Modern Slavery Act Transparency Statement 2019

Modern Slavery Act Statement 2019


This statement sets out Sea Products International Ltd’s actions to understand potential modern slavery risks within the business that it operates, and further investigate the feasibility of its aim to ensure that there is no modern slavery in its supply chains.

Our Business

Sea Products International Ltd are a leading importer and distributor of frozen food products within UK and Ireland, supplying retailers, manufacturers and foodservice outlets. To maintain a varied range of products on a year-round basis and achieve a diverse choice of competitive menu options, it is necessary for us to source globally. We work closely with our suppliers to ensure that slavery and human trafficking risks are identified and managed.

Supply chains and risk activities

Sea Products International Limited is not aware of, and has not identified, any instances of modern slavery in the following areas, but recognises that they are of a nature that is open to this risk. The risk would relate to the pay and working conditions of employees in these areas. The list is not exhaustive and may be added to should it be deemed necessary.

  • Production-line employees and other employees of the processing establishments that prepare and freeze the produce that the Company buys;
  • The fishermen employed on the fishing boats used to fish sea-caught fish and crustaceans supplied to the processing establishments;
  • Employees of fish-farms that produce the aquaculture produce supplied to the processing establishments, or who may also process their own produce;
  • Similar supply chains used in the production and manufacture of the fish food used in the farms.

Risk assessment

In the above cases, the risks increase in the following circumstances: in countries with little or no legislation; in countries where such legislation is not policed; where Sea Products International Ltd is purchasing product from third parties, and so does not have a relationship with the processing establishment, or where the supply chain is relatively longer. Conversely, the risks and the element of uncertainty decrease where the Company purchases product direct from processing establishments with whom it has long-standing relationships.  

Due Diligence

We have an ethical trading policy in place and we are committed to sourcing products from responsible, reliable suppliers who demonstrate compliance with all local and national regulations, and do not exploit their workforce in any way. We would never knowingly purchase from any supplier who contravened any law, nor supported any illegal practices. Their workforces must be respected and treated fairly at all times, we expect as a minimum our suppliers to follow the main aspects of the ETI Base Code.

We believe that we have good knowledge of human rights and ethical principles in our company-provided facilities. However, we acknowledge that more focus is needed in order to ensure all our suppliers are working to adequate standards.


The Company is instigating the following policies:

Reporting - The Company is encouraging its employees to report any concerns relating to modern slavery in the supply chain, or in any other aspect of the Companies activities. Instances of concern will be taken seriously.

Code of Conduct for our Suppliers - We are in the process of encouraging our suppliers, in the first instance, to agree on a code of conduct which includes treating their employees with dignity and respect, ensuring that they have safe working conditions and that they act in an ethical manner towards them and are within the law.

Further Steps

  • We are assessing which of our suppliers are members of Sedex and which suppliers have undergone Social compliance audits.
  • Where applicable we are encouraging our suppliers to consider Sedex membership as a way to share and view data with us and our customers.
  • Any new procedures and policies will be formally trained to any relevant members of staff
  • This statement is effectively communicated to all staff so they are aware of the Company Policy


This document has been approved by the Company’s board of directors and signed by a director, and will be reviewed and updated each year.

Dated: 11 April 2019              ­­­­