ANTI-SLAVERY AND HUMAN TRAFFICKING

Anti-Slavery and Human Trafficking Statement

As a business, Flatfish develop and sustain relationships with many different organisations within its supply chain, as well as employing sizable numbers of people. In light of the general law on employment and human rights, and, more specifically the Modern Slavery Act 2015, we have reviewed our existing compliance and risk management processes to establish to what extent measures already exist, and what additional measures may be required to avert slavery and human trafficking taking place in any part of our business activities or within our supply chain.

Flatfish Ltd has adopted a statement of our business value on the deterrence of modern slavery and human trafficking. The value statement governs all our business dealings and the conduct of all persons or organisations with whom we contract directly or who we appoint to act on our behalf.

We expect all who have, or seek to have, a business relationship with Flatfish Ltd, to familiarise themselves with our anti-slavery policy and to act at all times in a way that is consistent with our anti-slavery principles.

Flatfish Ltd Anti-Slavery Policy

As part of our ethos of good governance for good business, at Flatfish Ltd we operate to a set of core tenets which reflect our relationships with our principal stakeholder groups: customers, manufacturers, suppliers and team members. We adopt a behavioural value for all our business relationships, reflecting our attitude to the exploitation of individuals in any form, and more particularly the offences under the Modern Slavery Act 2015. We are committed to opposing modern slavery in all its forms and preventing it by whatever means we can. We demand the same attitude of all who work for us and expect it of all with whom we have business dealings.

Our attitude to modern slavery is: zero tolerance.

1.     Purpose of this Policy

1.1   Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”).   Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This document sets out the policy of Flatfish Ltd (the “Company”) with the aim of the prevention of opportunities for modern slavery to occur within business activities or its supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.

1.2 As a company, we have a zero-tolerance approach to modern slavery. We are 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 businesses or those of our suppliers.

2.     Steps for the Prevention of Modern Slavery

2.1 We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with obligations set out under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and we are evolving and updating our contracting processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children We expect our suppliers to hold their own suppliers to the same high standards.

2.2 All team members have a responsibility to familiarise themselves with our procedures to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for and incidence of modern slavery is prevented. Adherence to this policy forms part of all team members’ obligations under their contract of employment.

2.3   Whilst recognising obligations to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains. To underpin our compliance with practical steps, we intend to implement the following measure:

  • encourage and directly engage with vessels within our supply chain to make a commitment to the Responsible Fishing Scheme;
  • engage with our suppliers both to convey to them our Anti-Slavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses;
  • introduce contractual provisions for our suppliers to confirm their adherence to this policy and accept our right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion.

2.4    Our Company’s Slavery and Human Trafficking Statement, will be presented on our website during the course of 2016.

3. Responsibility for the Policy

3.1 Ultimate responsibility for the prevention of modern slavery rests with the Company’s leadership. The board of directors of the Company has overall responsibility for ensuring this policy and its implementation comply with legal and ethical obligations.

3.2 Team leaders at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.

4.     Actions to Report Modern Slavery or Human Trafficking

Whistleblowing – Concerns about suspected modern slavery associated with the Company or our suppliers may be reported in confidence by employees via Human Resources or by reporting it to:

Gangmasters Licensing Authority on 0800 432 0804

Modern Slavery Helpline on 0800 012 1700 or https://modernslavery.co.uk/contact.html.

Call the Police in an emergency on 999, or 101 if it is not urgent.

For personal help and support if you are a victim – Call Migrant Help on 07766 668781

or the Salvation Army on 0300 303 8151.

In summary, a team member should approach either their direct manager, or equivalent senior leader or the Head of Human Resources. If the matter is extremely serious then a director of the Company should be approached. The nature of the complaint will determine the Company’s next course of action.

Those who are accessing this policy because they:

  • are seeking a business relationship with our business or
  • already have a business relationship with us

are also advised to familiarise themselves with the mean features of our measures for combating modern slavery: Suspicious Activity Confidential Feedback Line 01472 245856.

You should call this line in any of the following circumstances:

  • You suspect a person acting on behalf of Flatfish Ltd is seeking to exploit another in a way which could amount to modern slavery;
  • You suspect that a person acting on behalf of one of our suppliers is seeking to exploit another in a way which could amount to modern slavery;
  • You have received an approach from a person acting on behalf of Flatfish Ltd who has invited you to participate in acts which could result in offences under the Modern Slavery Act 2015 being committed;
  • You have information which leads to the rational conclusion that a person acting on behalf of Flatfish Ltd or one of our suppliers is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act 2015.

Reports to the Suspicious Activity Confidential Feedback line (detailed above) are kept in confidence, subject to the need for Flatfish Ltd to act responsibly and within the law. The source of reports to the Line will be kept confidential, save to the extent that our maintaining that secrecy or the anonymity of the source is not permitted by law, or is not consistent with our maintaining our adequate procedures for the prevention of modern slavery being committed on our behalf or in any element of our supply chain.

Direct Communication

The Company encourages members of the public or people not employed by us to write, in confidence, to the Company’s Head of Human Resources at;

Flatfish Ltd, Unit 5, Sterling Street, Grimsby, North East Lincolnshire, DN31 3AE

to raise any concern, issue or suspicion of modern slavery in any part of our business or related supply chain.

5.     Safeguards

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. The Company will accept and take seriously concerns communicated anonymously.

However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.

Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.

6.     Communication and Awareness of this Policy

Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

7.     Review

Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by the Company’s Senior Management on a regular basis (at least annually) and may be amended from time to time.

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