Boutinot Limited is committed to preventing modern slavery and human trafficking in all areas of our business and supply chains. This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and sets out the steps taken by Boutinot Limited and the wider In Vino Group during the financial year ending 2025 to address the risk of modern slavery.
We take a zero-tolerance approach to modern slavery and human trafficking and are committed to acting ethically, transparently, and responsibly in our operations and business relationships.
2. Organisation Structure and Business
This statement applies to Boutinot Limited and the wider In Vino group, which operates globally across the United Kingdom, France, the United States, New Zealand, and South Africa.
Our activities include:
We work with a diverse global supply chain, including wine producers, growers, cooperatives, bottling facilities, logistics providers, and professional services.
3. Supply chains
Our supply chains are international and multi-tiered. While we maintain direct relationships with many suppliers, we recognise that we do not always have full visibility of lower-tier suppliers. We therefore take a risk-based and proportionate approach to supplier due diligence, focusing on higher-risk regions, activities, and labour-intensive stages of production
4. Modern Slavery Risks
The wine and agricultural sectors carry inherent modern slavery risks, particularly due to:
We recognise that risks may be heightened in certain geographies and during harvest periods and tailor our oversight accordingly.
5. Policies and Governance
Our approach to preventing modern slavery is embedded within our wider governance and people framework. Key policies include:
These policies collectively prohibit forced labour, child labour, exploitation, and discrimination, and promote fair pay, safe working conditions, and ethical business practices.
6. Due Diligence and Supplier Management
We operate a supplier approval and onboarding process which includes completion of a Supplier Approval Questionnaire and ongoing engagement in line with our Agency and Distribution Supplier Guidelines. These processes capture information relating to quality, traceability, health and safety, and ethical standards.
We are in the process of introducing a formal Supplier Code of Conduct to further strengthen and clarify our expectations relating to labour standards, human rights, and compliance with modern slavery legislation.
7. Training and Awareness
All employees are required to complete annual modern slavery awareness training via our e-learning platform, Cademi, which includes a dedicated modern slavery and human trafficking module. Training is assigned annually, with completion monitored by the People Team, and all employees are expected to complete the module by the end of February each year. New starters are assigned the training as part of induction.
8. Reporting Concerns
Employees and third parties are encouraged to raise concerns relating to modern slavery or human trafficking through our Whistleblowing Policy. Reports can be made confidentially and without fear of retaliation. Concerns are investigated promptly and escalated where appropriate.
9. Governance and Responsibility
Operational responsibility for modern slavery sits within Boutinot’s people and legal governance framework. Oversight is led by the Group Head of People, with legal advice and support provided by the Company Lawyer. Significant concerns are escalated through senior management governance structures and, where appropriate, to the Board.
10. Continuous Improvement
We recognise that addressing modern slavery is an ongoing process. During 2025, our focus includes:
11. Approval
This statement has been approved by the Board of Directors of Boutinot Limited
Managing Director – Dennis Whiteley
26/01/26
