Ethical issues impacting on the UK seafood supply chain Roger Plant, Ethics Consultant
Background Broad methodology/approach The big picture: recent examples Nature of evidence Countries to watch Industry perceptions Lessons learnt from Thailand Practical tools
Ethics around a long time FAO 2005
ILO 188
Ethics and seafood: conceptual challenges Paradigm shift to social. RFS a clear example, not alone. Disaggregate the social. Fisheries crime through to labour standards. Criteria for due diligence by companies, through their own codes and others. Structural concerns through law and policy reform, often beyond the seafood industry. How best to address these?
In the news
Myanmar Times: Veil of Illegal Recruitment Two of five recruitment agencies had falsified registration cards. Said this was common practice. Crew had no idea they were being sent to a fishing vessel. Heavily indebted, no option but to work in fishing for promised high wages.
AP Report: Ambon case in Indonesia Broke at end of March, when I was in Bangkok. Year long investigation of 40 current and former slaves, abandoned in Benjina. Named a major fishing company in Eastern Indonesia, operating boats with Thai captains and reportedly Thai owned. Led to rapid Indonesian reaction, and creation of task forces on both slave labour and IUU fishing.
Falklands case. Sunday Times reporting Allegations that Falkland Government allowed fisheries to operate under conditions of slavery and piracy. Licenses issued to vessels flagged in countries including South Korea and Taiwan. Vessels allegedly engaged in IUU fishing through exploitation of African and Asian crews.
Under review
Detailed reporting: Cambodian example in African waters Cambodian men held in servitude by traffickers on fishing vessels in African waters. Migrated through recruitment agency legally registered in Cambodia. Met in South Africa by mainly Taiwanese or Chinese brokers. Long-haul fishing with flags from different countries. Little or no payment for months or years at sea. Documents taken.
Example Two. Indonesian migrants on Korean vessels in New Zealand waters Well documented by scholars from Auckland business school, supplemented by media reports. May 2015 report based on interviews with some 300 fishers working on mainly Korean-owned vessels chartered by New Zealand firms. Shifts of over 50 hours, for way below the NZ minimum wage, physical violence and debt bondage. Over 500 workers who had escaped from vessels, taking legal action over the past five years, had received no compensation. An ongoing thorough assessment, after prompting policy reforms.
Improving the knowledge base: Challenges Literature review/academic work key findings. Overview studies are much the same (ILO/UNODC). Highlight gaps, stress the need for more research. Thailand stands out. Dilemma / limitations re data / Defra table. Difficulty defining initial catch area for UK imports. US TIP provides scattered information. USDOL list of goods produced under forced labour only sporadically updated. Even INTERPOL has limited case information. Example of enterprising individuals like Gunnar Album. Have I missed anything? Keen to get reactions.
Horizon scanning and countries to watch Thailand is still the hotspot in the news, but problems are clearly generalized in Asia, and perhaps beyond. Lack of control over the Distant Water Fleets going further into the high seas perhaps more use of vulnerable migrants. Means attention to China, Korea and Taiwan. Russia needs more work. India because of the rapid growth of shrimp farming, and high incidence of bonded labour at the national level. but not a necessary correlation if the new shrimp processing plants are carefully monitored.
Horizon scanning and countries to watch Other major shrimp producing countries like Bangladesh remain at risk. Apart from TiP reports, very little information generated on other countries at potentially high risk level e.g. Indonesia and Vietnam in Asia, Ecuador and some Central American countries Any comments on this analysis? Information is hard to find, but there is still time to fill some gaps.
Industry perceptions due diligence and auditing Most seem confident of skills and capacity to conduct audits at factory level. Can t audit/investigate down to vessel level. Complexity, capacity and cost. But some companies are now making commitments that supplier vessels should be assessed and certified (e.g.. by RFS or its equivalent) over the next few years. Huge potential importance of RFS, adapted to national circumstances, recognised in this area. No standard approach. Differences in approach to auditing/pre-audit i.e. 3 rd parties or internal resources. Some innovative work on supplier vessels. Templates for assessing contractual conditions. Need to work out how to monitor such initiatives on an ongoing basis.
Approaches to remediation Overall experience documented by law firm Baker & McKenzie, managing forced labour and trafficking in corporate supply chains. Moving away from zero tolerance towards remediation focused approach, engaging with suppliers to protect victims instead of immediately cutting off. Seems particularly relevant for seafood industry, with complex supply chains and feed mills. Needs to be carefully communicated to consumers. Can involve working with government. Thai experience is of particular relevance here. Example of other industries (electronics in China, cocoa in West Africa) who have brought in specialist NGOs like Verité and the Fair Labour Association to monitor performance.
Monitoring and reporting A crucial time for UK companies, as the new Modern Slavery Act and its transparency in supply chain provisions begin to be implemented Seafood industry reporting is in some cases becoming more transparent and open. Examples of such companies as Thai Union and CP Foods over the past year. Openly admit to the problems encountered, and explain the remediation measures taken. A question for the industry is whether there is scope for joint reporting, on common approaches and responses. Is this feasible? How could it best be achieved?
Lessons learned from Thailand a model?
Lessons learned from Thailand a model?
Lessons learned from Thailand a model? My own two visits at key times. Second visit essentially to discuss experience with partnerships. Not concerned with fact finding, though clearly ongoing serious problems with DWF, labour brokers and severe exploitation of migrants. Government is acknowledging the problems, engaging in communications and advocacy abroad. Three main industry partnerships in Thailand: ILO Good Labour Practice (GLP Project Issara Shrimp Sustainable Supply Chain Task Force
Brief comments on the Thai experience Highly innovative, and clearly respond to needs of industry at different levels. Some remediating problems, some concerned with training and policy, some bridging the gaps. Risk of atomized projects, need to generate a joined up approach on the policy concerns. Some risk of overlapping. Need to differentiate role of government from that of industry. Positive that problems detected through industry-led initiatives on the ground are generating a group of asks to the government, keeping it on its toes. Positive engagement of civil society and NGOs. A case where monitoring is needed at different levels. Useful for Seafish itself to share a further update?
Industry perceptions key asks Seafood Ethics CLG is clearly welcomed as filling a gap Bridge between industry, NGOs and government on sensitive issues Intelligence sharing is of vital importance A mechanism for showing internationally what the UK seafood industry has done, and can do Some different perceptions on the most useful tools. Country profiles can be useful, but can be simplistic and quickly out of date. How do you ensure that they are up to date? Tailored advice and guidance for the seafood industry. How to address different supply chain concerns?
Indonesia sample country profile Very preliminary. Tabled as a model to provoke thought and discussion. What other elements might be included. Is this kind of country-specific information of practical value. Should an attempt be made to have a uniform model, or adapt the model to different country and supply chain situations?
Next steps Complete this project (end July) Further contact: anthonyrogerplant@hotmail.com. Telephone: 0207 607 6108.