As a responsible food producer Kavli recognises its responsibility to deliver safe food.
Product quality and food safety have very high priority throughout our organization, and we are continually seeking to improve our standards further.
We maintain the same product quality and safety standards regardless of where the product is produced or sold and we place great demands on our production sites to ensure they employ quality and food safety standards to the requirements of the Global Food Safety Initiative.
HACCP (Hazard Analysis Critical Control Point)
Kavli is committed to ensuring that our products are safe throughout the whole food chain – from raw materials to finished products. To ensure this is done, we employ risk assessments based on HACCP (Hazard Analysis Critical Control Point) principles as the basis for all product manufacture and supply.
HACCP is a method of risk assessment aimed to identify hazards potential in production process in order that they can be prevented, eliminated or reduced to an acceptable level.
Kavli use the HACCP (Hazard Analysis Critical Control Point) food safety management system to maintain product safety. This management system is a globally recognised method of risk assessment, aimed at identifying potential hazards in the production process so that they can be prevented, eliminated or reduced to an acceptable level.
Kavli use multidisciplinary teams to create, approve and implement procedures for quality control and risk assessment based on these HACCP principles. These routines apply from supply and storage of raw materials through manufacturing, distribution of finished products and traded goods.
Some foods and ingredients can be allergenic. Wherever possible Kavli will avoid using ingredients known to be associated with allergenic reactions in consumers.
Kavli wants as many people as possible to be able to consume our products. At the same time, we know that some people can adversely react to certain ingredients used in food production. These ingredients are called allergens and Kavli seeks to avoid using known allergens where there are suitable alternatives.
This includes all food products produced or supplied by Kavli, as finished packaged products merchandised commodities.
All Kavli businesses have in place procedures for allergen management to be able to control the risks associated with allergy-causing substances and all Kavli products that contain allergens will be clearly and accurately labelled in compliance with regulatory requirements.
Kavli is committed to protecting the consumer from counterfeit commodities and food and has therefore incorporated practices and procedures to ensure that that fraudulent activity is prevented in its supply chain.
Food can be the effect of unethical actions or false representation with the purpose of financial gain. This may however pose a threat to consumers and a business’s viability.
As a leading manufacturer of food products Kavli is a commitment to producing safe, legal and healthy products that match or exceed the customers ‘ expectations of quality.
Kavli therefore conduct risk assessments in relation to the threats and vulnerabilities within our supply chain to ensure that our products and consumers ae protected. Kavli to do this, by making sure that all supplies of the raw material are sufficiently audited and tested for potentially fraudulent actions, such as the deliberate substitution, dilution, addition or misrepresentation of materials.
Kavli also ensure that its facilities, processes and distribution chain is designed and maintained in such a way that prevents the intentional addition of counterfeit materials in our products or merchandise.
Kavli employs current best practice routines and equipment to detect any potential foreign materials from contaminating our products.
Raw material quality and packaging material.
Product quality is dependent upon the quality of raw materials, processing and packaging. Kavli has established procedures for the approval of the suppliers and the receiving control of raw materials and packaging to ensure the best possible standards are maintained.
All Kavli businesses employ equipment and routines to prevent, identify and detect foreign objects in products so that end users are not exposed to the risk of injury from foreign bodies in our products.
The selection of equipment to detect possible foreign objects is done on a product risk basis that considers the nature of the product and the process of manufacture.
All such equipment undergoes a documented approval processes to ensure that it is fit for purpose.
As a supplier of food products Kavli have a responsibility to contribute to a healthy and varied diet. Kavli therefore take into account the health aspects of the consumer in the development of new and existing products. We are responsive to what customers think and the consumer’s attitudes and wishes where we believe this is appropriate and possible.
At Kavli we believe in the following:
Kavli does not use genetically modified ingredients in its products.
Kavli undertakes to only use raw materials and ingredients that are produced using traditional production methods and we will ensure that we do not use ingredients derived from genetically modified organisms (GMOs) as ingredients in our products. Kavli has strict rules in place with its suppliers with regard to the specification and supply of ingredients to ensure this.
Kavli is aware that it is possible that very small amounts of genetically modified material may enter materials by accidental cross contamination in the supply chain. The maximum proportion of such trace contamination tracks from genetically modified material sources will be such that it does not require GMO labelling as required by European GMO legislation.
Kavli will only use sustainably produced palm oil in its products.
Palm oil has properties that make it suitable for use in a variety of food products. To ensure that the shipment of palm oil and the palm oil contained in compound ingredients used by Kavli does not have a negative impact on the local environment or the community where palm oil is grown, we aim to use only sustainably produced palm oil that does not have a negative impact on the region where the Palm trees are grown or the people who live there.
We will therefore only buy palm oil from:
Soy is one of the world’s most important commodities. Kavli only use soy produced in accordance with environmental and ethical good practice according to RTRS (Round Table Responsible Soy)
Soy is one of the world’s most important crops with respect to the production of protein and fat. Most of the commercially produced soybean is used for animal feed, but it is also a common ingredient in the production of meat, milk, eggs and farmed fish.
When sourcing soy for use in products, Kavli will take responsibility for soy consumption and undertake to only use soy that is produced in a sustainable way, from sources that are produced with respect for people, animals and the environment as defined by the “Round Table on Responsible Soy (RTRS)”.
Sugar, fat and salt
Kavli recognise that Health Authorities would like to reduce the intake of sugar, fat and salt in the population. It is our intent to help in this work by customizing our products where possible to reduce the levels of these components in our products.
Many government agencies recommend consumers to reduce their intake of added sugar, fat and salt in the daily diet. A varied diet and a healthy lifestyle is crucial to reduce the risk of diseases such as cardiovascular diseases and diabetes.
Kavli supports the view that the intake of sugar should be limited in line with the advice of health authorities and from organizations such as the WHO (World Health Organization), but believes that some added flavour and sweetness is important for the taste and enjoyment of our products.
Kavli has committed to keep the level of added sugar as low as possible whilst at the same time maintaining the great taste of our products. Kavlis’ goal is to reduce sugar levels in products, and where possible replace sugar (fully or partly) with other suitable and approved sweeteners.
Kavli also aims to reduce the use of saturated fat and to avoid the use of trans-fats in the raw materials which are included in our products by carefully selecting the ingredients we use.
Sodium is a natural component of many raw materials. Sodium chloride as salt, will affect a product’s taste and can also be important in to maintain the product’s consistency and structure.
Sodium also has preservative properties and is found in several different types of salts, including sodium phosphates which are used by Kavli to give our products their creamy consistency.
Kavli supports the’ view that the intake of sodium should be limited in line with the recommendations of the WHO (World Health Organization). At the same time, we know that the level of salt will affect a product’s taste as well as other properties. Kavli is committed to keeping the sodium level of products as low as possible whilst maintaining the flavour, consistency and preservation of the product. Kavli will only select ingredients for use in our products that comply with all applicable food labelling regulations.
Kavli is committed to producing safe food and will ensure the ingredients they use meet all necessary regulatory requirements with respect to the content of possible contaminants such as residues of the veterinary medicine, pesticides, heavy metals and other contaminants.
Kavli has a responsibility to produce food that is healthy and safe to eat and does not contain traces of hazardous chemicals. We will therefore ensure that the ingredients we use meet all applicable regulatory requirements for food products.
We will ensure our products meet all appropriate legislation for the presence of contaminants such as heavy metals, pesticides, residues of the veterinary medicine or similar contaminants, and make sure or suppliers comply to strict specification to comply with this.
ORGANISATIONAL STRUCTURE – KAVLI UK
Kavli UK is part of the Kavli Group. The Kavli Group has been operating in international markets for more than 100 years. Today our products are present in more than 20 countries around the world. With products and product expertise from all the Kavli companies, the Kavli Group offers nutritious, quality food for consumers on all five continents of the world.
The UK was one of the early export markets for Kavli and its Primula Cheese brand was first sold in the UK in 1929. The first UK factory was opened in 1936 near to Newcastle-upon-Tyne and under the leadership of Knut Kavli, the UK business was established and is now situated on the Team Valley in Gateshead. In 1997 Kavli UK acquired the Castle MacLellan pâté business located in Kirkcudbright in South West Scotland. In 2013 Kavli UK acquired the St Helen’s Farm goats’ milk business located close to York, which it subsequently sold in 2021. Kavli UK currently has around 250 employees across its two sites and makes a range of food products including cheese spreads, snacks and dips under the Primula brand. Chilled pâté is made under the Castle MacLellan brand. Kavli UK also manufactures a range of private label products for UK supermarkets.
Kavli UK takes a zero-tolerance approach to slavery and human trafficking. We aim to educate our colleagues and supply chain by working closely with the Gangmasters Licencing Authority by keeping up to date with current legislation. Our Ethical Guidelines and Dignity at Work policies have underpinned the basis of our statement.
Kavli UK ensures that our labour providers hold a valid Gangmasters Licencing Authority licence and that they follow the provisions of the Gangmasters Licencing Act 2004, adhering to all their standards protecting workers from poor treatment and exploitation. This includes working hours, training, terms and conditions, national minimum wage and transport ensuring that our labour providers meet basic safety and welfare standards.
In 2019, as part of our due diligence, Kavli UK reviewed the controls put in place by our supply chain to establish, assess and monitor areas of potential risk. This assessed our supplier’s adoption and dissemination of the ETI Ethical base code allowing us to scope for future support and collaboration in line with our commitment under the Modern Slavery Act 2015. Criteria focused on their commitment to creating shared values, sustainability and compliance.
Kavli UK believes that by maintaining links with organisations such as Clearview, Sedex, Gangmasters Licencing Authority and Stronger Together we have created a firm basis for future due diligence. Stronger Together plays a key role in providing Kavli UK with the knowledge needed for effective implementation of a Modern Slavery strategy within its own supply chains, and by helping us to understand how we might identify modern slavery.
Kavli UK will continue to review both ours and our labour providers’ involvement and membership of Clearview, to ensure global social certification with the objective to drive responsible recruitment practices in our supply chains. The Clearview Technical Advisory Committee focus on the proactive measures that labour recruiters and providers have implemented to ensure that workers are not subjected to debt bondage, forced labour or other forms of hidden exploitation.
Kavli UK will not maintain business relationships with any suppliers that we know violate the human rights of its own colleagues. Kavli UK will also undertake due diligence when considering contracting with new suppliers.
AREAS OF RISK
Our supply chain review provided a risk assessment which allows Kavli UK to implement an auditing and monitoring programme commencing with the higher risk suppliers. Kavli UK is a member of the Supplier Ethical Data Exchange (Sedex) and all Kavli UK businesses are regularly audited by third parties who publish our results, thereby ensuring visibility to our customers and suppliers.
Kavli UK is not aware that any of our supply chain businesses have been identified as being at risk of incidents of forced or compulsory labour. Nor is Kavli UK aware of incidents of child labour being used. We have not received any human rights-related grievances in relation to our business or those of our supply chain.
Kavli UK has a long-standing relationship with the Gangmasters Licensing Abuse Authority which plays a role in our supply chain.
In the past, members of the HR team have undergone Stronger Together training. Stronger Together is a UK multi-stakeholder collaboration between supermarkets, the Association of Labour Providers, Clearview and the Gangmasters Licencing Authority. Kavli UK has embraced the Stronger Together programme across all our UK sites. Kavli UK will educate our colleagues to recognise the risks of modern slavery and human trafficking in our business and supply chain through incorporating the Stronger Together video/training package as part of our induction procedures.
Kavli UK actively encourages all colleagues to identify and report any potential breaches of its Modern Slavery Policy and have mechanisms in place to increase the visibility of issues through the Stronger Together hotline and our own confidential colleague “Whistle B” website. Colleagues are made aware of the stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate it from our business and supply chain. Kavli UK supports the principles of the Modern Slavery Act and its provisions around slavery, servitude, forced labour and human trafficking, including provision for the protection of victims.
This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes Kavli UK’s Slavery and Human Trafficking statement for the financial years 2019/2020.