Modern Slavery Statement


Our Business, Structure and Supply Chains

It is required under the Modern Slavery Act (2015) that businesses state the actions they have taken during the financial year to ensure that modern slavery is not taking place in both their operations and supply chains. Here at First Grade International we see slavery, forced labour and human trafficking as fundamentally unacceptable within our business. As a company we firmly support the movement for transparency and collaboration from businesses to eliminate this risk.

This statement refers to the financial year ending 31.12.2018.

First Grade International Limited was established in 2002 as a sales and marketing operation dedicated to the supply of high-quality food ingredients for UK and international based companies. Subsequently the business has expanded to include a consumer focused brand; Koko, which manufacturers and sells coconut based, ‘free from’ products in the UK and Internationally.

  • £60 million revenue in 2018
  • 38 employees in the UK
  • 32 manufacturing sites used
  • 300 customers supplied by us
  • Bulk Ingredients
  • 200 Products supplied by us
  • 11 sourcing countries
  • Retail Products

First Grade Internationals’ supply chain is both complex and extensive and is ostensibly divided into two main streams; one for bulk products and the other for Koko branded retail products. Our suppliers provide both raw materials and finished goods for manufacturing across our core product areas, which include; coconut products, fruit, oil, nuts and cocoa powder as well as provide contract manufacturing services for the supply of Koko Branded products. All areas of our supply chain are carefully monitored and audited by trained staff to make sure that legislative requirements of both UK Laws and International laws are being met.

In 2018 there were no reported breaches of the Modern Slavery Act 2015.

Our Policies

First Grade International’s Ethical Trade Policy

When dealing with suppliers, First Grade International Limited will endeavour to deal openly, fairly and adhere to contract terms.

First Grade International Limited expect suppliers to develop equal opportunity policies within employment without discrimination on grounds of race, religion and gender or other arbitrary basis.

Employees shall be free to join lawful associates: forced labour or coercion at work is unacceptable.

Employees should not be forced into involuntary labour.

Pay will at least meet statutory minimum national or local law.

Pay should also reflect what is needed to maintain family life above subsistence level.

The use of child labour is strictly forbidden.

First Grade International’s Recruitment Policy

As a company we will endeavour, through appropriate training, to ensure that employees making selection and recruitment decisions will not discriminate, whether consciously or unconsciously, in making these decisions. Job descriptions, where used, will be in line with the equal opportunities policies, with all new employees being subject to pre-employment checks to confirm their identity and right to work in the UK.

First Grade International’s Terms and Conditions of Purchase

Here at First Grade International we are committed to ensuring that all our suppliers adhere to the highest of standards of ethics. Therefore, our suppliers are required to demonstrate that they provide safe working conditions, act ethically and within the law in their use of labour and treat workers with dignity and respect. Failure to comply with the Modern Slavery Act (2015) will result in the termination of the business relationship.

Due Diligence Processes

First Grade International owned or contracted production sites are required by our company policy to be active members of SEDEX and to undertake an independent third-party ethical audit; SMETA or SA8000 certification in order to build trust and transparency throughout the supply chain.

Each year our customers are required to read our updated code of practice so that they understand what is required and expected of someone associated with First Grade International.

In 2019 FGI will be developing a Responsible Procurement Code to further reinforce its commitment to eradicating modern slavery within its supply chain.

Steps to Assess and Manage Risks

We are aware that the threat and the risk of modern slavery is extremely dynamic and can evolve quickly throughout the supply chain. As a result, we are regularly assessing and responding to risks in the country of origins associated with our supply chain to help ensure that our processes and supply chain remain free from modern slavery practices.
All our staff, customers and other business partners are encouraged to report any incidence or suspicion of modern slavery at the earliest opportunity to:

  1. If they are a member of staff, their line manager
  2. If they are a supplier, the primary account manager or business contact within our company.

This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

At first Grade International, any member of staff who is found breaching FGI’s policy on Modern Slavery will face disciplinary action, which could result in the dismissal for misconduct or gross misconduct.

In the event that a breach of the Modern Slavery Act by one of our suppliers is reported, the relevant member of staff will report such a breach to the Senior Management Team. FGI may terminate its relationship with a customer or supplier if it is found to be in breach of this policy and fails to take the required steps to remedy any breach.


At First Grade International, 13 members of staff from a range of our company departments have willingly taken part in training to help tackle the challenging human right issues including modern slavery through the Ethical Trading Initiative.

We are continuing to develop targeted training for our employees who are most directly involved in making purchasing decisions which could impact the risk of modern slavery throughout our business. We do also recognise that modern slavery is of a complex nature and so have sought to develop both informative and accessible training for all our employees within the business to raise their personal awareness of the risks posed to our company and how they as individuals have a part to play in delivering our vision.

David Armstrong
General Manager

Melvin Tay