Financial year 2021 – 2022

Scottish Sea Farms operates a zero tolerance to modern slavery and human trafficking and is committed to making every effort to eradicate the horrendous impact of this hidden crime from our business and supply chain. 

We recognise that modern slavery and human trafficking global and growing issues, and no sector or industry can be considered immune.

We define modern slavery in line with the United Nations Guiding Principles on Human Rights: “One person depriving another of their liberty in order to exploit them for personal or commercial gain.”

Our business

From our freshwater hatcheries and marine farms around Scotland’s west coast and islands, Scottish Sea Farms raises premium quality salmon which we supply to customers in over 24 countries around the world.

From the 33,000 tonnes of salmon that we expect to harvest in 2021 alone, we will contribute an estimated 135M protein-rich meals (based on one tonne producing approximately 4,116 x 120g portions.)

Helping make it happen are the 450+ people we employ directly, supported by over 700 hundred different Scottish suppliers with whom we spend a combined £100M+ annually procuring goods and services.

Our supply chains

Our supply chains include the sourcing and distribution of salmon to third party processes not just within Scotland and the UK, but across Europe, Asia, America and UAE too.

All our suppliers are required to sign up to our Suppliers’ Code of Conduct and confirm their compliance with the Ethical Trade Initiative (ETI) Base Code via a risk assessment process which expects the supplier to provide a current social compliance audit report (Sedex/META or similar).

Any issues raised in these audit reports must be dealt with by the supplier within stipulated time frames.

Should suppliers not be able to provide current social compliance audit reports they may be permitted to complete an Online Risk Assessment (ORA) which will be evaluated using standard industry benchmarks resulting in a Corrective Action Plan Report (CAPR), along with specified timeframes for completing these corrective actions.

We have zero tolerance to slavery and human trafficking, and we expect everyone in our supply chain to comply. Any supplier who refuses to provide us with the appropriate information in a timely manner may no longer be able to supply Scottish Sea Farms.

Roadmap for improvement

Testament to our commitment to this issue, Scottish Sea Farms has partnered with Verisio Ltd. who are recognised experts in the field of supply chain transparency and Modern Slavery Act Diligence, and who provide these services to many retailers, brands and food companies.

On behalf of Scottish Sea Farms, Verisio is in the process of mapping our entire supply chain, reviewing social compliance audit reports and providing monthly reporting regarding our global risk profile.

In our next annual Modern Slavery and Human Trafficking Statement we will report in detail on the exact number of our suppliers, any issues that were found and how they are being rectified.

Verisio uses a unique software programme, as well as physical on-site visits by their teams of qualified social compliance auditors, to ensure all our suppliers meet our Code of Conduct which is detailed below.

Our policies 

We recognise that embedding anti-modern slavery practices across our business and supply chains is a fundamental requirement. Our code of conduct outlines our expectations of our supply chain and ourselves and incorporates the following policies:

Our code of conduct 

We commit to:

Transparency in our operations

• We accept unannounced audits should it be deemed necessary
• At a minimum, SSF must comply with local law

Freedom of employment

We shall not use any form of slave, forced, bonded, indentured, or involuntary prison labour, nor shall we be engaged in exploitation or human trafficking, or import goods tainted by slavery or human trafficking. In addition:

• All personnel shall have the freedom to accept or leave a job voluntarily
• Workers are not required to lodge ‘deposits’ or their identity papers with Scottish Sea Farms and are free to leave their employment after reasonable notice
• Scottish Sea Farms shall have management systems that ensure employment is freely chosen that includes written policies and procedures, communication and training, monitoring and governance.

Freedom of association and the right to collective bargaining

Scottish Sea Farms is required to respect the rights of workers to associate or not to associate with any group, as permitted by law:

• All personnel shall have the right to associate or not associate with any group of their choice, as permitted by law without fear of reprisal, intimidation, or harassment
• All personnel shall have the right to form, join and organise trade unions of their choice to bargain collectively on their behalf with the organisation
• In situations where the right to freedom of association and collective bargaining are restricted under law, the organisation shall allow workers to elect their own representatives freely
• Scottish Sea Farms shall ensure that union members, representatives of workers and any personnel engaged in organising workers are not subjected to discrimination, harassment, intimidation, or retaliation for being union members, the representative(s) of workers or involved in organising workers and that such representatives have access to their members in the workplace
• Scottish Sea Farms shall have a freedom of association and the right to collective bargaining management system that includes written policies and procedures, communication and training, monitoring and governance.

Working conditions

Scottish Sea Farms shall:

• Provide a safe and hygienic workplace environment bearing in mind the prevailing knowledge of the industry and of any specific hazards
• Appoint a senior management representative to be responsible for ensuring a safe and healthy work environment for all personnel and for implementing this Standard’s Health and Safety requirements
• Take adequate steps to prevent potential health and safety incidents and occupational injury, or illness arising out of, associated with or occurring in the course of work, minimising or eliminating, so far as is reasonably practicable, the causes of all hazards in the workplace environment
• Provide personnel with appropriate personal protective equipment as needed when hazards remain after adequate minimisation or elimination of the causes of all hazards in the workplace environment and the organisation
• Assess all the workplace risks to new, expectant and nursing mothers including those arising out of their work activity, to ensure that all reasonable steps are taken to remove or reduce any risks to their health and safety
• Ensure that, in the event of a work-related injury, adequate employees are trained to provide first aid
• Ensure that all personnel receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers
• Provide, for use by all personnel, free access to clean toilet facilities, potable water, suitable spaces for meal breaks, and, where applicable, sanitary facilities for food storage
• Ensure all personnel have the right to remove themselves from imminent danger without seeking permission from the organisation.

Child and young workers

Scottish Sea Farms shall not engage in, or support the use of, child labour as defined below:

• Underage labour is any person under the minimum employment age according to the laws of the facility’s country, or, in the absence of regulation, under the minimum age for completing required education. If the country’s minimum working age is either not defined or younger than 15, suppliers, facilities and subcontractors within their supply chain shall not employ anyone younger than 15. Underage labour is not to be used to produce or distribute goods or services. Underage labour laws protect children and benefit communities
• Scottish Sea Farms shall develop, document, maintain and effectively communicate to personnel and other interested parties, written policies and procedures for remediation of child labourers, and shall provide adequate financial and other support to enable such children to attend and remain in school until no longer a child as defined above
• Scottish Sea Farms may employ young workers, but where such young workers are subject to compulsory education laws, they shall work only outside of school hours
• Scottish Sea Farms shall ensure that under no circumstances shall any young worker’s school, work and transportation time exceed a combined total of 10 hours per day, and in no case shall young workers work more than 8 hours a day
• Young workers may not work during night hours
• Scottish Sea Farms shall not expose children or young workers to any situations, in or outside of the workplace, that is hazardous or unsafe to their physical and mental health and development
• Scottish Sea Farms shall have a child and young worker management system that includes written policies and procedures, communication and training, monitoring and governance.

Definitions: 

Child means any person less than 15 years of age. If local minimum age law stipulates a higher age for work or mandatory schooling, the higher age applies.

Young Person means any worker over the age of a Child (as defined above) and under the age of 18. 

Child Labour means any work by a Child or Young Person younger than the age specified in the above definitions, which does not comply with the provisions of the relevant ILO standards, and any work that is likely to be hazardous or to interfere with the Child’s or Young Person’s education, or to be harmful to the Child’s or Young Person’s health or physical, mental, spiritual, moral or social development.

Wages and benefits

Scottish Sea Farms shall:

• Ensure that personnel are compensated according to the law including minimum wage, overtime and premium pay
• Ensure that personnel receive equal pay for equal work without discrimination
• Ensure that no deductions are taken from the employees pay as part of any disciplinary action
• Ensure that personnel’s wages and benefits composition are detailed clearly and regularly to them in writing for each pay period
• Lawfully render all wages and benefits due in a manner convenient to workers, but in no circumstances in delayed or restricted forms, such as vouchers, coupons or promissory notes
• Have a wages management system that includes written policies and procedures, communication and training, monitoring and governance.

Working hours

Scottish Sea Farms shall:

• Comply with applicable laws, collective bargaining agreements (where applicable) and industry standards on working hours, breaks and public holidays. The regular work week, not including overtime, shall be defined by law but shall not exceed 48 hours
• Ensure working hours, excluding overtime, is defined by the contract, and shall not exceed 48 hours per week
• Ensure workers do not work over 12 hours per day, where allowed by local law
• Ensure all overtime is voluntary and that overtime shall be used responsibly, taking into account all the extent, frequency and hours worked by individual workers and the workforce as a whole
• Ensure that the total hours worked in any 7 days shall not exceed 60 hours
• Ensure workers shall be provided with at least one day off in every 7 days or, where allowed by national law, 2 days off in every 14 days
• Have a working hours management system that includes written policies and procedures, communication and training, monitoring and governance.

No discrimination

Scottish Sea Farms shall ensure that the environment provided is free from discrimination:

• Scottish Sea Farms shall not discriminate in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation
• Scottish Sea Farms shall not interfere with the exercise of personnel’s rights to observe tenets or practices or to meet needs relating to race, national or social origin, religion, disability, gender, sexual orientation, family responsibilities, union membership, political opinions or any other condition that could give rise to discrimination
• Scottish Sea Farms shall not subject personnel to pregnancy or virginity tests under any circumstances
• Scottish Sea Farms shall have a ‘No Discrimination’ management system that includes written policies and procedures, communication and training, monitoring and governance.

Regular employment

• Scottish Sea Farms shall only employ workers who are legally authorised to work in their location and facility and have a process for validating employees’ eligibility to work status through appropriate documentation
• Scottish Sea Farms shall ensure that all work performed is on the basis of a recognised employment relationship established through national law and practice.

No harsh or inhumane treatment

• Any physical, verbal or threatening abuse, harassment in any form, including intimidation and unethical disciplinary actions, shall be prohibited
• Scottish Sea Farms shall establish a written grievance procedure that is confidential, unbiased, non-retaliatory and accessible and available to personnel and interested parties to make comments, recommendations, reports or complaints concerning the workplace
• Scottish Sea Farms shall have procedures for investigating, following up on and communicating the outcome of complaints concerning the workplace and/or non-conformances to this standard or of its implementing policies and procedures. These results shall be freely available to all personnel and, upon request, to interested parties
• Scottish Sea Farms shall not discipline, dismiss or otherwise discriminate against any personnel or the interested party for providing information on compliance or for making other workplace complaints.

Environmental

Scottish Sea Farms shall:

• Comply with the requirements of local and international laws and regulations including having necessary permits
• As a minimum, meet the requirements of local and national laws related to environmental standards
• Where it is a legal requirement, be able to demonstrate that we have the relevant valid permits for the use and disposal of resources, e.g., water, waste and air emissions etc.
• Have an environmental policy, covering our environmental impact, which is communicated to all appropriate parties, including our suppliers
• Be aware of the significant environmental impact of our site(s) and our processes.

Workers’ accommodation

Scottish Sea Farms shall ensure that:

• Dormitories, or other housing that is provided, have sufficient living space that meets all emergency safety standards and applicable laws
• Accommodation/dormitories or other housing provided (such as single dwelling homes, or apartments) includes the same standard of living for all residents
• The physical and structural integrity of living quarters are assessed by experts to guarantee that they are capable of and suitable for housing people
• The living quarters should afford a minimum of approximately 20 square feet (1.8 square metres) per person, which includes a sleeping area and available floor space. Everyone should be provided with a secure storage of at least one cubic foot (0.3 cubic meters).

Workforce, subcontractor agencies and migrant labour

Scottish Sea Farms will not sub-contract unless previously agreed with our clients:

• Any employment agencies or subcontractors used must have the legal right to operate and only supply workers registered with them
• All employment agencies and subcontracted suppliers must meet the same criteria as directly contracted product and service suppliers
• Scottish Sea Farms shall ensure that third-party agencies, recruitment firms, labour brokers and subcontractors comply with legal employment practices. All standards also apply to temporary workers as well as regular workers
• Scottish Sea Farms shall ensure a full understanding of the entire recruitment process and assess all labour recruiters and intermediaries against legal requirements
• Scottish Sea Farms shall have an effective management system in place to identify and monitor the hiring and management of all migrant workers, contract workers, agency workers, temporary or casual labour
• Scottish Sea Farms shall implement processes to enable adequate control over agencies with regards to the above points and related legislation
• Scottish Sea Farms shall ensure that employment agencies only supply workers registered with them
• Scottish Sea Farms shall ensure workers do not pay any recruitment fees at any stage of the recruitment process

Scottish Sea Farms’ employee handbook – equal opportunities, diversity, non-harassment, disciplinary, whistle blowing and anti-bribery policies – supports these aims, with all new starters receiving the handbook as part of their offer pack.

Responsibilities and training

The Head of HR is assigned day-to-day responsibility for anti-slavery and human trafficking compliance within the business and has the responsibility for developing and operating company procedures relevant to this issue.

The members of the management team are responsible for compliance in their respective departments and for their supplier relationships and have been trained accordingly.

All key employees receive training each year on the requirements of the code of conduct and are required to pass a formal assessment on this training to measure their understanding.

As well as training for key employees, all staff receive an induction into the business where Scottish Sea Farms’ policies, procedures and expectations are outlined, and they are made aware of modern slavery issues and understand what channels are available to them for raising concerns.

Measuring our effectiveness

Scottish Sea Farms use the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

Key performance indicators:

1. Any, and all, complaints of modern slavery or human trafficking reported internally or through the confidential whistle blowing channels are responded to within 24 hours
2. All key staff including all senior management will have been trained in the Modern Slavery Act and Equality and Diversity by August 2022
3. Supply chain policies, code of conducts and websites will be reviewed annually at least once to ensure relevance and effectiveness
4. Payroll and HR practices will be audited at least once a year to ensure compliance and outline any gaps and scope for improvement.

Continuous improvement

In addition to our KPIs we have set ourselves the following improvement targets for this coming year:

• Establish a working party consisting of HR, IT, Technical and Procurement that will meet every quarter to review our code of conduct and ethical targets, and ensure that they are being met
• Roll out our Modern Slavery and Equality and Diversity training to all employees as part of our induction programme by August 2022.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2021.

Jim Gallagher
Managing Director
Scottish Sea Farms