
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. Lovering 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 are now aiming 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.

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. Last year, we became an active member of the Sustainable Seafood Coalition(SSC), contributing 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. Further, as active members of SEDEX, we track suppliers’ progress towards an independently verified ethical standard underpinned by the ETI Base Code
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. Throughout 2016-17, we were invited to participate in a Steering Group with the British Standards Institute (BSI), developing voluntary guidelines to combat Illegal, Unreported and Unregulated (IUU) fishing and avoid the use of forced labour. Finally, last year, Lovering Foods started a Fishery Improvement Project (FIP) in Peru in partnership with one of our suppliers and an NGO, amongst other stakeholders. Through the FIP, we visited a supplier to gain insight and identify potential improvements towards better working conditions at vessel, port, and factory levels.


Our Policies
Tuna is our number one product and we have therefore focused our initial efforts in this area of our business. We currently uphold a number of policies, as follows:
1. Sustainability Policy (2015)
2.Tuna Sourcing Policy- This requires our tuna suppliers to increase transparency & traceability on the vessels they source from, including by checking working standards on vessels at least yearly;
3. Supplier Ethical Trade Code of Conduct and Supplier Guide to Ethical Trade- These documents require all suppliers to join an approved ethical scheme and comply with the ETI Base Code. These are in final stages of approval and will be implemented throughout the 2017-18 financial year.


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, such as Stronger Together’s ‘Tackling Modern Slavery in Global Supply Chains’ (London, August 2015; Boston [UK], October 2016) and the SEDEX conference ‘Simplifying Supply Chain Sustainability’ (London, March 2016). We believe that everyone in our company has a part to play in ensuring the amelioration of social conditions within our supply chains. Thus, information received from workshops, important news regarding ethics and sustainability, and updates on the progress Lovering Foods has made is shared with all relevant employees through biannual internal newsletters and with customers through regular meetings. As part of the induction process, new staff members participate in our Seafood Sustainability Workshop as well as our Modern Slavery Awareness Training. As the Modern Slavery Awareness Training has just recently been implemented, all relevant staff members were required to undergo training in March 2017.


Our Procedures
Lovering Foods is a SEDEX member and uses the SEDEX Advance platform to gain visibility of working conditions at processing sites. Currently, more than 75% of our suppliers are registered. Upon registration, a desktop audit called a ‘Self - Assessment Questionnaire’ (SAQ) is completed by the supplier. We then use customer specifications and risk assessment procedures to determine whether an on-site ethical audit is required. Sites identified as medium or high risk are required to conduct a SEDEX Members Ethical Trade Audit (SMETA) from a certified auditing body at a frequency determined by our customers, and, if necessary, will be given corrective measures to apply within a set timeframe.
Our dedicated Technical team ensures all products undergo a rigorous approval procedure before reaching our customers. This includes a variety of quality, food safety, and traceability verifications.

Next Steps...
- Further develop our CSR Department, dedicating a team member to ethical trade;
- Formalise and strengthen Loverings' private label risk assessment procedure and ethical sourcing policy;
- Ensure that all suppliers are SEDEX members, have a completed SAQ, and have conducted ethical audits as necessary according to their risk assessment outcome;
- Conduct ethical risk assessments on all Kingfisher and Royal Line supply chains, and own-label supply chains where a retailers own policy is not available;
- Continue to expand our third-party engagement.Read More
Continue to expand our third-party engagement through the following steps:
- Become an active member of the Sustainable Seafood Coalition (SSC),
and thus contribute to the establishment of UK-wide standards on seafood labelling, risk assessment, and fishery improvement efforts;
- Participate 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);
- Participate in discussions with suppliers, industry associations, and environmental groups on how to improve on-board monitoring on the wide range of fishing vessels we source from;
- Further collaborate with customers and other suppliers to share best practice and find more practical and effective ways of mitigating risk in the supply chain.
- Become an active member of the Sustainable Seafood Coalition (SSC),
and thus contribute to the establishment of UK-wide standards on seafood labelling, risk assessment, and fishery improvement efforts;

From March 2017, we plan to expand the scope of our responsible sourcing policy to include our fruit, vegetable, and Oriental goods supply chains. We have decided to focus first on our seafood supply chains as this industry is of a higher risk.

Andres Reyes-Alzate,