Ensure that no worker pays recruitment fees, directly or indirectly. Review recruitment practices and verify that any third-party labor agents are not charging fees to workers. Conduct worker interviews and recruit through verified ethical recruitment agencies. 

• • Take Action, Action 2: Develop and implement guidelines for responsible recruitment

Require clear wage structures, no document retention, and transparent deductions in contracts with labor agents and hiring managers. Include rights-based performance clauses and conduct spot checks to ensure they are upheld. 

• • Take Action, Action 2: Develop and implement guidelines for responsible recruitment

Review and standardize employment contracts across your sites and your suppliers. Contracts should be clear, multilingual, and include terms on wages, working hours, rest days, and repatriation. Support suppliers in delivering verbal briefings or visual aids to explain terms to workers. 

• • Take Action, Action 2: Develop and implement guidelines for responsible recruitment

Ensure that working hours, rest time, and safety policies comply with national law and international standards. Use punch cards or electronic logs to track hours, and audit living quarters to verify cleanliness, occupancy limits, and fire safety compliance. 

• • Take Action, Action 1: Instill standard good practices as prevention mechanisms in designated high-risk areas

Train production supervisors and HR staff on recruitment risks, understanding and protecting workers’ rights, and communication. Host training in partnership with local organizations or experienced facilitators who understand the seafood sector. 

• • Embed, Action 5: Train employees on human rights due diligence policies, procedures, and expectations

Provide accessible, anonymous grievance channels. Consider secure physical drop boxes, toll-free hotlines, text-based reporting apps, or partnerships with local NGOs. 

• • Take Action, Action 4: Develop and implement effective grievance mechanisms with remedy

Establish or support functioning worker committees. Facilitate regular dialogue between management and workers, ensuring that meetings can be scheduled during work hours. 

• • Engage, Action 3: Establish safeguards and develop ongoing collaboration with workers

Partner with civil society to build worker awareness of grievance mechanisms and support grievance resolution. Offer joint training, outreach, and on-site drop-in hours for worker support groups.

• • Take Action, Action 4: Develop and implement effective grievance mechanisms with remedy

Promote freedom of association by engaging with trade unions, worker committees, and trusted organizations. Ensure workers can organize safely and are involved in identifying and addressing labor risks. 

• • Engage, Action 3: Establish safeguards and develop ongoing collaboration with workers

Display grievance information clearly where workers congregate, such as in canteens and housing facilities. Include contact details, instructions, and workers’ rights in multiple languages.

• • Take Action, Action 4: Develop and implement effective grievance mechanisms with remedy

Work with suppliers and labor providers to correct problems when they arise. For example, reimburse illegal recruitment fees and update procedures to prevent recurrence. 

• • Take Action, Action 2: Develop and implement guidelines for responsible recruitment

Coordinate with buyers to align expectations and get support for remediation. Share improvement plans and seek co-funding for systemic solutions, such as updated housing or digital timekeeping or pay systems. 

• • Take Action, Action 5: When human rights violations are found in your supply chain, respond with corrective action and timely remedy

Join platforms or improvement groups tackling labor risks in seafood. Share best practices, learn from others, and deploy responsible recruitment expectations across shared supply chains. 

• • Engage, Action 4: Participate in diverse, collaborative industry efforts to support HRDD program development

Monitor key metrics like recruitment fees repaid, worker grievances resolved, and improvements made in housing, contracts, or rest time. Set internal goals and review them regularly.

• • Iterate, Action 1: Assess the efficacy of your company’s human rights due diligence practices and seek opportunities for improvement

Publish anonymized case studies or success stories to show progress. For example, share how a grievance led to improved worker orientation processes, or how housing was upgraded in response to worker feedback. 

• • Communicate, Action 2: Publicly report your company’s efforts 

Build trust and position your company as a responsible partner by being transparent about ongoing challenges. Communicate what’s been done, what remains, and how you are working toward better outcomes.  

• • Communicate, Action 2: Publicly report your company’s efforts