Ending Slavery in Seafood Supply Chains:

What Businesses Can Do

Overview: Recent revelations have put social responsibility into the spotlight. Now more than ever a company’s reputation depends on the actions taken by suppliers. This briefing provides some steps to lower business risks and help the human beings most at risk, predominantly migrants working where exploitation is unchecked. The recommendations are consistent with the UN Guiding Principles on Business and Human Rights,ILO guidance, and theOECD due diligence framework and mirror the categories of engagement in the UK Modern Slavery Bill and California Supply Chains Transparency Act and similar regulatory mandates.

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Ending Slavery in Seafood Supply Chains:

What Businesses Can Do

The seafood industry imports 100+ product categories from over 200 fisheries and thousands of farms worldwide. Together with governments, companies have a shared responsibility to understand risks of trafficking, child and forced labor (“slavery”) in supply chains.

This is a universal problem found in many commodity industries across every part of the world. However, aban on imports with ties to slavery means shipments may be detained for inspection and traceability paperwork. To be ready for the day-to-day consequences of the ban, we recommend wide screening in advance of any law enforcement activity for hotspots in production. If any are found,seafood buyers can ask their sellers to report on origins and inputs.

Screening should start with the fish, shrimp, and shellfish on the US Department of Labor’s (DOL)list of goods made by child or forced labor.[1] It includes fish from Thailand, Indonesia, the Philippines and Peru, among other countries. See DOL’s "Sweat and Toil" app. DHS agents may inspect products petitioned over concerns of being made with child and forced labor, and these inspections may increase due to the recent change to the Tariff Act of 1930.

Why is change needed?According to the US Department of State, trafficking in fishing is significant in 55 fishing countries. It is now well known that forced labor is prevalent on Thai fishing boats traveling throughout Southeast Asia and beyond with men remaining at sea for 3-6 years or longer working 18-20 hours per day for seven days a week under threat of violence and paid very little or not at all[2]. All levels of onshore seafood processing are also affected2. Forced labor in Thai seafood was hidden in plain sight until June 2014 when the Guardian newspaper connected prawns to slavery[3] and the US Department of State dropped Thailand to the bottom rank for country efforts to combat trafficking in persons. 3000 men were rescued and significant changes are occurring but risks of slavery remain severe for business and laborers alike.

Seafood importers face a difficult task overseeing many aspects of product sourcing including addressing newly found problems in the supply chain.Retailers have a vital role supporting suppliers to drive change within their supply chains. Change is a process andexperiences in other sectors like mining, cotton and palm oil have shown what works and doesn’t.

Steps to Lower Risks of Importing Seafood associated with Slavery

For a company with a strong relationship with a few suppliers, it may be possible to close out exposures directly. For larger companies, getting the information and accountability needed will require a tiered or phased approach that shows a little more understanding of how difficult it’s going to be to show full visibility behind a product.

If, for example, you buy shrimp that comes from a large importer or distributor, under their proprietary brand, you may have no relationship with the importer, much less the producer. So it starts with asking the importer or distributor where they get their shrimp. They’re not going to give a clear answer because they won’t immediately know and must leave room for themselves to buy shrimp on the open market if needed. So it’ll mean contacting the producers that provide the majority of the distributor’s private label shrimp and starting to ask about working conditions. They’ll simply say there is no slavery in their supply, so it’ll require preparations on the background and having the right questions to drill down into subbed arrangements, auction and spot buys, and so on.

In some cases, finding a new supply is an option, but it shouldn’t be the first choice. Instead, engaging suppliers and improving oversight can cause more positive impact. Posing the right questions about the origins and inputs of seafood supplies builds accountability and coverage for this issue. Look upstream to understand regulators’ and investors’ expectations as well. Doing this systematically will reduce risks geometrically and show due diligence to investors, regulators, and others.

The following action plan outlines specific steps any company may take to find and address any risks where they are found.

  1. Plan on addressing this issue. Learn what your buyers need to be safe.
  • Develop and publicly articulate a sourcing statement taking a clear stand against captive unpaid work (or very poorly paid)in all aspects of production and supply.
  • Hold suppliers accountable for their entire supply chain. Require suppliers to demonstrate where materials come from and, when sourcing from known hotspots, how they are made in compliance with local laws on payment for work.
  • Provide training to all staff and direct suppliers on the company’s buying policy, basic risk factors and definitions.
  • Establish procedures for failing to comply.
  1. Understand your supply chain. Understand your risk.
  • Isolate products from fisheries at “high risk” for more questions.

Seek information through the media and existing resources, such as the Sustainable Shrimp Task Force reports and the Labor Safe Screen online survey and reports, for a summary of issues, progress, and key questions for suppliers, such as:

  • Is there a line of command to trouble shoot with suppliers?
  • What does the supplier propose to back you up in future if their product is investigated?
  • Can they show full visibility? (=consistent information for all facilities, including catch, reefer & supply vessels, meal, feed & hatchery facilities, primary through tertiary processing).
  • Who is capable to gather & verify critical information at key nodes of the supply chain?
  • How are they listening to the human rights experts to know where to look?

Talk to the exporter or get independent advice to understand the supply chain.

Work with organizations already making real improvements and remediation plans where violations are found.

  1. Strong industry-wide measures

Ending slavery is a shared responsibility requiring shared definitions and priorities and pooling of resources to make any difference for seafood producers.

  • Support regulatory standards for imports that accomplish the goals of the Presidential Task Force on Seafood Fraud and IUU Fishing and EU anti-IUU strategy and requirements.
  • Engage standards setting and certification entities, such as GAA & MSC, to incorporate and implement effective human rights standards. Ask them to audit for labor recruitment costs. Ask them to include subcontracted facilities in their scope so true employment parameters are known.
  • Participate in industry-wide, pre-competitive collaborations to identify problems and share the cost of developing and implementing solutions (e.g. Shrimp Task Force).
  • Use theSocial Responsibility for Fisheriestool sponsored by Seafish, Monterey Bay Aquarium and Sustainable Fisheries Partnership.

Other best practice measures include:

  • Find ways to hearworker voiceand to bring first-hand accounts of working conditions directly into risk assessment, auditing, and ultimately into procurement decisions.
  • Support local labor rights organizations who are helping migrant workers. A small donation can have a big impact.
  • Cross-check what facility owners and industry organizations are saying with what producers and NGOs are saying.Assign this to a high-ranking executive.
  • Where warranted develop a grievance mechanism.
  • Know your legal risks. Learn from government actors in producing countries and UN, ILO staff.
  • Disclose supplier lists where warranted.

For more information and support, contact:

Katrina Nakamura & Lori Bishop

Blogs on these topics may be found on the Labor Safe Screen and Sustainability Incubator websites.

[1] An American platform for the global evidence base. ILAB-DOL is also an implementer of the Trafficking Victims Protection Act (TVPA), being the primary US Federal anti-trafficking legislation.

[2]ILO 2015

ILO 2013:

ILO and Asian Research Center for Migration 2013:

IOM2011:

[3] Guardian 2014: