Modern Slavery Statement 2024

Introduction

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Thistle Seafoods has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. 

Thistle Seafoods has a zero-tolerance approach to any form of modern slavery.  We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. 

Our Business 

Thistle Seafoods is a private label manufacturer of chilled and frozen coated and added value seafood and non-seafood products.  We employ more than 650 staff across both of our sites; 460 and 228 staff at our Boddam and Uddingston sites respectively. Our facilities are accredited to the highest BRC Grade A standards.  We currently supply major retailers and food service companies in the UK, as well as Europe, North America, and Australia. 

Our High-Risk Areas 

The areas we believe that are at the highest risk for modern slavery occurring is within our raw material and ingredient supply chain.  We have approximately 106 tier one suppliers of raw material and ingredients which are located across several different counties.  We recognise that our supply chains are complex and go beyond tier one.  For example, with regards to fish, the supply chain is long with multiple tiers, which go as far back as the fishing vessels.  The raw material can move through multiple areas and factories before arriving at Thistle Seafoods, which makes the supply chain complex and difficult to manage.   

Thistle Seafoods operates a supplier policy and maintains a preferred supplier list.  We conduct due diligence on all suppliers before allowing them to become a preferred supplier.  This includes an online search to ensure that a particular organisation has never been convicted of offenses relating to modern slavery.  To mitigate the risk further, we RAG rate our suppliers based on information from their self-assessment questionnaire (SAQ). The questionnaire contains sections specifically asking about modern slavery and child labour and must be completed and submitted prior to supply. From this we audit high risk tier one factories and ensure that they adhere to the correct standards.  This includes providing them with our Social Compliance and Ethical Policy and asking them to sign an acknowledgment confirming that they understand it and will work to the standards identified. 

Our Policies and Practices 

Thistle Seafoods is a registered AB member of SEDEX.  This platform allows us to view and run reports on our suppliers’ ethical data, manage information regarding our own facilities, and share information with our customers.  In addition, we operate several internal policies to ensure that we are conducting business in an ethical and transparent manner.  These polices are reviewed and updated on an annual basis.  They include: 

Social Compliance and Ethical Policy 

This policy sets out the specific standards the organisation expects its suppliers to meet in relation to human rights, environmental impacts, and ethical business practices.  It also outlines that the organisation’s employees and directors must carry out their business and perform their duties to the highest ethical standards and in compliance with all relevant legal principle.  This includes when dealing with employees, customers, suppliers, and all other stakeholders. 

Recruitment Policy 

We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees, to safeguard against human trafficking or individuals being forced to work against their will.  

Any employment agency that supplies temporary labour to us are subject to a labour agency provider audit every six months.  These audits ensure the following:  

• They hold the required Gangmaster and Labour Abuse Authority Licence.
• They are members of the Association of Labour Providers (ALP) and are aware of and are operating to the standards of the Stronger Together Initiative. 
• There is a Service Level Agreement, Terms of Business and Supply Service Schedule in place between both parties. 
• They hold the relevant documents on the personnel they employ i.e., right to work in the UK, contract of employment, training records, literacy information, food handler’s agreement, etc.
• They adhere to working regulations and pay legislation.
• They demonstrate commitment to, and application of, the requirements of the ETI base code. 

Whistleblowing Policy 

We are committed to upholding the highest standards of conduct and ethics in all areas of the organisation.  In line with this commitment, we have appointed an external, independent whistleblowing service called SeeHearSpeakUp.  If any member of staff has a serious concern about any aspect of the organisation’s work, how colleagues are being treated, or practices within our business or supply chain, they are encouraged to come forward and voice those concerns in a safe and secure manner.  All concerns are taken seriously and investigated appropriately. 

Equal Opportunities Policy 

We are committed to promoting equal opportunities in employment.  All employees and job applicants receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex, or sexual orientation (‘Protected Characteristics’). This policy applies to all aspects of employment with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.  All managers are responsible for ensuring all employees receive the same treatment and opportunities irrespective of their Protected Characteristics.  All staff are responsible for not discriminating against their colleagues, customers, or suppliers during their employment. 

Grievance Policy and Procedure

A formal grievance policy is in place to support any member of staff wishing to raise concerns or issues through an official and confidential process. All grievances are treated seriously, investigated fairly, and addressed in a timely manner. We actively monitor the volume and nature of grievances received, document the outcomes, and assess whether further action or policy adjustments are required to prevent recurrence and improve working conditions.

Bribery Policy 

It is our policy to conduct all our business in an honest and ethical manner.  We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.  This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners. 

Training 

We ensure that key members of staff who undertake audits of supplier sites have a good understanding of modern slavery, can identify the signs of it and are aware of the process to follow if they suspect that it is taking place within our supply chain. In addition, we include information regarding modern slavery within our induction.  This includes showing a Stronger Together approved video regarding modern slavery, highlighting what the signs of modern slavery are and how it can be reported.  All members of staff must attend the induction prior to commencing work with us. There is refresher training every 3 years for all staff. We also have the Stronger Together posters displayed in multiple languages across our sites, to remind staff of the signs of Modern Slavery and how it can be reported. Representatives from the Ethical working group including Technical, Buying, HR and CSR have completed Stronger Together modern slavery training.

Key Performance Indicators 

To assess the effectiveness of the measures we apply the following key performance indicators (KPI’s), comparing our previous financial year results with the current financial year results.

Key Performance Indicator	FY 2022	FY 2023	FY 2024
% of staff that have completed the modern slavery awareness session at introduction	100	100	100
Number of modern slavery cases identified on site	0	0	0
Number of modern slavery cases identified in our supply chain	0	0	1
% of new suppliers that have completed our onboarding SAQ	100	100	100
% of eligible tier 1 raw material suppliers with a modern slavery statement on the UK register or website*	56	87	94
% of eligible tier 1 raw ingredient suppliers with a modern slavery statement on the UK register or website*	48	88	79
% of tier 1 or 2 manufacturing sites of raw material & ingredients linked on SEDEX***	n/a	n/a	76
% of production managers/supervisors with additional training in modern slavery awareness	n/a	n/a	6

 

2024 Media Attention

In 2023, The Ocan Outlaw Project and similar NGO campaigns highlighted the risk of human rights abuses in seafood supply chains, in particular China. The CSR department continues to closely track these allegations and are working with suppliers to ensure our supply chains are not associated.

Our Progress 2024

Modern Slavery Outreach

The CSR Unit has continued to engage with national bodies and relevant trade groups to track and align with Modern Slavery best practices (e.g., Seafood Ethics Action (SEA) Alliance, Seafish & MSC). We have continued to join roundtable discussions as a collaborating partner with Scotland Against Modern Slavery (SAMS). All members of the Ethical Working Group have now completed relevant Stronger Together training modules.

Internal Training

We have introduced modern slavery refresher training. This will be carried out every 3 years, or more regularly if any instances of modern slavery are found on either site.

Association of Labour Providers (ALP)

ALP is a not-for-profit trade association that promotes responsible recruitment so that labour provision is recognised as a model of sustainable good practice.  Thistle Seafoods is an associate member and actively engage in the labour user round table discussions, monthly member support forums, workshops and training they provide.

SEA Alliance

Thistle Seafoods is now a membes of SEA Alliance. This organisation is a collaboration of retailers and seafood businesses that aims to strengthen human rights due diligence carried out by the global seafood supply chain and helps ensure human rights are respected.

FNET (Food Network for Ethical Trade)

Thistle Seafoods are now members of FNET. This organisation is a collaboration of retailers and food businesses that aims to strengthen human rights due diligence carried out by the global land-based food supply chain and helps ensure human rights are respected. The FNET platform and forums highlight global issues of human rights abuses in multiple commodities, which will allow us to focus our attention on the relevant areas.

Ethical Risk Matrix (ERM) – Quarterly Review

The CSR department populate and maintain the ERM which is aligned with our Preferred Supplier List. This list includes seafood, ingredient and packaging suppliers.  The ERM details multiple indicators of forced labour as well as our suppliers’ SEDEX performance. This matrix is reviewed on a quarterly basis and the suppliers with the most severe SMETA NC’s as well as the highest risk supplying sites are shortlisted for review. These findings are discussed, and actions are taken. Based on the nature of the business relationship; detailed calls with suppliers will take place to remedy the situation or an alternative source will be explored.

KPI Development

**This KPI has been modified to include modern slavery or human rights abuse allegations. If any are indicated, we will provide context and latest situation report.

***The previous KPI relating to % of suppliers linked on SEDEX focused solely on tier 1. To strengthen our HRDD, Thistle Seafoods has made the decision to link with the last manufacturing site in the supply chain. Our previous KPI would have covered some manufacturing sites and in some cases agents/sales offices. We view manufacturing sites as higher risk than an agent/sales office. Our ambition to link with 100% of the last manufacturing sites will provide greater visibility of our supply chain and indicate areas that need focus.

Traceability

The CSR department continues to improve visibility at vessel level to ensure that IUU (Illegal Unreported & Unregulated) fishing is not taking place within our supply chain. Vessels that are involved in IUU would present a high risk for human rights abuses.

Future Plans 2025

KPI’s

Our aim is to improve our KPI scores mentioned above. We also plan to include the following KPI:

• % of tier 1 or 2 manufacturing sites of raw material & ingredients completed SAQ to 100%

Internal Training

Production supervisors and managers will be provided with additional modern slavery training. This will be refreshed every 3 years. We will continue to train relevant staff via Stronger Together courses.

Whistleblower Service

Thistle Seafoods whistleblower service will continue to be offered free of charge to our supply chain and communicated via our Social Compliance and Ethical Policy.

Approval for this Statement 

This statement was approved by the Board of Directors on the 19th June 2025.

Pamela Macdougall

19th June 2025