Cogai Ltd
Financial Year: 2025–2026

1. Introduction

Cogai Ltd (“Frostflow”) is committed to conducting business responsibly, ethically, and in compliance with all applicable laws and regulations.
This Modern Slavery and Human Trafficking Statement outlines the actions we are taking to prevent modern slavery and human trafficking within our operations and supply chains.

Frostflow recognises that modern slavery including forced labour, human trafficking, and servitude is a global issue that affects all industries. As a growing UK-based food supplier working with international partners, particularly across Africa, we are committed to ensuring that every aspect of our business upholds human dignity and fair labour practices.

2. Our Organisation and Supply Chain

Frostflow is a UK supplier of authentic Afro-Caribbean frozen foods, including snails, catfish, cassava leaves, peppers, and other agricultural produce.
Our products are sourced from trusted farming and processing partners in Africa and distributed to Afro-Caribbean shops, restaurants, and wholesalers across the UK through cold-chain logistics.

As we expand our operations, we are building partnerships with certified processors and distributors who share our ethical and sustainability values. Our supply chain therefore spans agricultural production, processing, packaging, logistics, and retail distribution.

3. Our Commitment

We have a zero-tolerance policy towards modern slavery and human trafficking. We act with integrity and transparency in all business dealings and maintain effective systems and controls to safeguard against any form of exploitation.

Our values Integrity, Responsibility, and Partnership guide how we work with suppliers, employees, and customers.

4. Identifying and Assessing Risk

We acknowledge that the agricultural and food processing sectors, particularly in developing regions, can be exposed to modern slavery risks such as:

• Seasonal or informal labour
• Third-party recruitment without proper oversight
• Limited enforcement of labour standards in smallholder operations
  
  

To address these risks, we are mapping our suppliers and assessing risk exposure based on geography, employment practices, and the nature of goods supplied. This assessment will form part of our annual supplier review process as Frostflow continues to grow.

5. Due Diligence and Supplier Standards

Frostflow is implementing a Supplier Code of Conduct requiring all suppliers to:

• Comply with all local and international labour laws
• Prohibit forced, bonded, or child labour
• Provide safe working conditions and fair wages
• Maintain transparent recruitment and employment practices
  
  

Suppliers who fail to meet these standards or refuse to cooperate with audits may face suspension or contract termination.

We also ensure that Frostflow’s own operations including warehousing, packaging, and logistics comply fully with UK employment law and uphold fair working conditions.

6. Policies and Governance

Our ethical framework is supported by the following policies:

• Supplier Code of Conduct (in development)
• Whistleblowing Policy
• Sustainability and Quality Policy
• Anti-Bribery and Corruption Policy
  
  

These are reviewed annually by Frostflow’s management team and form part of our wider compliance roadmap as we progress towards BRC certification.

7. Training and Awareness

We are raising awareness among employees and partners about the risks of modern slavery.

• Procurement and logistics staff are being trained to identify warning signs of exploitation.
• Modern slavery awareness will be integrated into onboarding and compliance sessions.
  
  

As Frostflow expands, we will develop formal training modules in collaboration with ethical trade and sustainability experts.

8. Monitoring and Performance Indicators

We measure the effectiveness of our approach through:

• Annual supplier reviews and risk assessments
• Supplier compliance with the Code of Conduct
• Employee completion of ethics and awareness training
• Zero reported incidents of modern slavery or human trafficking
  
  

Progress is reviewed annually as part of Frostflow’s sustainability reporting.

9. Future Commitments

In the coming year, Frostflow will:

• Finalise and issue our Supplier Code of Conduct
• Incorporate ethical sourcing clauses into supplier contracts
• Pilot supplier audits in key sourcing regions
• Include ethical and labour standards in our sustainability metrics
• Strengthen collaboration with producers demonstrating fair labour and environmental standards
  
  

These steps are integral to our sustainability roadmap and support our goal of achieving BRC certification by 2030.

10. Approval

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and constitutes Frostflow’s Modern Slavery and Human Trafficking Statement for the financial year ending September 2026.

It has been approved by the Board of Directors and signed on their behalf.

__________________________

Management, Cogai Ltd
Date: 01/10/2025

Registered Address:
Frostflow
Unit 5 St. Margarets Estate
St. Margarets Road
Dartford, Kent, DA4 9LB
United Kingdom