Modern Slavery Statement 2025

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 750 staff across both of our sites; 477 and 292 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 100 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. Thistle Seafoods require potential suppliers to link on the Sedex platform prior to purchasing; allowing for further investigation into their HRDD performance. 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. These data populate our internal Ethical Risk Matrix (ERM) which is reviewed on a quarterly basis and forms part of our HRDD strategy. In addition, the CSR team chair a routine internal Ethical Working Group; comprising of a member from each department, including board members, to share and discuss relevant topics regarding human rights and ethical practices. 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, posted on our company website, 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 at least an annual labour agency provider audit.  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 and Contract 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. 

Gender Pay Gap and Diversity, Equity and Inclusion

The Company is committed to promoting gender equality, fair pay, and equal opportunity across all areas of the business. We aim to ensure that all individuals are treated with dignity and respect and that decisions relating to recruitment, pay, development, and progression are made fairly, transparently, and consistently.  We recognise that achieving gender equality and broader diversity, equity, and inclusion outcomes requires ongoing management attention, data‑led review, and practical action. This policy sets out our approach and commitments in these areas.  This policy applies to all employees, managers and directors of Thistle Seafoods Limited.

Dignity at Work: Addressing Bullying, Harassment, Sexual Harassment and Inhuman Treatment

The Company is committed to providing a working environment where everyone is treated with dignity and respect, free from bullying, harassment, sexual harassment, and any form of inhumane or harsh treatment.  This policy applies to behaviour in the workplace and outside the workplace where work-related activities take place (including business trips, events, and social functions).  It applies to all individuals working for or on behalf of the Company, including employees, agency workers, contractors, visitors, customers, and suppliers.  All managers have a duty to prevent bullying, harassment, sexual harassment, and inhumane treatment and must take proactive steps to ensure such behaviour does not occur. All employees are responsible for treating others with dignity and respect and for not engaging in any form of unacceptable behaviour.

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.

Antibribery and Corruption 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 within the staff canteen, 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 2023	FY 2024	FY 2025
% 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	1	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*	87	94	93
% of eligible tier 1 raw ingredient suppliers with a modern slavery statement on the UK register or website*	88	79	81
% of tier 1 or 2 manufacturing sites of raw material & ingredients linked on Sedex***	n/a	76	88
% of production managers/supervisors with additional training in modern slavery awareness	n/a	6	8
% of tier 1 or 2 manufacturing sites of raw material having completed Sedex SAQ to 100%	n/a	n/a	48
% of tier 1 or 2 manufacturing sites of ingredients having completed Sedex SAQ to 100%	n/a	n/a	62

 

*website included from 2023 reporting year

** & *** see KPI development below in “Our Progress 2025”

2025 Media Attention/Allegations

In February 2025 it was brought to our attention that a UK fishing vessel had received allegations surrounding mistreatment of a fisher on board that featured within Thistle Seafoods supply chain. This information was communicated via the Sea Alliance and Thistle Seafoods participated in a series of discussions on the matter. A formal investigation and report were identified as the most suitable next steps. Thistle Seafoods is unable to comment any further on the topic as the case was still ongoing at the time of our last involvement. We understand that there is still much work to do in regard to ethical assurances on board fishing vessels in the UK and throughout our supply chain. We are engaged in the relevant groups to address these issues and advocate for continual improvement in relation to the treatment and working conditions of fishers.

Our Progress 2025

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).

Internal Training

We have continued to roll out modern slavery refresher training. This will be carried out every 3 years, or more regularly if any instances of modern slavery are found on site. To date, thirteen members of the Ethical Working group, alongside an additional seven relevant colleagues have attended formal modern slavery awareness training provided by Stronger Together.

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 continues to hold SEA Alliance membership and are actively involved in the Human Rights Due Diligence, Advocacy and Engagement & UK Action Plan working groups. Thistle Seafoods currently sits on the ‘Change on the Water Fund’ panel.

FNET (Food Network for Ethical Trade)

Thistle Seafoods continues to be 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 have allowed 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 critical and major SMETA NC’s as well as the highest risk supplying sites are shortlisted for review. Sites with incomplete or out of date Sedex SAQ’s are also reviewed and the necessary actions are documented. 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.

***FY 2023 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. FY 2023 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 2026

KPI’s

Our aim is to improve our KPI scores mentioned above.

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 26th June 2026.

Pamela Macdougall
26th June 2026