Freedom Food Limited

On 3 February Save Seil Sound wrote to the Scottish Charity

Regulator, OSCR, raising issues about Freedom Food Limited,

as follows: 

“(We are) … a campaign group consisting of ordinary citizens in mid Argyll concerned about the damage that is being caused to our local environment and wild life by the massive expansion of aquaculture. I am writing on behalf of the group to ask that you investigate and review the charitable status of Freedom Food Limited (“FFL”), a limited company incorporated in England and Wales (02723670), but which is registered with you as a Scottish Charity under SC038199. According to its published accounts the company is beneficially owned by the RSPCA, whose charitable activities seem to be confined exclusively to England and Wales.

For convenience I quote the sole object registered by FFL with you, as follows:

“To prevent cruelty to Animals by the promotion of humane farming. transportation, marketing and slaughter of farm animals, In particular but without prejudice to the generality of the foregoing, by Implementing a set of rearing and handling standards approved from time to time by the Royal Society for the Prevention of Cruelty to Animals ("the RSPCA)”

As far as can be determined from the information published in their accounts and on the RSPCA website the sole activity carried on by FFL is running a scheme now known as “RSPCA Assured”, in terms of which companies operating various forms of battery farming are able to acquire a badge that eventually appears on the products retailed in supermarkets.  To quote from the website:

“RSPCA Assured, previously Freedom Food, is the RSPCA’s farm assurance and food labelling scheme.

It aims to improve the welfare of animals farmed for our food. RSPCA Assured assesses farms, hauliers and abattoirs to the RSPCA’s strict welfare standards. If they meet every standard, the RSPCA Assured label can be used on their product.

RSPCA Assured allows free range, organic, indoor and outdoor farms to join its scheme as long as the RSPCA’s welfare standards can be met. 

The only way of knowing if a product is RSPCA Assured is if it has the label on it. If it doesn't have the RSPCA Assured label then it is unlikely to have been reared to RSPCA welfare standards.”

In relation to aquaculture it can be estimated from analysis of the accounts that about two thirds of the aquaculture companies operating in Scotland are currently members of the scheme. Payments from these companies are a mixture of membership fees plus a sort of royalty based on the tonnages in the farms. (In recent years an average of 25% of the total stock in Scottish fish farms has died of disease, or has been lost through escapes and it’s not clear if the payments include these.) However there is no published list of members and thus no possibility for members of the public to know from which “farm” a particular product has come. Indeed some retailers have made up false names, such as Marks & Spencer’s “Lochmuir”.

This lack of transparency about the source means that it is impossible for anyone to know if the product he or she is buying has been produced by methods involving the deliberate infliction of cruelty, whether on the actual salmon or on other living creatures. Those opposed to industrial fish farming are so on a number of grounds. Those relevant to animal cruelty include the following:

1 Caging many thousands of salmon, a migratory species, can be  said to be intrinsically cruel. This is evidenced by the totally unnatural behaviour patterns, with the stronger fish on the surface constantly jumping to escape, while the weaker ones below gradually suffocate. This applies to each and every unit.

2 An inevitable consequence of the close confinement is that sea lice are now rife on the West coast. Almost all units are carrying burdens of lice in excess of limits set by the regulatory bodies. Plumes of sea lice eggs are emitted, drift long distances on the tides and attach themselves to wild salmon and sea trout. Individual campaigners have produced photographic evidence showing fish in serious distress, some with gaping holes where flesh has literally been eaten away. Again this problem is endemic.

3 On discovery of excess lice levels operators are required to take action, including in serious cases to cull the fish and put them out of their misery. There have been cases where this has only happened after visits from campaigners. 

4 Companies are now “delicing” salmon by pumping them through tubes into vats of hot water in wellboats, that then discharge the residual waste directly into the sea. On occasions salmon have not survived this process, which seems fundamentally a form of animal cruelty.

5 Salmon farmers routinely obtain government licences to shoot seals. In exchanges on social media representatives of the RSPCA have acknowledged that this happens on at least some of the farms they certify.

6 Accoustic Deterrent Devices, otherwise known as seal screamers, are routinely used to frighten off local seals, despite it’s being known that they damage the hearing of non-target species such as whales, porpoise and dolphins.

7 Companies are now routinely trapping wrasse and lumpfish, “cleaner fish” whose natural function is to keep the shallow inshore waters clear. They are then added to the fish cages to predate on the sea lice on the salmon. On conclusion of the growing cycle these are killed along with the salmon.

All of the foregoing processes are intrinsically cruel and some or all are practised on farms licensed by FFL. It can be argued that instead of preventing cruelty the company is promoting it.

One would expect a genuine certification process to have at least three components, (1) truly independent monitoring, (2) a proper system of inspection and (3) publication of results. Examination of what the RSPCA place on the public record suggests that each is lacking.

Regarding (1), monitoring is via a list that can be accessed here:

https://science.rspca.org.uk/sciencegroup/farmanimals/standards/salmon

It can be seen that the vast majority belong to fish farm companies operating on the West coast. Regarding (2) and (3) no details of inspections are given and nothing is published.

I respectfully suggest that rather than operating as a charity in Scotland, certainly as far as aquaculture is concerned, FFL are operating a licensing scheme to raise money for their sole shareholder, which does not operate here. I suggest that you ask them if any of the companies on the list participate in the scheme, if there have been actual inspections of sites in Scotland, if so for details of the results and to explain why nothing is published. Further it would be useful to know if they have ever refused an application from a fish farm company to join the scheme.”

We were surprised to find that OSCR do not get involved in charities regulated in both Scotland and England. They passed our complaint to the Charity Commissioners, who have now replied as follows:

“Thank you for your email which was referred to us by OSCR for our consideration, in which you raised concerns about FREEDOM FOOD LIMITED - 1059879.

Thank you for taking the time to notify the Charity Commission of your concerns relating to the charitable status of the above named organisation

Your concerns have been assessed by a senior case worker.  We have decided to keep the information you have provided on the charity’s records.  This means that we will reassess this matter should further information come to light.

I would also like to reassure you that the information you have provided will be used by the Commission to highlight particular areas of concern to the public and to drive improvements across the charity sector. We review all matters of concern that come into the organisation on a regular basis to inform our regulatory work and to identify issues or threats of harm to the sector as a whole.

We will also use this information to inform our proactive work with charities to address issues of concern.  This can result, for instance, in a spot check on a charity, a letter to trustees, or a regulatory alert to a particular group of charities

At the Charity Commission we want to ensure that charity can thrive and inspire trust, so once again I appreciate the time you have taken to contact us.”

So, to paraphrase the reply, 

“Thanks for trying Jimmy, now just shove off!”