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Modern Slavery Policy


F Smales & Sons (Fish Merchants) Ltd welcomes the requirements of Section 54 of the UK Modern Slavery Act 2015 and works towards better strategic understanding of the risks and impacts of our core supply chain towards the prevention of modern slavery or human trafficking.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. F Smales & Sons (Fish Merchants) Limited has a zero-tolerance approachto any form of modern slavery. We are committed to acting ethically, 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

F Smales & Sons (Fish Merchants) Limited is a dedicated and privately-owned seafood processing plant supplying to supermarkets, food service and fish & chip shops. The supply chain extends from the fisherman catching the fish to ingredients and packaging.The organisation currently operates within the United Kingdom (UK) although some of its suppliers are not based in the UK.

We source fish from a global network of suppliers and are committed to understanding our supply chain from sea to store.

We accept production items from across the world,have approximately 100 approved suppliers and employ over 200 employees, in addition to using recruitment agencies for the temporary provision of labour in line with business requirements.



F Smales & Sons (Fish Merchants)operates a strict adherence to the Ethical Trading Initiative (ETI) Base Code. This is founded on the conventions of the International Labour Organisation and is an internationally recognised codeof labour practice. The company is also a member of SEDEX, the Supplier Ethical Data Exchange which is a not for profit membership organisation dedicated to driving improvements in responsible and ethical practices in global supply chains and monitors adherence of all members against the principles of the ETI Base Code. Our aim is to have zero non-conformances from our ethical audits, and where we do close these out as soon as possible.

Our High Risk AreasThe Company believes that none of its activities or those of its suppliers are considered to be at high risk of slavery and human trafficking.


Our Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.


These include:

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.


Whistleblowing Policy

We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.


Our Suppliers

F Smales & Sons (Fish Merchants) Ltd operates a supplier policy and maintains an approved supplier list. We conduct due diligence on all suppliers before allowing them to become an approved supplier.This due diligence includes an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery and on-site audits which include a review of working conditions. Each supplier is risk assessed and the frequency of their supplier review is determined by this.F Smales & Sons (Fish Merchants) Ltd also requires that all suppliers are SEDEX registered.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

  • They have taken steps to eradicate modern slavery within their business.
  • They hold their own suppliers to account over modern slavery.
  • (For UK, based suppliers) They pay their employees at least the national minimum wage/national living wage (as appropriate).
  • (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations.
  • We may terminate the contract at any time should any instances of modern slavery come to light.



We regularly conduct training for our Procurement/Buying Teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.


Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within ourbusiness or supply chain if; no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.


Responsibility for the Policy

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.

Managers 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.


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

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

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