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MSA Statement

Modern Slavery Act Statement


Introduction from the board
We are proud of the steps we nave taken to combat slavery and human trafficking. We have implemented the True World Foods (UK) Anti-Slavery Policy (the "Policy") which is designed to ensure that we strictly prohibit the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.

It is a priority within the group to ensure that the people we deal with in particular suppliers and our representatives) share this responsibility and reflect our values to prevent slavery. servitude and forced or compulsory labour.

The Organisation's structure
Our ultimate parent company is UCI. a District of Columbia-based. not-for-profil corporation. UCI owns 100% of the shares of One Up Enterprises, Inc., which is based in Delaware. That company owns 100% of the shares of True World Holdings LIC. which is based in Virginia. which in turn owns the entire shareholding of True World Foods, Ltd., which is based in Ireland. True World Foods, Ltd., owns 100% of True Word Foods (UK) Ltd.

Our group has around 1,000 employees worldwide.

We are involved in buying and distributing fresh and frozen seafood. We acknowledge that this is an industry with an increased risk or modern slavery, given the nature of the industry and the countries in which our suppliers operate.

Our supply chains
Our our supply chains mainly will relate to the supply and distribution of fresh and frozen seafood. We import from Australia, Japan, Korea, China, Vietnam, Thailand, SrI Lanka, the Maldives and Norway. As some of these countries are at a particular higher risk of modern slavery, we remain vigilant at all times with regard to slavery and human trafficking.

Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our suppiv chains or in any part of our business. Our Policy reflects our commitment to acting ethically and with integrity in a our business relationshios and to implementing and enforcing effective systems and controis to ensure slavery and human traffickino is not taking place anvwhere in our supply chains.

Due diligence processes for slavery and human trafticking
As part of our initiative to identity and mitigate risk. we have in place systems to:

  • Identity and assess potential risk areas in our supply chains

  • Mitigate the risk of slavery and human trafficking occurring in our supply chains

  • Monitor potential risk areas in our supply chains

  • Protect whistle blowers

Supplier adherence to our values and ethics
We have zero tolerance for slavery and human trafficking. Our suppliers are required to hold their own suppliers to the same high standards.

As part of our ongoing risk assessment and due diligence processes, we consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Policy.

We also assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third panties. Using our risked-based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Policy, which sets out the minimum standards required to combat modern saver and trafficking.

If we find that other individuals or organisations working on our behalf have breached our Policy, we will ensure that we take appropriate action. This may range from considering the possibly or breaches being remedied and whether that might
represent the nest outcome for those individuals impacted by the breach, to terminating such relationships.

Measuring Effectiveness
We will continually monitor the effectiveness of our efforts to combat modern slaver and human trafficking, and will carry out a formal review each year to identify any issues or areas for improvement.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business. we provide training to our staff.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group's slavery and human trafficking statement for the financial year ending 31 March 2021. It was approved by the board of directors on 3rd June 2020.


Bongjin Jung, Director
True World Foods (UK) Limited
Date: 30rd June 2020​

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