Modern Slavery in the Fishing Sector

Introduction

In the last 12 months, there has been significant media coverage of human rights abuses in the Thai fishing fleet. Some of the catch is used for the production of fishmeal, which is then used as an ingredient in farmed Shrimp feed, the Shrimp then being exported to western markets (including USA and EU) where importers, retailers and consumers see these abuses as completely unacceptable.

Media attention has increased and reports published by the UK newspaper “the Guardian” in mid-2014 (http://www.theguardian.com/global-development/series/modern-day-slavery-in-focus+world/thailand) have stimulated significant debate in seafood supply chains.

Background

Slavery has existed for centuries and persists today, the difference being that chains and manacles have been replaced by less visible means of holding labour captive and abusing human rights. Identity documents may be confiscated and held by employers, debt used as a means of retaining labour e.g. repaying various costs, or abusing migrant and illegal workers who are reluctant to complain to the authorities.

The fishing sector is particularly vulnerable for many reasons, including:

  • Long periods at sea preventing crew from leaving the boat
  • Poor working conditions and long hours associated with processing catch
  • Lack of access by enforcement authorities when at sea
  • Foreign flags used to create barriers to enforcement
  • Use of migrant labour lacking representation

Verification of labour standards in developing world countries is also extremely difficult. Written policies can be worthless and an auditing approach relies on interviewing workers and employers who may be under duress, in fear of reprisals or other consequences. Their responses may need to be translated to the auditor, creating a filter and opportunity for misunderstanding. Just confirming the true identity of an interviewee may be difficult. Workers may also not want a reduction in a common non-conformance, working hours, as this will inevitably result in reduced income or the loss of their employment. This causes difficulties in shore based facilities but becomes even more of an acute problem at sea.

The disincentives to meaningful data gathering need to be considered with expert certification and audit bodies with experience in this field. Aggregation and anonymisation of responses are a prerequisite for any reliable audit result.

Supply chains are also notoriously difficult to map – a UK International Sustainability Unit project in 2013 into the use of mixed species whole fish in fishmeal in Thailand encountered difficulties tracing fishmeal supplies into feed manufacture due to mixing and consolidation of catch from small boats and limited record keeping.

Regulatory and enforcement structures may be weak in developing world countries and compromised further by corruption.

Fishmeal production in Thailand

Our most recent indications (2013 – Thai Fishmeal Producers Association) are that Thailand is one of the worlds’ larger producers of fishmeal at around 460,000 tonnes, used entirely for domestic production of farmed fish and shrimp feeds. This total is comprised of:

Tuna by-product                              140,000 tonnes

Other species by-product            160,000 tonnes

Mixed trawl whole fish                  160,000 tonnes

While a significant percentage (40%) of the fishmeal production in Thailand is based on mixed trawl whole fish, this compares to only 15% (IFFO estimate) of global fishmeal production, originating mostly in China and South East Asia, with the balance of raw material from by-product and targeted single species whole fish.

The media attention has focussed on fishmeal used in farmed shrimp feed. Current inclusion rates in shrimp feed are around 20%, making it one of the highest aquaculture fishmeal users in percentage terms. However, CP Foods announced an intention to introduce a zero fishmeal shrimp feed, initially in response to environmental concerns about overfishing. This has not yet occurred as, although a zero fishmeal diet could be made, growth rates of farmed shrimp would be lower and potentially disease risk increased. CP have also preferred a leadership position to address problems rather than formulate the problem away.

IFFO position

The importance of social and labour standards has been raised within the IFFO membership, including presentations on Ethical Trading (IFFO Annual Conference, Istanbul 2012) and coverage in IFFO Monthly Updates. It is an area in which IFFO members have good standards with some excellent examples of workforce and community engagement. However, outside IFFO membership, there are many small fishmeal producers who will be receiving raw material from boats where human rights abuses may occur, creating a risk to the reputation of the industry.

The IFFO website contains an overview of ethical standards in the seafood industry and the concerns over human rights abuses http://www.iffo.net/industry-news/ethics-seafood-industry and a position statement on the reported abuses in Thailand http://www.iffo.net/position-paper/4-iffo%E2%80%99s-position-reported-abuse-human-rights.

The most recent position statement was a joint declaration signed by IFFO and others, at the Global Aquaculture Alliance conference in Ho Chi Minh City, Vietnam in November 2014. http://www.iffo.net/node/678

The debate currently centres on the fishing sector in Thailand, due to a long record of problems and a connection to western markets through the export of farmed shrimp. At the current date, IFFO lists the following members in Thailand:

  • Non-Producer Member – Charoen Pokphand (CP) Foods Public Company, a fish farming, feed and food processing company that, due to their size and presence in the shrimp export market, has been accused of using fishmeal from boats employing forced labour. CP have been one of the leading voices calling for better labour standards in the Thai industry.

A Thai Fishmeal Producers Association (TFPA) (http://www.thaifishmeal.com/index.php?lang=en) exists; contacts have been made but the Association is not currently an IFFO member. However, the TFPA is working with several other Thai industry bodies including the Thai Feedmill Association and the Royal Thai Government to resolve these problems.

IFFO will continue to engage with other stakeholders to resolve these abuses and protect the reputation of the fishmeal industry as a whole.

IFFO Responsible Supply (RS) Standard

The Responsible Supply standard was written to define environmental and food safety requirements for fishmeal and fish oil producers wishing to be independently certified. There was originally no component reflecting labour standards either in fishmeal processing factories or on board fishing vessels that supply raw material. However, clauses requiring compliance with national labour laws for the factories were introduced to the standard in 2014. These can be included in Improver Program criteria and can form a useful tool to provide assurance to the growing number of buyers concerned about this area.

The IFFO RS governing body are considering how to recognise the Seafish Responsible Fishing Scheme (RFS) standard (due to launch in 2015) which would provide useful additional assurance on standards on board fishing vessels. This standard, amongst other requirements, assesses the crew entitlement to work (permits), hours worked, on board living conditions, human rights (abuse, forced labour, discrimination) and pay. The RFS standard is based on the main International Labour Organisation reference document ILO 188 Convention on Work in Fishing (2007) – a recent YouTube video http://youtu.be/sqiapk3mlqw gives an overview of the RFS recommendations for crew and vessel operations.

IFFO is collaborating with other groups in Fishery Improvement Projects in South East Asia towards certification to IFFO RS. While not explicitly connected with labour standards, improved fishery management will improve income to fishermen and reduce the incentive for the use of forced labour.

Conclusions

While audits will be a useful tool, they have their drawbacks and a holistic approach is essential to avoid reliance on audits which are only partly effective. This requires the root causes to be addressed, including:

  • Clear jurisdictional boundaries e.g. requiring all fishing vessels to carry the flag of the territorial waters in which they operate.
  • Effective regulation and enforcement of labour standards
  • Improved fishery management to improve earnings to fishermen in the long term
  • Support structures for victims
  • Development of audit tools to improve accuracy, particularly at sea.

A holistic approach also avoids commercial supply chains being accused of being only concerned about their particular business and not the welfare of the wider community. However, it is a long term strategy and requires organisation and commitment to continue lobbying regulators who hold the key to long term solutions. The tariff barriers and other trade restrictions employed by e.g. the USA and EU are powerful incentives. The problems will only be reduced by structural change and cannot be achieved by the private sector acting alone.

Guidance to IFFO members

Labour and Human Rights abuses are clearly unacceptable both from a moral view and as a risk to reputation. IFFO have already condemned the reports of criminal abuses in the Thai fishing sector and are continuing to work with our partners to improve standards.

A group of retailers, seafood processors and fishmeal producers including CP Foods, Thai Union, Costco and Walmart have outlined a number of requests for Fishmeal producers. Although these were intended for fishmeal production in Thailand, it is recommended that IFFO producer members review their own systems and assess whether similar requirements are needed and are being met in their fisheries and that the traceability to demonstrate sourcing standards is in place. Guidance on appropriate labour standards is available within the ILO188 Convention on Work in Fishing but the key recommendations are summarised below.

The level of interest and concern over standards on board fishing vessels has been apparent at industry conferences and events over the last 6 months. It is likely that buyers of farmed fish will be seeking increased assurance that standards on fishing vessels are acceptable and requiring information from their supply chain.

IFFO members should also communicate to buyers the many positive examples of good working conditions and labour relations demonstrated in our industry.

Requirements for Fishing Vessels

Requirements for Fishmeal Producers

All employees have signed employment contracts

All employees have a legal right to work

All vessels are registered with local authorities and carry unique International Maritime Organisation numbers.

Plants are audited and approved against national labour laws.

All vessels are licenced for the gear used.

Only buy raw material covered by catch documentation.

Logbooks are maintained for catch, landing and any transhipment.

Provide catch documentation with the sale of fishmeal.

Vessels carry Vessel Monitoring Systems to track movements.

Are certified against the IFFO Responsible Supply standard.

Crew for each trip are listed and photographed when leaving and returning to port.

Maintain a list of all vessels supplying raw material, updating every 6 months.

All catch is covered by documentation including species, vessel, port of landing and date.

 

Further information

Additional information on social standards is available through international organisations including:

Please contact secretariat@iffo.net if you need any further assistance.