CORPORATE SOCIAL RESPONSIBILITY

POLICY

READY FOR THE FUTURE TOGETHER

ATLANTIC SHRIMPERS LIMITED

3

PREFACE

Atlantic Shrimpers Limited (ASL) was established in Lagos, Nigeria in 1996 and has grown into a successful global business.

We are proud that we have such a successful and responsible organisation. We work hard, look for opportunities and maintain the highest standards. A package of shared values guides our business decisions. In short:

• We contribute to global food security by supplying healthy protein to a wide range of different markets: from the local Nigerian market to the markets of Europe, Asia and the United States;

• We adhere to all local and international regulations that govern our operations;

• We fish responsibly and all of our vessels are fitted with satellite VMS and AIS systems to enable tracking by local fisheries authorities;

• We prefer local management and employees;• We produce and sell the highest quality seafood;• We serve and support our local communities;• We produce with care to sustain healthy ecosystems.

This Corporate Social Responsibility (CSR) policy document is a clear statement of our position. We take this opportunity to set out our environmental and social activities in a structured framework.

Board of DirectorsAtlantic Shrimpers Limited

2

ASL Shrimp Farm, Badagry, Nigeria

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Over the past few years we have

worked to identify what social and

sustainability topics are specifically

relevant for our operations. We have

looked at our strengths and where we

can seize opportunities to add social

value to our local communities. And we

have looked at where we want to make

improvements in mitigating undesirable

impacts. Our CSR manager assisted

the board of directors of ASL in drafting

this CSR policy document.

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ATLANTIC SHRIMPERS LIMITED IN NIGERIA

In 1996 the company was offered the opportunity to buy 15 trawlers from a local company. That was the start of a growing fishing operation in Nigeria under the name of Atlantic Shrimpers Limited. In 2001, a number of vessels were added to the shrimp trawling fleet and the Prim7Stars brand name was acquired. Today ASL employs approximately 1,600 people. The company is located in Lagos, the most populous city in Africa.

In 2016 ASL opened a new 160 hectare black tiger (Penaeus monodon) shrimp farm in Badagry just outside Lagos. This facility includes its own hatchery and processing plant, to be able to control the quality of the final product through its entire cycle. Total production capacity is 1,200 tonnes per annum. The farm, including the hatchery and processingplant, provides work to approximately 300-350 local people.

DISTRIBUTION ACTIVITIES BY PRIMSTAR B.V. IN THE NETHERLANDS

From its headquarters in Hendrik-Ido-Ambacht (near Rotterdam, one of the world’s biggest ports), PrimStar B.V. manages ASL’s worldwide shrimp distribution activities. The most important current markets for ASL products are Europe and the United States. In addition, ASL is expanding its distribution activities in rapidly evolving markets in Asia.

ASL started operating in 1996 as a fishing company in Lagos, Nigeria with 15 shrimp trawlers. Today the company owns 72 shrimp trawlers in Nigeria (representing approximately 50% of Nigeria’s offshore shrimp fleet) and a shrimp aquaculture operation in Badagry, Nigeria. ASL shrimp products are distributed worldwide under the Prim7Stars brand.

CORPORATE SOCIAL RESPONSIBILITY

INTRODUCTION TO ATLANTIC SHRIMPERS LIMITED (ASL)

7

HEALTHY FOOD

CARE FOR (OUR) PEOPLE

RESPONSIBLE PRODUCTION

SUSTAINABILITY IN OUR DAILY BUSINESS

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PILLAR 1Population growth and diet change have increased the importance of seafood protein. We supply healthy, nutritious foodthat is both safe and hygienic. We believe in the prevention of contamination rather than relying on chemical treatments as a solution. (See page 9)

PILLAR 2We strive to take optimal care of the marine ecosystems upon which our company relies. In relation to our aquaculture activities we focus on responsible use of land and water supplies and we avoid damage to local (marine or terrestrial) biodiversity. (See page 13)

PILLAR 3For the production, processing, packaging and transport of our shrimps, we aim to be as efficient as possible, e.g. with the amounts of packaging material used and paying attention to responsible waste handling practices. By working on technical innovations, we aim to decrease our environmental impact in relation to climate change. (See page 19)

PILLAR 4We want to be recognised as a company that takes very good care of its employees and of the people in the communities where we operate. We are very proud of our very good reputation in Lagos, which has come with years of investments and hard work to build lasting relationships with our workforce, their families and communities. We are working hard to achieve the same in Bagadry, where we recently opened the doors of our new shrimp farm. (See page 23)

INTRODUCTION OF THE SUSTAINABILITY PILLARS

This policy document presents the activities we undertake at ASL to minimise our environmental impact and optimise economic and social value. The list of subjects included was established by conducting a materiality analysis following the approach as suggested by the Global Reporting Initiative. The subjects were subsequently organised in four sustainability pillars:

PILLAR 1: HEALTHY FOODPILLAR 2: RESPONSIBLE PRODUCTIONPILLAR 3: SUSTAINABILITY IN OUR DAILY BUSINESSPILLAR 4: CARE FOR (OUR) PEOPLE

CORPORATE SOCIAL RESPONSIBILITY

8 9

CONTRIBUTING TO FOOD SECURITY

Globally, 16% of human animal protein consumption comes from seafood. Wild caught marine fish are generally high in protein and provide a wide variety of vitamins and minerals, including vitamins A and D, phosphorus, magnesium, selenium, iodine and Omega-3. Shrimp is also high in protein and serves as a source of vitamin B12, B6, E and A, selenium, iron, phosphorus, zinc and copper. With a growing world population, demands for healthy and safe seafood products will only increase in the future.

We supply safe, healthy shrimp products to a variety of markets in Europe, the United States, Asia and West Africa. In addition, we contribute to food security in Nigeria by delivering 4,000 tonnes of finfish (the bycatch of our 72 shrimp trawlers) through the 8 fish shops that we manage locally in Lagos and other major Nigerian cities. In addition, some fish is sold through local women, the so called ‘fish mamas’, who sell the fish at local community market places. In the coming years we will strive to further increase the supply of our locally produced seafood in a sustainable manner in order to feed Nigeria’s fast growing population. By doing so, we will create employment and support the Nigerian economy through import substitution and increased exports.

The demand for fish greatly exceeds supply in Nigeria. This is illustrated by the fact that Nigeria imports approximately 800,000 tonnes of fish annually. Our products can thus be regarded as a welcome addition to local markets and a contribution to making the country less dependent on imports. It is our intention not to compete with local fishermen. We have a higher cost price, due to our advanced fishing and processing technology. In addition we do not fish on the same fishing grounds as artisanal fishermen. Our shrimp trawlers are required to operate outside the 5 mile coastal zone in Nigeria.

ACTIVITY IN 2019

• Expand our network of local

‘fish mamas’ in Lagos to engage

further with the local community

and if feasible open new fish shops.

• Increase the availability of locally

produced seafood throughout

Nigeria by making our products

available in retail stores across

the country.

OBJECTIVE 2024

• Investigate the possibility to supply

our products to regions inland from

Lagos and contribute more to food

security in these regions.

PILLAR 1

HEALTHY FOOD

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ACTIVITIES IN 2019

• Have the enlarged effluent water

treatment system on the farm

fully and optimally operational.

• Further develop training

programmes on hygiene, quality

and product safety at the highest

possible level for our aquaculture

employees.

• Obtain ASC certification for

our farm.

OBJECTIVES 2024

• We continue to invest in our

traceability systems in all our

operations, to keep in line with

changes in customer demands.

• We have found or developed a

natural alternative for the use

of sodium metabisulphite.

chemicals or antibiotics. Cooling down the shrimp with an ice chill-bath immediately after harvest stops all metabolic processes. Sodium metabisulphite is added to the ice chill-baths in minimal quantities to prevent melanosis occurring. In the future we would prefer to use a natural alternative.

QUALITY CONTROL IN OUR WILD-CATCH OPERATIONSWe have carefully designed our catch handling process on board our vessels to maximise product safety and quality. The shrimp and fish are sorted by species and sizes and, within 2 hours after catch, frozen to a core temperature of -18 degrees Celsius. They are then immediately packaged into final consumer packages and subsequently stored at -24 degrees Celsius in the vessels’ cold stores.

This approach ensures a very short processing chain reducing risks of contamination and reducing the number of critical control points in the HACCP process. We put much effort in raising awareness and increasing the level of knowledge concerning safe and hygienic operations on-board our vessels through obligatory training programmes provided at our own schooling facility at the centre of our operation in Lagos. We guarantee traceability of the fish and shrimp products by registering the fishing vessel and date of catch on the consumer package, immediately after catch. Product quality is checked by our own staff when the vessel comes into the port, by visiting buyers and by the Nigerian Federal Department of Fisheries.

TOP QUALITY PRODUCTS AND FOOD SAFETY

Food safety is the top priority for all our products. At the same time, we want to deliver a product as natural as possible: free from artificial colours or flavours or any chemical residues.

Since our operations are in a country with a warm climate and such circumstances are often beneficial to micro-organism growth, we face a major challenge. We overcome this through our production designs, which are aimed at the prevention of microbial growth and through the implementation of extremely strict hygiene protocols. We do this throughout our production and processing chains. This way, we do not have to resolve microbial growth chemically. Designing and updating HACCP (hygiene management) protocols, monitoring product quality, continuous training of personnel, and ensuring traceability of our products to customers are therefore of the utmost importance.

QUALITY CONTROL IN OUR AQUACULTURE OPERATIONSWe want to supply natural products which are guaranteed free of antibiotics or other veterinary medicines. We are aware that in the aquaculture industry, disease outbreaks are a commonly encountered problem. In order to prevent or treat such diseases, veterinary medicines are often used. The residues of these drugs can be detrimental to human health and with the use of antibiotics, there is a risk of developing antibiotic resistant strains of human pathogens. However, we believe in the prevention of contamination rather than relying on chemical treatments as a solution.

We are currently in the process of applying for the sustainable ASC1 certification. Since we source larvae from our own on-site hatchery facility and processing of the harvested shrimp is done in our own on-site processing plant, we are able to control the treatment of our product throughout the entire production and processing cycle. All quality control mechanisms in the on-site processing plant are BRC2 and IFS3 certified.

At the farm, we focus on preventative measures like establishing a water treatment system, which treats the incoming seawater mechanically with drum filters and UV treatment. Such a system, together with the biosecurity protocols that we have in place, help us to eradicate potential disease vectors without having to use any

ALL QUALITY CONTROL

MECHANISMS IN THE

ON-SITE PROCESSING

PLANT ARE BRC AND

IFS CERTIFIED

1 ASC = Aquaculture Stewardship Council, a certification for environmentally and socially responsible seafood. See www.asc-aqua.org.

2 BRC = BRC Global Standard for Food Safety. See www.brcglobalstandards.com3 IFS = International Featured Standards, a global standard for Food Safety and Quality. See www.ifs-certification.com.

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SUSTAINABLE EXPLOITATION OF WILD STOCKS

In shrimp trawling a mix of shrimp and fish species is caught. Taking care of the marine ecosystem means that fishing pressure on biological populations should not be beyond what will secure the natural regeneration of that population in the long term. One way in which overfishing of target species is prevented lies in the fact that we are only allowed to fish outside the 5 mile fishing limit, so that we catch large, mature shrimp. Therefore the deltas, where the shrimp breed and nest, are avoided.

We have operated a fleet of 72 vessels in Nigeria for some time now and have a good understanding of trends in the abundance of the shrimp populations that we target. We believe that the catch levels of the entire national fleet are currently near maximum sustainable levels. Increases of total catches or of the fleet’s catching capacity are probably not wise. For this reason, we are wary about further increasing the size of our fleet. Newly built vessels will most likely replace older vessels being decommissioned. This was also one of the reasons for deciding to invest in shrimp aquaculture.

Since our vessels form a substantial part of the locally active fleet, we acknowledge that we have the ability to assume a leading role in progressing scientific research on fish and shrimp population abundance. For the purpose of monitoring product quality and for our sales department, all our skippers carefully register all catch quantities by species and size classes and report these daily to our office in Lagos. We believe that this detailed data could potentially provide a basis for scientific analyses of trends in the stocks that we catch.

Aquaculture farms may have an impact on global marine wild stocks, albeit indirectly, through the use of wild caught marine fish in feed. The amount of wild caught fish needed per unit of output from the aquaculture farm may vary substantially, depending on the composition of the feed and the feed conversion ratio (FCR) achieved on the farm. A critical factor in guaranteeing sustainability is knowing the origin of the feed ingredients, i.e. whether the fish used comes from sustainably managed fisheries. We strive to source the most sustainable feed available by purchasing feed from renowned and reliable suppliers, from who we demand transparency about their sourcing practices.

ACTIVITIES IN 2019

• Work exclusively with ASC

certified feed on our farm.

• Have our historic catch data

analysed by a scientific research

institute.

OBJECTIVES 2024

• We have established a relationship

with researchers to make our catch

data available on a structural basis

for the purpose of conducting stock

assessments.

• We have explored the possibility to

obtain MSC4 certification for our

shrimp fishery.

• Work with our feed supplier to

enable sourcing of ASC certified

shrimp feed produced locally.

PILLAR 2

RESPONSIBLE PRODUCTION

4MSC = Marine Stewardship Council, a certification for sustainable and well managed fisheries

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ACTIVITY IN 2019

• Improve control systems (for

example with the implementation

and use of Vessel Monitoring

System) and combat IUU

fisheries in collaboration with

NITOA and the Nigerian

authorities.

• In our regular briefings before

departure, we remain focused on

the correct implementation of

fishing legislation by our captains

and other crewmembers.

OBJECTIVE 2024

• We have zero infractions on

fisheries legislation.

COUNTERING IUU FISHING AND COMPLIANCE WITH (INTER)NATIONAL LEGISLATION

Fisheries cannot be managed sustainably if illegal, unreported or unregulated (IUU) fishing activities occur. IUU fishing practices undermine the efforts of those who fish in a responsible manner.

Particularly in developing countries, IUU fishing can constitute a problem. At ASL, we are 100% dedicated to fully comply with all national and international fisheries legislation. This means that we obtain all necessary permits and licences from the Nigerian authorities or authorities in any neighbouring countries where we operate. We aim to aid the Nigerian authorities in implementing improvements to the fisheries regulatory system by entering in open dialogue with them. We do this together with other companies active in the area through the local Nigerian Trawler-Owners Association (NITOA). We work together with local control authorities in a transparent manner and share information with them about any observed IUU practices.

STRENGTHENED CULTURE OF COMPLIANCE

In 2017 we suffered a very unfortunate incident with one of our fishing vessels. The vessel was correctly licensed to fish in Ivory Coast waters but was accused of fishing across the sea border, within the territorial waters of Liberia. The vessel did not have a fishing licence there. Such an incident is against ASL company policy and all instructions given to skippers before they sail. We hold the strong position that an incident like this should not have occurred and should never re-occur in the future. To strengthen our culture of compliance and have better control over our fishing fleet whilst at sea, we have taken several measures, by which we are confident that incidents like this will be prevented in the future:

• Before each fishing trip, the skipper and crew are briefed by the company on a number of issues, including the fishing plan. In the future, during the briefing, the risks of fishing in or near borders will be emphasised more. Border areas should be avoided whenever possible, by the use of planned buffer zones.

• When fishing near a border area is part of the fishing plan, each vessel will be accompanied by at least one other ASL vessel to be able to assist in the case of an incident with engine or navigation problems. This is to prevent the vessel accidentally going across any border.

• VHF Automatic Identification System (AIS) units are installed on our trawlers by which skippers can see the locations of the vessels nearby (fitted with AIS) in their vicinity. In case of an emergency, the skipper can approach a vessel nearby for assistance. AIS is also monitored by the Nigerian Navy.

• All our vessels are equipped with an independently verified Vessel Monitoring System (VMS). VMS is a satellite based monitoring system, which provides data to the authorities on the location, course and speed of the vessels at regular intervals. This means that the entire fleet can be tracked from a distance to allow authorities and our fleet managers to conduct effective enforcement activities.

AT ASL, WE ARE 100% DEDICATED

TO FULLY COMPLY WITH ALL

NATIONAL AND INTERNATIONAL

FISHERIES LEGISLATION.

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ACTIVITY IN 2019

• We continue to work on

developing lighter fishing gear

and adopt it on a number of

vessels to test its performance.

If successful, we start adopting

the new gear across our fleet.

OBJECTIVES 2024

• We have increased our

knowledge of the bottom habitat

types on which we trawl and

where appropriate, we have

taken measures to mitigate

damages by creating maps of

wrecks for distribution within

the fleet.

• We have introduced innovative

technologies and lighter gears

across our fishing fleet.

ACTIVITY IN 2019

• Make final adaptations to the

ETP system to achieve optimal

performance and apply for

ASC certification.

OBJECTIVE 2024

• Our water quality monitoring still

shows that we are not negatively

impacting local fresh water

resources.

ECOSYSTEM IMPACTS OF OUR AQUACULTURE OPERATIONS

For the establishment of our farm, we found a stretch of land where no mangrove trees were growing, but which was a very suitable place for starting our operations. Therefore no mangrove trees needed to be removed. We are aware that mangrove trees represent the fundamental key elements of a healthy ecosystem and support biodiversity, climate resilience and the livelihoods of local communities. Therefore, if we would need to remove any mangrove trees in the future, we will make sure they are compensated for by relocating them or by planting new trees at another location.

Freshwater resources are limited in many areas and deserve protection in terms of quantity and quality. Failing to acknowledge this could lead to local depletion of supplies, which can be catastrophic to local communities that depend on them. Similarly, pollution of fresh water supplies through the disposal of unchecked waste (water) would be equally detrimental. In order to ensure that neither are occurring, the water quality of the ground water source we use is tested continuously for contaminants and for signs of depletion such as salinization.

Treatment of our waste water is the most important way to avoid contamination of the environment. It is therefore of the utmost importance that our effluent water treatment plant (ETP) system is well maintained. The ETP system that we installed was designed according to international standards. Environmental laws demand frequent analysis of waste water quality to monitor that the water is not contaminating the environment. Besides that we monitor this ourselves, this is monitored by the Nigerian authorities and by an independent party at regular intervals.

Besides pollution of the environment through waste water, local biodiversity could be impacted through the escape of shrimp which may spread diseases to the local wild populations. To prevent shrimp from escaping, the dykes around the ponds are built high to avoid flooding and the effluent water from the ponds flows through a fine screen mesh installed in the ETP. To prevent the spread of diseases via crabs or birds, specially designed overhanging fences around the ponds have been installed.

ECOSYSTEM IMPACTS OF BOTTOM TRAWLING

Bottom trawling is generally associated with a risk of damaging bottom habitats. Dependent on the habitat type (sea grass, coral reef, rock gardens or sandy plains) and the equipment used, the extent of damage varies. Our shrimp vessels use outrig equipment, which makes contact with the sandy bottom especially where the otter boards are towed over the seafloor. We participate in gear technology advances to minimise sea-floor damage of our operations, i.e. by developing and adopting lighter fishing gear.

Although we believe that turtles only rarely occur in the area where we are active, all our vessels have nets equipped with turtle excluder devices (TED) as a precautionary measure. With our operations, we were able to obtain a sustainability certification from Friends of the Sea for our main target species wild tiger shrimp (Penaeus monodon).

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MATERIAL USE AND WASTE MANAGEMENT

In our operations we buy and use various materials and we produce waste. Packing the shrimp and fish immediately in final consumer packages on board the vessels in Nigeria is not only beneficial for food safety but also for efficient material use. We are continuing to experiment with smarter packaging solutions, for instance by reducing the size of the plastic wrap around our shrimp packaging.

There is some room for improvement in the handling of waste on board of our vessels. We strive to make improvements in awareness about and management of waste.

An important issue with respect to waste is the loss of fishing nets. Our trawlers sometimes lose nets due to the presence of ship wrecks or obstructions on the ocean floor. Loose drifting fishing nets can form a threat to marine animals as they can get entangled in them. At the same time the ship wrecks or other obstructions on the ocean floor are a threat to the safety of the vessels and employees since getting stuck on them may cause problems.

ACTIVITIES IN 2019

• Include the subject of waste

handling into our staff training

programme and/or initiate an

awareness campaign about

waste handling.

OBJECTIVES 2024

• We will implement a system on

board the vessels with which

skippers can map wrecks in our

operating waters and we share

this information with other

fishers and fishing companies in

the region.

• We have reduced the number of

nets that our vessels lose

annually.

• We have investigated smart

packaging concepts and

sustainable package material.

PILLAR 3

SUSTAINABILITY IN OUR DAILY

BUSINESS

2020

ACTIVITY IN 2019

• We will investigate the feasibility

of installing solar panels at our

shrimp farm in Badagry and at

our wharf in Lagos.

OBJECTIVES 2024

• To have an up to date insight in

our energy use and CO2 footprint.

Based on this information we

plan to implement a strategy to

reduce energy use and green-

house gas emissions further.

• To increase the share of

renewable energy in our

energy mix by 10%.

• To use some solar power

at our shrimp farm, in case the

results from the feasibility study

are positive.

ENERGY USE AND GREENHOUSE GAS EMISSIONS

Our processing plants use energy and our trawlers need fossil fuels. Supplies we use in our operations are transported to our facilities. Finally, our products are transported to our customers. During all these activities, greenhouse gases are emitted. We continually investigate ways to reduce conventional energy use and possibilities to transition to renewable energies. The recently started project to investigate the adoption of lighter fishing gears is aimed at reducing fossil fuel use. As fossil fuels are expensive, their availability uncertain and prices volatile succeeding in this would bring ecological as well as economic benefits.

Technological advances, such as building new vessels, which are specifically designed to be fuel efficient are built of longer lasting durable materials, need little maintenance and are safer, provide major benefits on many levels. Such transitions in the fleet come with substantial investments and thus move at a slower pace. However we have started with two newly built shrimp vessels in the fleet and the initial performance results are very good.

We reduce transport distances where we can, for instance by aiming to source as much as we can locally. For example, our cardboardpackaging was originally produced in the Netherlands, but we now source from a Nigerian supplier.

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WE INVESTIGATE WAYS TO

REDUCE CONVENTIONAL

ENERGY USE AND

POSSIBILITIES TO

CHANGE TO RENEWABLE

ENERGIES.

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HUMAN RIGHTS

We have over 1,600 people employed at ASL and through the decisions that we make about their employment conditions we have an impact on their wellbeing. With regard to human rights, the situation is straightforward: we never engage in forced labour or child labour. We make sure that we comply with all relevant national and international human rights legislation.

Decent working conditions are an important human right as well as a prerequisite for establishing positive and long lasting relationships with our employees. We work predominantly with local employees in order to contribute to the local economy (e.g. 96% of our staff are Nigerian). Since working in the fishing sector can be physically demanding with long working days and weeks away from home, we pay great attention to worker safety and we feel that compensation should be fair.

Employees also receive pension, health care benefits and women receive maternity leave and compensation. We make sure our employees receive adequate training, are aware of safety-at-sea instructions and use protective equipment at all times. We encourage employees to connect with local Labour Unions but we like to take a proactive approach to resolving potential problems.

We believe that if we can offer people jobs that are not only safe and satisfying, but also provide prospects of increased responsibilities and personal development, they are likely to stay with us. Several Nigerian employees who have joined our company as sailors in the past, are now holding positions of Captains and Chief Engineers. With our help through coaching and trainings they have passed the necessary examinations to become licensed to carry out these new positions.

In relation to our supply chains, we do everything we can to ban abusive practices through our supplier choices. We already discussed in pillar 2 that we carefully select our feed suppliers from an ecological sustainability perspective, but even more important is that we make 100% sure that the feed used at our shrimp farms does not come from sources linked to above mentioned practices.

ACTIVITY IN 2019

• Work together with our feed

suppliers to guarantee sourcing

of sustainable shrimp feed for

the farm.

OBJECTIVES 2024

• We continue to be a responsible

employer by constantly informing

ourselves if wages are still in line

with local living cost standards and

making sure that we provide decent

and safe working conditions.

• We continue to remain vigilant of the

sources of the feed used at our

farms and demand traceability

from our suppliers.

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PILLAR 4

CARE FOR (OUR) PEOPLE

24 2524 25

ACTIVITY IN 2019

• Reinforce our work on preventing

piracy incidents together with

local partners through the

Nigerian Trawler-Owners

Association (NITOA).

OBJECTIVE 2024

• Continue to organise safety and

health awareness campaigns

for our employees and in our

neighbouring local communities.

ACTIVITY IN 2019

• Continue working with the

Community Nursery and Primary

School in Lagos to improve

education facilities there.

OBJECTIVE 2024

• A majority of the people that we

recently recruited for work on the

farm and in the factory are still

working with us and we have helped

them develop their skills and their

employability.

COMMUNITY CARE

Similar to investing in lasting relationships with our employees, we aim to have a positive impact in the local communities by establishing lasting relationships with local partners. We engage in collaborations rather than compete with local entrepreneurs. We buy our supplies locally as much as we can and distribute much of our fish via a network of local ‘fish mamas’, so that we indirectly support jobs for many women.

Respecting local communities means that we take into account local culture and customs. Having been active in Nigeria since 1996 we have established a mature relationship with national and local governments and have earned ourselves a reputation for being a serious and reliable business. Our business integrity is based on transparency and honesty. We never engage in the direct or indirect offer, payment, soliciting or acceptance of bribes in order to circumvent regional, national or international legislation.

We would like to make a positive contribution to children’s education in Nigeria. In 2016 we decided to adopt a Community Nursery and Primary School located in Festac Extension, Mile two, Amuwo Odofin Local Government Area, Lagos. Since the adoption we have been improving and maintaining the infrastructure of the school.

SAFETY AND HEALTH CARE

We apply a strict ‘no illegal drugs and no alcohol’ policy at our premises and on our vessels to prevent substance abuse or addiction and to minimise risks of accidents. We make sure that our employees have access to safe and clean dormitories, adequate sanitary facilities and are provided with healthy, nutritional food while living on our vessels. Our fishermen and their families receive free medical assistance at our own small clinic in Apapa, Lagos, which is manned by a doctor and two nurses. Emergency medical services are also covered for employees and their families at a hospital located nearest to their home in case they cannot reach the Apapa Clinic. Farm employees at Badagry farm receive medical services at our on-site clinic.

A crew safety issue of another nature comes from the occurrence of piracy along the Nigerian coastline. Based on risk analyses, we aim to avoid fishing areas with a high occurrence of piracy, and for a number of years we ordered our vessels to fish in groups rather than individually. At the moment we record and report incidents with piracy to local authorities and security agencies such as the Federal Department of Fisheries, Nigerian Navy and NIMASA5, and other local fishing companies. We have investigated available techniques to try to prevent pirates from boarding our vessels.

WE AIM TO HAVE A

POSITIVE IMPACT IN THE

LOCAL COMMUNITIES BY

ESTABLISHING LASTING

RELATIONSHIPS WITH

LOCAL PARTNERS.

5 NIMASA = Nigerian Maritime Administration and Safety Agency. See www.nimasa.gov.ng

26 27

Corporate Social Responsibility is to a certain extent about transparency. We have to explain to the outside world what we are doing and why and how we are doing it. At the same time, efforts to improve the sustainability of our operations will only succeed if our employees and customers understand and appreciate the value of those efforts. Therefore, effective communication, both within our organisation and with the outside world, is essential.

CSR REPORTING The Board of Directors of ASL, drawing from experience with CSR reporting by ASL’s shareholders, will produce annual sustainability reports as a tool to record and monitor developments. We currently maintain records of various indicators for commercial reasons, e.g. for monitoring quality, ensuring traceability and for providing documentation to certification bodies. We will investigate what additional information we should collect in order to make valid statements about the current state of, and progress on, CSR matters described in this document for future sustainability reporting.

INTERNAL COMMUNICATION Last but not least, it is important that our employees see the value of sustainability actions and that they feel empowered and inspired to play their own part. At the end of the day, our employees often have the best ideas on how to improve their daily work. To make the implementation of this plan a success, we will actively share the items in this plan with our staff members. The people mentioned on this page play a vital role in this.

COMMUNICATION

KAMLESH KABRAManaging Director ASLMr Kabra is responsible for the

overall management of all of our

Nigerian based operations and

reports directly to the Board of

Directors of ASL.

MONSURU ADEMOLA BALOGUNGeneral Manager ASL Mr Balogun is responsible

for overall administrative

activities and the

implementation of ASL

policies, such as HR and

Health & Safety policies.

BENEDETTE NGOZIOKONKWOVice President ASL Mrs Ben is responsible for

overall quality control

management at sea and is

involved in overall food

safety management

at ASL.

PRINCE ODION OJEIFOVice President ASL Prince Odion Ojeifo is

responsible for Corporate

Affairs and for liaising

with various government

agencies.

JACCO NUMANCSR Project Manager ASL Jacco Numan is responsible

for monitoring CSR activities.

He works from our sales office

in Holland and visits ASL

frequently.

“In this plan, we have written down who we are, how we work and what our core values are. I am looking forward to work together with our team on the implementation of the planned activities and on achieving our objectives for 2024.”

BOARD ATLANTIC SHRIMPERS LIMITED

For questions or

suggestions contact:

csr@primstar.nl

©2019

www.primstar.com