Modern Slavery Statement


This statement sets out Dawnfresh Seafoods Ltd’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. As part of the Food and Drink Industry, the organisation recognises that it has a responsibility to take a robust approach to these issues. The organisation is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring its supply chains are free from slavery and human trafficking. This statement relates to actions and activities during the financial year 1st April 2019 to 31st March 2020.  

Scope of Statement

This statement covers the activities of Dawnfresh Seafoods Ltd including three production and seven farming sites.

The company currently operates both farming and production facilities within the United Kingdom.

Responsibility for the organisations anti-slavery initiatives is as follows:-

  • Modern Slavery statement update: The Board of Directors are responsible for ensuring the statement is up to date, and accurately reflects the organisations actions and initiatives to tackle slavery and human trafficking;
  • Policies: The HR Team are responsible for introducing policies and reviewing the process by which they are developed;
  • Training: The L&D team have participated in Stronger Together workshops and drawn on the resource to cascade information throughout the organisation. They are responsible for facilitating training to the wider business.

Relevant Policies 

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Ethical Policy: The organisation’s ethical policy demonstrates the company’s commitment to being fair and just in dealings, contracts, and agreements with employees, agency workers, contracted workers, suppliers and customers.
  • The Preventing Hidden Labour Exploitation Policy: This policy sets out our commitment to developing and adopting a proactive approach to tackling hidden labour exploitation and providing all employees and workers with the support and appropriate channels to raise concern.
  • Temporary Labour Policy: Dawnfresh will, where necessary, use temporary agency workers to help fulfil customer orders and maintain high standards of service. We acknowledge that temporary labour is used within our operations, and may also be used throughout our supply chain. We have identified this as an area of risk and are involved in a number of initiatives to manage this risk. In addition, we only partner with a sole, specified, and reputable labour provider to provide all of our temporary labour on site. Dawnfresh conduct twice yearly audits on our labour provider to ensure fair and ethical treatment of temporary labour used on site.

Initiatives to manage risk

  • Stronger2gether – Dawnfresh Seafoods supports Stronger2gether, a multi stakeholder initiative which aims to reduce modern slavery, particularly hidden forced labour, labour trafficking and other third party exploitation of workers. Our HR Team attend regular workshops to keep abreast of updates and relevant materials are displayed at all sites to provide details of what employees/managers should look out for and how they can raise any concerns.
  • Responsible Recruitment Toolkit – 7 leading supermarkets have announced their commitment to be founding sponsors to promote Responsible Recruitment. In doing so, they have taken a proactive approach to sponsor the toolkit to support suppliers in embedding responsible recruitment in their supply chains. Dawnfresh are registered and are working towards meeting the 27 standards mapped out in the toolkit under two main headings of Structures &Systems and Recruitment & Supply/Management. This will enable us to become champions of legal and ethical standards and to move beyond ‘just being compliant’.

Due Diligence 

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

  • Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • Evaluating the modern slavery and human trafficking risks of each new supplier;
  • Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping and supplier approval and monitoring procedure;
  • Using Sedex, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular. Suppliers are requested to be on Sedex and provide a link to their Ethical SAQ;
  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.


The organisation requires all HR Professionals along with each new employee joining the organisation to complete training on modern slavery as a module within the organisations wider induction programme.

Covered through the induction process is the following:

  • How to identify the signs of slavery and human trafficking;
  • What initial steps should be taken if slavery and human trafficking is suspected;
  • How to escalate potential slavery or human trafficking issues to relevant parties within the organisation;
  • What external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and Stronger Together initiative

Awareness-Raising Programme

As well as training staff, the organisation has raised awareness of modern slavery issues by placing posters across the organisation and showing the Stronger Together video at every induction/refresher induction session.

The posters and video explain to staff:-

  • How to identify the signs of slavery and human trafficking;
  • What employees can do to flag up potential slavery and human trafficking issues to the relevant parties within the organisation; and
  • What external help is available, for example through The Gangmasters Licensing Authority and Modern Slavery Helpline.

Board Approval 

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.

Director’s name:

Helen Muir, HR Director/Company Secretary             


Helen Muir


19th March 2019                        




Contact Us

Dawnfresh Seafoods Ltd.
Bothwell Park Industrial Estate
Uddingston, Lanarkshire
Scotland G71 6LS

T: +44 (0) 1698 810008
© Dawnfresh Seafoods Limited 2020. All rights reserved. Company registration number – SC053773.