Ensure that no worker pays recruitment fees, directly or indirectly. If you are working with labor brokers, verify their compliance with ethical recruitment standards. Conduct audits of labor recruiters, request documentation of fee structures, and require suppliers to use approved brokers only. 

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

Include performance expectations and monitoring mechanisms covering wage deductions, loan schemes, and document retention in labor recruiter contracts. Include clauses that enable third-party inspections and set financial penalties for noncompliance. 

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

Ensure that working hours, rest time, safety equipment, and living environments on vessels or in facilities comply with national laws and international standards. Conduct regular inspections and require vessel operators to log hours and rest periods. 

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

Train supervisors on nondiscrimination, anti-harassment, and grievance procedures. Partner with NGOs or training providers to conduct scenario-based workshops on board or on-site. 

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

Install grievance channels that workers trust, such as drop boxes, digital tools, or access to independent support. Provide QR codes that link to anonymous reporting platforms and display posters about these in common areas. Require employers to adopt anti-retaliation policies with associated training for supervisors so workers feel safe to raise issues. 

• • 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 that workers can organize safely and are involved in identifying and addressing labor risks. 

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

Help facilitate elections for worker representatives and ensure that meeting time is scheduled during paid hours. 

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

Collaborate with civil society organizations to provide rights education, facilitate dialogue with management, and co-host training sessions and open forums with trusted local groups. 

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

Enable communication for fishers at sea, including access to Wi-Fi, to allow them to raise concerns and stay connected. Equip vessels with internet hot spots and create agreements on fair use, privacy, and access. 

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

Respond quickly to issues raised by workers. 

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

Engage with buyers to share what steps are being taken to address issues raised and where support is needed. Create joint remediation plans and invite buyers to co-fund pilot programs or training.

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

Join improvement initiatives and collaborate with NGOs, unions, or precompetitive platforms. Contribute to shared resources, pilot ethical recruitment systems, and share lessons through roundtables or joint reports.

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

Involve those impacted by the issues raised in solution design and/or remediation.

• • Take Action, Action 3: Enable worker-led efforts and encourage freedom of association for seafood workers throughout your supply chains

Track and share progress to demonstrate improvement and build trust. Use dashboards, case studies, or anonymized examples to show how issues were identified and addressed.

• • Communicate, Action 1: Communicate to key stakeholders about progress you’ve made against your policies and goals

Demonstrate commitment and credibility by disclosing lessons learned and next steps even if all challenges are not yet resolved. 

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