Policy Against Human Trafficking and Slavery

Icicle Seafoods, Inc. ("Icicle") is committed to providing a work environment and supply chain that is free from human trafficking and slavery. Icicle takes responsibility for promoting ethical and lawful labor and employment practices and expects the same from all participants in its supply chain. Icicle strives not just to meet the minimum requirement of complying with laws, regulations, and basic human rights, but to ensure that its employees have a safe, fair, equitable, and rewarding work environment.

Verification:

Icicle participates in a heavily regulated industry in which state and federal authorities closely monitor and enforce laws and regulations including licensing and inspecting fishing vessels and crews. This licensing and inspection process ensures that vessels and their crews adhere to applicable health, safety, and labor practices. Furthermore, Icicle utilizes only reputable third party vendors that adhere to all applicable labor and employment laws and regulations. Third party vendors perform ethical audits addressing the health, safety, and working conditions of Icicle employees at certain Icicle facilities.

Supplier Audits and Certification:

Icicle expects its suppliers to conduct business with honesty, integrity, and to adhere to the following standards:

• Not use forced or compulsory labor, i.e., any work or service that a worker performs involuntarily, or under threat of penalty;
• Ensure that the overall terms of employment are voluntary;
• Comply with the minimum age requirement prescribed by applicable contracts or laws;
• Compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply will overtime pay requirement;
• Abide by applicable laws concerning the maximum hours of daily labor and required rest breaks;
• Provide a safe and healthy work environment, including for any company-provided living quarters;
• Respect employees' rights to freedom of association, consistent with applicable laws;
• Encourage a diverse workplace and provide a workplace that is free from discrimination, harassment, and/or other forms of abuse.

Suppliers must be able to demonstrate compliance with these standards at the request and satisfaction of Icicle. Icicle reserves the right to perform periodic random audits to ensure compliance with these standards.

Internal Accountability:

Icicle has a comprehensive Code of Business Conduct and Ethics that requires employees to comply with all applicable laws, rules and regulations and states Icicle's commitment to providing equal opportunity in all aspects of employment. Icicle requires compliance with all applicable health and safety laws and regulations and does not tolerate any discrimination or harassment. Icicle also strictly adheres to all Employee documentation requirements. Violation of Icicle's Code of Business Conduct or any of its rules or practices will lead to discipline up to and including termination. Under no circumstances would human trafficking or slavery be possible or permitted under Icicle's policies and procedures.

Training:

Icicle trains its human resource, recruitment, and management staff on applicable labor and employment laws and regulations as well as on company policies, practices, and procedures to ensure that all applicable laws, regulations, and company policies, practices, and procedures are strictly complied with.