This statement applies to Flatfish Ltd (referred to in this statement as ‘the Organisation’).
The information included in the statement refers to the financial year 2021/2022.
Flatfish Ltd operate from one state of the art fish production facility and two Traditional Curing houses based in Grimsby, one of which is a Grade II Listed Building. Flatfish is part of Nippon Suisan Kaisha Europe B.V. Nissui are the second largest fish company worldwide, with a global reach. The organisation is controlled by a board of Directors.
The main Flatfish site is located in Stirling Street in Grimsby and the Traditional Curing houses are located in both Cross Street and Lingard Monk Street on the Fish Docks in Grimsby, North East Lincolnshire, England, both within excellent sea and air routes.
The main activity of the Flatfish production facility is the processing of fresh and frozen fish for several major retailers. The Traditional Curing facility produces Traditionally smoked fish, dyed and undyed, again for major retailers. The Organisation performs the sale of the aforementioned goods for both fresh and frozen fish counters. Demand for the varied nature of our products is consistently high throughout the year and is therefore not seasonal.
The labour supplied to the Organisation in pursuance of its operation is wholly carried out in the United Kingdom in the North and North East Lincolnshire region.
The Organisation considers that modern slavery encompasses:
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation and in many cases exceeds those minimums in relation to its employees.
In order to fulfil its activities, the main supply chains of the Organisation include those related to the supply of fish varieties from various suppliers in both the UK, Iceland and Norway.
No trade union representation is in place at either of the Flatfish sites.
The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in its onboarding process as agency workers do form part of the workforce. However, the Company is aware of the risk of modern day slavery existing in the day to day life of permanent and agency workers, Stronger Together information is placed in strategic areas of the business to assist employees at any time during their employment with the business.
In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
Impact of COVID-19
During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for the Organisation, as it did for others across the nation.
The Organisation welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.
Unfortunately, the Organisation assessed that it would need to delay the publication of this statement for the 2019/2020 financial year due to the impact of COVID-19. It has therefore been delayed for one year. The reason for the delay was due to the global pandemic.
The Organisation concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘Potential Exposure’ above.
The risk of modern slavery was considered stable as the current workforce, both permanent and agency, was not increased. Rotational homeworking was implemented in March 2020 for office based staff.
During the pandemic, the Organisation’s employees still had access to the grievance procedure to raise any concerns that they may have had.
In line with emergency legislation passed by the Government, employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking. This was due to the factory based nature of the core business model.
The Organisation’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.
The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers. Affiliation to SEDEX, ISO9001 and/or BRC and incorporation into the Stronger Together initiative forming part of these controls.
The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken steps to ensure that modern slavery is not taking place.
Key performance indicators
The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.
A Workforce Incident Management Team, covering all areas of the Organisation will be established and will meet at quarterly intervals, with annual refresher training put in place for all staff members. The criteria will follow the due diligence framework of, Commit, Communicate, Assess, Monitor, Act and Remedy. Staff are also requested to complete anonymous Worker questionnaires, provided in various languages as part of their induction and throughout their period of employment with the Company, coupled with a modern slavery video presentation and open forum discussion.
All of our suppliers are requested to complete SAQ’s at tender, or show affiliation/compliance to SEDEX, ISO9001 or BRC to ensure modern slavery forms part of their business profile.
The Organisation has the following policies which further define its stance on modern slavery: Modern Slavery Statement (HR-078), Human Rights Policy (HR-038), Ethical Trading Policy(CP-11), Equality & Diversity Policy (CP-18), Anti-Bribery & Corruption Policy (HR-028), Stronger Together Initiative.
Slavery Compliance Officer
The Organisation has a Modern Slavery Lead, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.