ASSESS

Assess human rights risks to workers in your supply chains

Assessments help your company prioritize its social responsibility efforts. The best human rights assessments include information from different sources, including workers.

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ACTION

01

Conduct an assessment of human rights risks

Conduct a preliminary risk assessment

  • 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).
        • List of all products sourced from each facility.
        • Country of origin for all product(s).
    • Although not specific to the seafood industry, public tools such as the Slavery and Trafficking Risk Template can help companies with preliminary desk-based assessmen:ts. Seafood-specific risk guidance is included in Verité’s Risk Assessment Guidance for the Seafood Supply Chain. Other risk assessment tools are noted in the table below.

Assess

  • Assess supplier risks:
    • 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.
      • Tools such as Verité’s Sample Seafood Supplier/Subcontractor Self-Assessment can be used to support the development of a questionnaire.

Identify

  • Identify the most salient risks:
    • 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.
    • Prioritize suppliers of high-volume or high-value products for deeper engagement to ultimately reach all suppliers associated with high and moderate-risk products.
    • Issue a request for information to suppliers associated with the high-risk supply chains to assess how risks are mitigated.
    • Ensure suppliers are managing and addressing the risks to an extent that meets your company’s expectations.

ACTION

02

Gather additional information on the ground

Conduct

  • 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.
    • Use third-party or independent social auditors with specific expertise in social compliance, interacting with workers, and the local region.
      • Organizations such as the Association for Professional Social Compliance Auditors provide resources for auditor competencies.
      • Auditors should be in good standing and certified or accredited to deliver audits and certifications against the standard used.
      • Practical memos for internal and external auditors conducting assessments of human rights performance can be found in Shift and Mazars LLP’s: UN Guiding Principles Assurance Guidance.
    • 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

  • 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.
    • Undertake a determination of actual and potential human rights risks using the Social Responsibility Assessment Tool (SRA) Tool to assess fishery improvement projects (FIPs) or other regional fisheries systems.
      • Ensure an evaluation team with social science research experience, including human rights and wellbeing protocols, conducts the assessment.
      • Use a worker-driven approach to assessing labor conditions. Workers, fishers, farmers, and their representatives should be involved in the evaluation and consequent program design.

Verité

Shift and Mazars LLP

Walk Free Foundation

Resources for FIP implementers and similar fisheries

  • Social Responsibility Assessment Tool
  • Social Responsibility Assessment Toolkit Templates:
    • Pre-assessment forms
    • Vessel assessment and physical inspection templates
    • Document review guides
  • Conservation International Center for Communities and Conservation Train the Trainer Modules
  • Conservation International and Verité: Enhancing Capacity to Detect and Address Labor and Human Rights Issues and Risks in the Seafood Supply Chain

ACTION

03

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.

Identify

  • Collectively Identify:
    • 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.

ACTION

04

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.
  • Support and advocate for convenings that bring together workers, trafficking survivors, grassroots organizations, trade unions, employers, recruiters, and global brands and retailers. Through these convenings, establish meaningful dialogue and collective action, prioritizing worker-led models.

Optimize Your Company's Path

Discover how companies can apply the RISE Roadmap to improve their social responsibility practices.

Retailers/Brands

  • To start, focus on practices for gathering data, publicly available risk information, and due diligence practices across the many suppliers that contribute to your company’s sourcing.
    • Work with key suppliers (i.e., high volume, long-term) while assessing specific high-risk supply chains.
    • If sourcing from importers, collect additional data to understand the requirements importers have with their own sourcing companies.
      • Ask importers to share sourcing practices of vessels, farms, other producers, and processors from which they source to establish transparency and traceability.
  • Collaborate with other retailers or brands that source from similar regions or suppliers for in-person assessments if possible.
  • If your company sources and sells multiple commodities, understand the human rights risks unique to seafood. (e.g, at-sea work).

Suppliers

  • Maintain an accurate and centralized list of all products purchased and the companies from which they are purchased.
  • If sourcing from importers, collect additional data to understand the requirements importers have with their own sourcing companies.
    • Ask importers to share sourcing practices of vessels, farms, other producers, and processors from which they source to establish transparency and traceability.
  • If your company sources and sells multiple commodities, understand the risks unique to seafood(e.g, at-sea work).
  • Develop systems to store and easily access data so that information can be readily taken in from sourcing companies and conveyed to buyers.

Processors

  • Document company processes to improve social responsibility and mitigate risks.
  • Align data collection with the data required by key buyers (i.e., high volume, long-term).
  • Develop systems to store and easily access data so that information can be readily taken in from sourcing companies and conveyed to buyers.
  • Track instances of worker grievances (e.g., questions to human resources, complaints through trade unions) as they may reveal risks for labor abuse, and resolve worker grievances internally.

Producers

  • Document company processes to improve social responsibility and mitigate risks.
  • Align data collection with the data required by key buyers (i.e., high volume, long-term).
  • Develop systems to store and easily access data so that information can be readily taken in from sourcing companies and conveyed to buyers.
  • Track instances of worker grievances (e.g., questions to human resources, complaints through trade unions) as they may reveal risks for labor abuse, and resolve worker grievances internally.

Build the Foundation

Responsible Recruitment

  • 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.
  • Map labor recruitment in supply chains.
  • Evaluate recruitment practices throughout your company’s supply chains, as verified by workers themselves.

Worker Engagement

  • 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 vessel lists 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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