MODERN SLAVERY STATEMENT
INTRODUCTION
This is a statement under s.54 of the Modern Slavery Act 2015. It relates to the business of Falfish (Holdings) Limited and its subsidiary Falfish Limited (together referred to as “Falfish”).
We are committed to improving our practices to combat slavery and human trafficking. This statement sets out Falfish’s actions to understand all potential modern slavery risks related to the business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in the business and our supply chains.
As part of the fishing sector, Falfish recognise that we have a responsibility to take a robust approach to slavery and human trafficking. The Company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.
OUR BUSINESS AND ORGANISATIONAL STRUCTURE
Falfish supplies fish to customers throughout the United Kingdom and Europe, controlled from its Head Office in Redruth, Cornwall. We have over 150 employees, all of which are recruited through the Company’s Head Office, which also sources any sub-contractors when required. Due to the seasonal nature of the business operation, we engage a number of temporary staff through employment agencies which averages 35 people per month during a 12 month period.
OUR SUPPLY CHAINS
Suppliers providing goods and services to the Company are predominately based in the United Kingdom or Europe. Global suppliers can be used on occasion as necessary.
Falfish operates a supplier policy and maintains a preferred supplier list. We endeavour to build long term relationships with key suppliers, and all procurement is subject to the relevant criteria being satisfied prior to engagement. We complete due diligence checks on all suppliers prior allowing them to become a preferred supplier, including an online search if necessary to ensure that the particular organisation has never been convicted of offences relating to modern slavery.
In addition to the above, as part of the Company’s contract with suppliers, the supplier is required to confirm
that:
1. They have taken steps to eradicate modern slavery within their business.
2. They hold their own suppliers to account over modern slavery.
3. They pay their employees at least the national minimum wage / national living wage where applicable.
4. The Company may terminate the contract at any time should concerns in relation to modern slavery arise.
OUR POLICIES ON MODERN SLAVERY AND HUMAN TRAFFICKING
The Company operates the following policies that describe its approach to the identification of modern slavery risks and the steps to be taken to prevent slavery and human trafficking in its operations:
• Modern Slavery – The Company is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
• Whistleblowing – The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains, of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Valuing Dignity and Diversity at Work – The Company’s Valuing Dignity and Diversity at Work policy makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.
• Equal Opportunities – The Company promotes the right for all workers, customers and other business partners to be treated without discrimination, especially on the grounds of protected characteristics.
• Bribery – The Company is committed to ensuring adherence to the highest level of ethical standards.
• Supplier Code of Conduct – The Company is committed to selecting suppliers who are known to adhere to the highest standards of ethics, treat workers with dignity and respect, and act ethically and within the law in their use of labour. However, any serious violations of the Company’s supplier code of conduct will lead to the termination of the business relationship.
• Recruitment/Agency Workers – The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
DUE DILIGENCE PROCESSES FOR MODERN SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we have in place systems to:
• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.
The Company is subject to Ethical Audits with certain suppliers which demonstrates compliance and commitment on behalf of Falfish when working with our supply chain.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values and ethics, we have in place certain supply chain compliance programmes.
This includes Gangmaster Licencing audits for all recruitment / employment agencies on a six-monthly basis. Failure to meet the criteria may result in Falfish terminating the business relationship with the recruitment / employment agency.
TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.
The Company conducts training for its procurement / buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within the Company’s supply chain.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We will continue to build on the progress we have made this year. We will continue to improve communication on this topic with our supply chain and welcome opportunities to collaborate with suppliers. We routinely monitor our staff and agency providers to ensure we are complying with the Modern Slavery Act 2015. This is done via external audits and measures compliance.
BOARD APPROVAL
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending March 2021.
This statement has been approved by the Company’s board of directors who will review and update it annually.
Managing Directors Signature:
Mark Greet
Date: 21st February 2021