Use existing data to conduct a preliminary risk assessment:
Review company policies, codes of conduct, supplier expectations, and ensure alignment with international standards, best practices, and seafood expectations.
See Commit for more information about best practices.
Map existing supply chains, flagging products associated with higher risk geographies, species, and production or harvest methods.
To start, identify all Tier 1 suppliers (i.e., suppliers the company purchases from directly). Prioritize the highest volumes of products associated with higher risk geographies, species, and production/harvest methods for further supply chain mapping.
Over time, work to map all suppliers, vendors, agents, and subcontractors to the vessel level, including:
Name of the company.
Name and location of the production facility (as relevant).
Review supplier codes of conduct, human rights policies, and commitments for gaps against your company’s requirements.
Send suppliers a self-assessment questionnaire to determine compliance with your company expectations.
Self-assessments are a standard due diligence practice to understand supplier risks and mitigation practices. However, self-reported information should be verified or validated through additional data sources (ideally including input from workers or their representatives) to verify accuracy.
From your company and supplier assessments, identify the products associated with the most severe human rights impacts. If necessary, use an internal metrics system (such as a scale or rating system that includes supplier, product, and production information) to track or measure risk.
The UN Guiding Principles on Business and Human Rights assess the salience of a human rights issue using four factors: “most severe,” “potential,” “negative,” and “impacts on human rights”—placing the focus on risk to people rather than on risk to the business.
Conduct an audit, site visit, or other activity to verify compliance with corporate commitments.
Include document reviews, interviews, site tours, or other necessary activities. Social compliance audits that do not include workers’ perspectives should be considered less accurate than audits that do.
Identify areas for improvement and develop corrective action plans with time-bound expectations.
Support suppliers in addressing risks and building onsite capacity. Request regular progress updates.
See Build Capacity for more information on corrective action plans and supplier engagement.
Consider conducting an enhanced investigation of risk in consultation with local stakeholders.
If audits are not available or required by your company or its buyers, or if your company wants to supplement existing audits or certifications, consider an in-depth risk assessment conducted in consultation with local groups.
If the appropriate safeguards are in place, engage directly with workers
Only engage workers meaningfully
Ensure that your company only allows direct worker engagement if there are mechanisms in place to act upon the information received, remediate, and the safety and security of workers can be guaranteed.
Inclusive models for worker engagement in that region or facility.
Appropriate information to collect on working conditions.
Safeguards to protect the privacy and safety of workers, particularly against retaliation for grievances identified.
Existing grievance mechanisms that are useful for and used by workers.
Mechanisms for safe, effective remediation when risks are detected or grievances are reported.
Review the Updated Guide to Ethics and Human Rights in Anti-Human Trafficking for more information.
Provide the necessary safeguards
To safely and effectively cultivate relationships with workers, establish:
Protections against retaliation and mechanisms for remediation.
See Build Capacity and Worker Engagement for more information about addressing risk and engaging with workers.
Engage global and local stakeholders to expand the assessment of working conditions
Collaborate with regional partners
Identify organizations that support human and labor rights in countries of production. Consider regional outposts of global organizations as well, such as local unions with global affiliations.
Learn about the services provided by various local organizations, and determine which organizations are most aligned with your company’s goals.
Develop formal relationships through contracts, memorandums of understanding, or other methods of agreement.
Collaborate with other supply chain partners
Extend data collection requirements to all supply chain companies through supplier expectations letters and codes of conduct.
Communicate to suppliers about the data that will be requested of them.
Maintain updated documentation about working conditions and labor rights in supply chains.
Implement data collection and worker engagement processes that involve safe worker participation, if not already in place.
Collaborate with global partners
Work with expert organizations or initiatives to understand the ethical issues associated with collecting data from vulnerable populations and weigh the benefits and risks.
Implement ethical standards and approaches for working with migrant workers and trafficked persons.
Assess recruitment-related risks in supply chains, such as fees and related costs, labor protections in countries of employment, and the prevalence of migrant and other potentially vulnerable workers (e.g., women, seasonal workers) in the workforce.
Collect data on issues raised by workers in the risk assessment, and use this information when identifying salient issues.
Companies that collect data from workers must also be prepared to verify and remedy reported instances that violate company policy.
If issues are not raised through grievance processes and worker engagement, utilize publicly available information from civil society or worker-support organizations to determine whether risks are actually absent or the grievance and worker engagement mechanisms are ineffective.
Decent Work at Sea
Flag high-risk seafood supply chains in assessments, including fishing on vessels in international waters (e.g., tuna) that may be under-monitored and seafood that uses ‘trash fish’ for feed.
Encourage vessels in your company’s supply chain to participate in public vessellists and, to the extent possible, share vessel information with buyers.
If vessel information is available, utilize vessel transparency platforms such as Global Fishing Watch to review vessel-level risks.
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