the UK casual dining market, employing over

2,800 people. Our brands include Giraffe, Ed’s Easy Diner, GBK, Carluccio’s,

Fishworks, Cinnamon Collection Restaurants and Slim Chickens. As a

responsible business, we recognise our responsibility to ensure that our

business activities are guided by the careful balance of the interests of all our

stakeholders. For this reason, the company has established environmental and

social policies and procedures as well as programs that protect and sustain the

environment, workers within our supply chain and restaurants, and our


We have reviewed our business and our supply chain. Neither we nor, to the

best of our knowledge, our supply chain makes use of forced labour.

Supply chain purchasing model

Our product supply chains are extensive and global; we source over 3000

products from more than 250 suppliers whose supply chains span over 30 countries.

We operate a centralised procurement model in which we have established

strong relationships with food, service and non-food suppliers. We require all

of our direct suppliers to work closely with their suppliers, distributers, agents

and producers to promote total transparency and knowledge of the operations

within our supply chain.

We have reviewed MSA statements published by our suppliers on use of

forced labour to ensure that they in turn are taking what appears to us to be

appropriate steps.

New suppliers

We have a rigorous process for assessing new suppliers on their technical

capabilities and ethical credentials. We do not engage with business partners,

including suppliers, who do not meet our high standards.

Key members of our procurement team have been trained to identify the risk

of indicators of modern slavery and human trafficking in our supply chains and

in the procurements process we may seek to impose contractual obligations on

our suppliers under which they:

• warrant that their business and, to the best of their knowledge, their

own supply chain do not use forced labour;

• agree to provide us on request with responses to a self-assessment

questionnaire regarding use of forced labour and steps they have taken

to ensure it is not used by them or their supply chain.

• agree to permit us and third parties acting for us to inspect their

facilities, records and practices, to have access to their personnel and to

audit their business for the purposes of ensuring that they comply with

these obligations and that there is no use of forced labour.

• impose equivalent obligations on their own suppliers.

Supplier Ethical Data Exchange (SEDEX) and ethical audits

All new suppliers to the business are required to register with and complete

assessment’s within SEDEX. Following a review of the outcomes of these

assessments ethical audits may be carried out. It is our policy that any

suppliers who are deemed high risk, as identified by the SEDEX risk assessment

score, undertake an audit within three months of being identified high risk. A

preliminary desktop review of the suppliers has identified no high-risk

suppliers to our business.

Our people

All our employees are paid by bank transfer and we don’t allow payment to be

made into third party bank accounts thus minimising the risk of forced

compulsory labour. We do employ family members, however, where possible

we avoid this being in a direct reporting relationship and where it is their line

managers HR are aware and monitor the situation.


The relevant head of each business area such as Brand Operations Directors and

heads of the procurement, legal, property, finance and IT teams have

responsibility for their department’s compliance with our Responsible Sourcing

Policy. All policies are approved by the CEO annually.

Assessment of effectiveness in preventing Modern Slavery

We will continue to keep under review new risks as they emerge and carefully

monitor new suppliers and business activities. We believe in continuous

improvement in the prevention of Modern Slavery and we will continue to

review our ethical trading programme annually to ensure it reflects best


This statement was approved by the Board of Boparan Restaurant Group.


Satnam Leihal