Modern Slavery Act Statement

Transparency in Our Supply Chains

Awareness of labour issues in the seafood industry has increased in recent years through a number of high-profile media cases. Lack of traceability is a common key factor in these cases of forced labour. Kingfisher Foods has a publicly stated commitment to 100% traceability throughout our product range and continuously strives to mitigate risks of labour issues in our complex international supply chains. To achieve this, we manage strong direct relationships with our suppliers to ensure visibility to factory level.

We continue to expand our scope to gain a deeper understanding of our indirect suppliers (including packaging and raw material) and to address the industry-wide issue of lack of visibility at sea. We continue to tackle the challenges faced within our international supply chain through collaboration with stakeholders. We commit to the ETI Base Code and focus our efforts on industry wide challenges such as ensuring employment is freely chosen; living wages are paid; and excessive working hours are avoided.

Supply

Modern Slavery Act Statements

Progress & Due Diligence

Collaboration

To confront the issues facing our industry, we work closely with our suppliers and customers, partner with a number of external organisations, and use our variety of third-party connections to continuously develop, evaluate, and improve our internal policies and procedures. As an active member of the Sustainable Seafood Coalition(SSC), we contribute to the establishment of UK-wide standards on seafood labelling, risk assessment, and fishery improvement efforts. We are also a Participating Company of the International Seafood Sustainability Foundation (ISSF), an interdisciplinary organisation working to improve sustainability and traceability in the tuna industry.

In addition, as active members of SEDEX, we track suppliers’ progress towards an independently verified ethical standard underpinned by the ETI Base Code. We continue to develop our relationships with our customers by ensuring a clear understanding of ethical trade requirements and increase transparency and engagement with their ethical trade teams. Our collaboration extends further through participation in conversations organised by groups such as the ISSF and SSC on the development and application of external risk assessment tools, such as the Seafish Risk Assessment for Sourcing Seafood (RASS) tool, and the inclusion of social criteria into the SSC’s Code of Conduct.

Kingfisher Foods are Marine Stewardship Council (MSC) Chain of Custody certified which ensures that products from MSC certified sustainable fisheries are traceable and separated from non-certified products. We continue to participate in Fishery Improvements Projects (FIPs) in Peru and Morocco to increase our ability to source from MSC certified fisheries.

Our Policies

Seafood is the majority of our business and we have therefore focused our initial efforts in this area, but have developed policies to cover all high-risk areas of business, as follows:

1. Sustainability Policy – This is publicly available on our website;

2. Tuna Sourcing Policy – This internal policy requires our tuna suppliers to increase transparency & traceability on the vessels they source from, including by checking working standards on vessels at least yearly. A second version was sent out in July 2017;

3. Fishing and Supply Vessel Social and Labour Standard Policy – This is publicly available on our website;

4. Supplier Ethical Trade Policy – This internal policy requires all suppliers to join an approved ethical audit scheme and comply with the ETI Base Code. The policy was implemented at the end of October 2017 and continues to be upheld with new supplier relationships. Specific information is provided for SMETA audits since Kingfisher Foods are A/B Sedex members.

5. Modern Slavery Whistleblowing Policy – This internal policy enables our staff to feel comfortable raising any concerns they have regarding slavery or wrongdoing in our supply chains and be protected from retaliation. We are committed to operating in line with the law, our Ethical Trade Policy and Ethical Trade Code of Conduct and our business values.

6. Supply Chain Equal Opportunity and Inclusion Policy – This internal policy intends to clarify Kingfisher Foods position on inclusion and equal opportunity throughout our supply chain. We expect all our suppliers to have policies and procedures in place to prohibit and prevent any form of discrimination. Kingfisher Foods work collaboratively with suppliers to enact this policy.

7. Monkey-Free Coconut Harvesting Policy – This internal policy was developed in 2019 and further developed in 2023 in response to PETA’s finding of Northern and Southern pigtailed macaques being identified as at risk of exploitation for agricultural labour, specifically, coconut harvesting. By providing support to our processors through this policy, we work to assure monkeys are not used in any supply chain.

Training

The CSR Department is responsible for all aspects of ethical trade at Lovering Foods. As such, they maintain relationships with external organisations and attend relevant workshops and conferences.

We believe that everyone in our company has a part to play in ensuring the amelioration of social conditions within our supply chains. Thus, important news regarding ethics and sustainability, and updates on progress Lovering Foods has made is shared with all relevant employees. Additionally, the CSR department provides annual modern slavery training to all employees, including highlighting how to spot the signs of modern slavery in our supply chain. The CSR department takes great effort to ensure customers are kept up to date on developing situations through regular meetings.

Internal tools have been developed to ingrain CSR into purchasing practices, putting ethical trade into practice and ensuring third-party ethical auditing methodologies and Kingfisher Foods policies are adhered to.

As part of the induction process, new staff members participate in our Seafood Sustainability Workshop as well as our Modern Slavery Training. This training is in addition to a CSR overview provided as part of the company’s onboarding schedule.

Our Procedures

Kingfisher Foods approach to assessing risk within our complex supply network is driven through incorporating data sources at all levels of the supply chain.

The first step of our risk assessment is to identify suppliers ‘inherent risk’. We use Sedex’s RADAR tool to provide an understanding of human rights risks at a country and sector level. This is combined with our own understanding of supplier specific inherent risks, which comes through the enhanced Sedex ‘Self-Assessment Questionnaire’ (SAQ) and learning from our supply partners and their teams on the ground. Our assessment considers the additional risks associated with high-risk types of labour (seasonal, permanent, agency, migrant).

Once the inherent risk is identified, we evaluate how successfully suppliers manage risks through third-party ethical audits and Lovering Foods CSR department site visits. Our formalised ethical audit procedure provides bespoke support to our suppliers throughout their ethical audit. This includes supporting sites to understand how ethical audits are conducted, through to providing guidance on remediating any issues raised. In 2022/23, we achieved 100% coverage of our suppliers in third party ethical audits. Additionally, by looking at the type of non-conformances that were raised by region more closely, we have been able to classify the most common risk areas that exist in each region, utilise root-cause analysis for remediation.

Our dedicated Technical and Supply Chain teams ensure all products undergo a rigorous approval procedure before reaching our customers. This includes a variety of quality, food safety, and traceability verifications.

We continue to expand the scope of our responsible sourcing policy to include all of our products supply chains. We continue to prioritise our seafood supply chains as this industry is of a higher risk.

Adam Chevreau-Kareliussen

CSR Manager
Adam.Chevreau-Kareliussen@kingfisherfoods.co.uk

Transparency in Our Supply Chains

Modern Slavery Act Statements

2023 - 2024

2022 - 2023

2021 - 2022

2020 - 2021

2019 - 2020

2018 - 2019

2017 - 2018

2016 - 2017

2015 - 2016

Progress & Due Diligence

We continue to expand the scope of our responsible sourcing policy to include all of our products supply chains. We continue to prioritise our seafood supply chains as this industry is of a higher risk.

Adam Chevreau-Kareliussen