Slavery And Trafficking Statement

Slavery And Trafficking Statement


Whitby Seafoods Slavery and Human Trafficking Statement 2016

The Modern Slavery Act 2015 seeks to address the role of businesses in preventing modern slavery from occurring in their supply chains and organisation.

Whitby Seafoods are committed to maintaining and improving systems in our operations and supply chain to avoid human rights violations and to drive action in promoting ethical trading in the industries we work in.   Raw material is sourced predominantly from the UK and supported by a partner in Vietnam for a proportion of our processing.  Other raw materials are sourced in smaller quantities from suppliers in China, Vietnam, Malaysia and Iceland.

This statement relates to actions and activities during the financial year 1st January 2015 to 31st December 2016. 

Organisational Policies

The company have the following policies in place to mitigate the risk of Modern Slavery within the organisation;

  • Forced, Bonded and Involuntary Labour

This policy sets out our belief that fair and ethical treatment of our employees and workers is fundamental to our success.  As such the company is committed to following the principles and provisions of the Ethical Trading Initiative (ETI) Base Code and communicating this to our employees and workers.

  • Freedom of Association

We have committed that all Whitby Seafoods employees are free to join or form a trade union and bargain collectively under any terms relating to their employment.

  • Young Workers

This policy clearly sets out that all our young employees and workers are able to participate in safe and legal employment and no child labour is tolerated in our operations.

Risk Assessment

Whitby Seafoods employs risk assessment methodology to identify where priorities for further consideration should be taken.  The risk assessment takes into consideration the jurisdiction country for the catch area as well as the country the fish preparation takes place.  References are made against Seafish Country Profiles as well as the US trafficking persons report 2016.  The company has prioritised the sourcing of seafood as its main focus due to the nature and reported challenges in seafood sourcing.   

Risk mitigation is accounted for in the risk assessment.  Risk mitigation includes;

  • Direct feedback from the supplier (e.g. Sedex self-assessment)
  • Involvement in multi-stakeholder efforts
  • Working towards, or achieved credible certification (e.g. RFS, ASC, Fairtrade, SMETA)

The most challenging aspect of seafood supply is that the primary source of supply comes from fishing boats which spend a large proportion of time out of sight.  Policing these boats and evidencing ethical traceability is an industry wide challenge. 

The company promotes the application of the Sedex self-assessment tool as its primary vehicle for managing ethical trading within its land based supply chain.  Whitby Seafoods will use the information provided to identify high risk suppliers and take appropriate action to drive improvement in labour standards.  This includes the option of cease of supply.

The most prevalent accreditations for Whitby Seafoods’ business model that include ethical approaches to labour are;

  • Responsible Fishing Scheme (RFS) accreditation
  • A Sedex audit undertaken by a 3rd party
  • Aquaculture Stewardship Council (ASC) accreditation


Whitby Seafoods is actively pursuing that vessels from which scampi is sourced are RFS approved.   We are working with industry bodies to assist with this implementation across nephrops fisheries.

Certification to the RFS requires an independent audited assessment of the application of good practice of an individual vessel, its skipper and crew. 

The first core principle of the RFS is safety, health and welfare.  The criteria within this principle are detailed below;

  • Health and Safety is a paramount concern and is core to the RFS
  • Demonstrate commitment to a culture of integrity and respect (e.g. no forced labour).
  • The RFS Compliance Support Guides (CSG) draw upon other relevant safety management and welfare initiatives.

The specific performance indicators in this module of the standard are based on internationally recognised universal standards such as;

  • United Nations Universal Declaration of Human Rights and its Protocols
  • ILO Declaration on Fundamental Principles and Rights at Work of 1998
  • The ILO Tripartite Declaration Concerning Multinational Enterprises and Social Policy
  • The Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises.

Whitby Seafoods are actively engaged with the seafood industry with the deployment of the Seafish RFS programme in order to mitigate any risks of unethical practices taking place on the vessels from which we source.


The Sedex tool allows Whitby Seafoods to view supplier self-audit questionnaire answers against set ethical criteria.  This allows the business to determine if any remedial action is required with the supplier.  This tool is being used widely in the UK to drive ethical standards and mitigate risk in the supply chain.

By way of example, the Whitby Seafoods site underwent an independent 3rd party Ethical Audit in May 2015 and is now approved against the SMETA (Sedex Members Ethical Trade Audit) standard.

ASC Accreditation

ASC applies a third-party certification system to its accreditation.  This ensures the program is robust, credible and meets best practice guidelines for standard-setting organisations as set out by ISEAL and the FAO (Food and agricultural organisation for the United Nations).   ISEAL’s mission is to strengthen sustainability standards systems for the benefit of people and the environment.

The ASC standard has a section specifically to develop and operate farms in a socially responsible manner that contributes effectively to community development and poverty alleviation.

Within this there are clauses that drive minimum standards in the areas of;

  • Child labour and young workers
  • Forced and compulsory labour
  • Health and safety
  • Freedom of association and collective bargaining
  • Discrimination
  • Working hours
  • Fair and decent  wages
  • Labour contracts

Monitoring and KPI’s

In order to effectively monitor the ongoing risks of modern slavery and to track feedback from our supply base, three key metrics in which improvement is measured;

  • % vessels with RFS approval
  • % suppliers with ASC or Sedex Audit approval
  • % suppliers with Sedex self-assessment

These KPI’s are reviewed annually at board level for effectiveness and forms a key part of the business’ decision making for new and future opportunities.


A senior manager within our business has undergone training on this subject matter and is driving an awareness programme internally.  Externally, wherever possible, Whitby Seafoods will include social elements in any improvement programmes that engage our supply base.  An example of this would be to include a social component in any Fishery Improvement Programmes (FIP’s) that we might engage in.

The Managing Director and two senior managers are trained against the Seafish RFS standard as part of championing improved working conditions and improved labour transparency in the seafood sector.

This statement has been approved by the organisation’s board of directors and signed by the Managing Director, who will ensure it is reviewed and updated annually.

Daniel Whittle

Managing Director

Whitby Seafoods Ltd