Follow six steps to social responsibility

Following the six steps to social responsibility.

With the myriad of guidance notes, reporting templates and resources available the questions is – where do you start?

Start with TESS. TESS has brought all of these resources together, in one place, to signpost seafood businesses to external websites and sources of information that can help to manage supply chains and inform decision making. If a risk is identified in a supply chain as part of this process use one of the tools or approaches highlighted in TESS to help support your decision making.

The UN Guiding Principles on Business and Human Rights are viewed as the authoritative global reference on business and human rights. They provide a strategic framework for businesses to use in order to tackle modern slavery in their supply chains.

Stronger Together has built on the UN Guiding principles and developed a toolkit which provides a robust six-step approach to guide businesses through a process which will help them address social responsibility challenges in seafood supply chains.

TESS has adopted this Stronger Together six-step approach, which is effectively a straightforward business improvement cycle. Taken on a step by step basis TESS has brought together the many and varied resources that are available to support seafood industry businesses and aligned them to a step in this cycle.

The Six Steps

STEP 1- COMMIT. Make a public commitment to respect human rights

Step 1 in this business improvement cycle is about making a public commitment to respect human rights, both within the business and within your supply chain.

The first key issue is the legal requirements for companies to report on the steps they are taking to identify slavery in their supply chains, such as the UK Modern Slavery Act (2015) UK, the California Transparency in Supply Chains Act (2010) USA and the EU Directive 2014/95/EU on disclosure of non-financial and diversity information. These laws around transparency in supply chains are rapidly developing but they represent a minimum requirement. Companies need to recognise and accept that addressing the issues surrounding modern slavery in seafood supply chains is no longer an option and to ignore this key area invites the potential for reputational risk and possibly legal sanction.

Action to take

The first step is assigning responsibility.

The starting point is to assign responsibility to a Board Director (or equivalent) and to senior functional managers. It is necessary to consider business operations, who is affected and what difference the business can make. It is important to have a Code of Conduct in place stating a commitment to securing decent working conditions, which should cover direct employees, suppliers, subcontractors and other business partners. This should encompass what commitments can be made in purchasing practices.

This approach is based on the Stronger Together Toolkit for tackling modern slavery in global supply chains (Step 1. Pages 15 – 18). Stronger Together is a multi-stakeholder initiative aiming to reduce human trafficking, forced labour and other hidden third party exploitation of workers. Stronger Together provides guidance, resources and a network for employers, labour providers, workers and their representatives to work together to reduce exploitation. Their toolkit for tackling modern slavery in global supply chains provides guidance and good practice for responsible businesses to develop a robust strategy to prevent, uncover and report modern slavery. This outlines a strategic framework of six practical steps for businesses to take. Step 1 is for businesses to commit to tackling modern slavery and assign responsibility internally.

Key considerations and resources that can help

Internationally recognised operational guidelines:

It is important to know your legal risks and learn from internationally recognised operational guidelines. An internationally or nationally recognised Code of Labour Practice or a Code of Conduct provides a framework under which countries or the supply chain can demonstrate a commitment to ethically and socially responsible working practices.

To support this TESS signposts you to Regulations, Codes of Conduct, Codes of Labour Practice, Indicators of forced labour, Indicators of trafficking in human beings, International Declarations, Conventions, Directives and Guidelines.

UK regulatory requirements

For UK-based seafood business it is imperative that you are aware of UK specific national regulatory reporting requirements and seafood-specific Codes of Practice that apply in the UK, so that you know your legal risks and reporting responsibilities.

As an example some businesses will have reporting requirements under the Modern Slavery Act 2015. The Modern Slavery Act 2015 came into force in the UK in March 2015. The Act aims to prevent all forms of labour exploitation and increase transparency of labour practices in supply chains. S.54 of the Act requires organisations to report on the processes and due diligence taken to ensure that their supply chains are slavery free. This ‘Transparency in Supply Chains’ clause requires organisations with a worldwide turnover of £36m or more and that have a ‘demonstrable’ presence in the UK to produce and publish a slavery and human trafficking statement each financial year ending on or after 31 March 2016. The statement is a summary of the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any part of its business or its supply chains. A statement needs to be published regardless of whether any steps have been taken or not. While a disclosure stating that the company does nothing to prevent such practices is legally compliant under the law, such a disclosure can leave a company susceptible to negative publicity from customers and human rights organisations. Under the Modern Slavery Act large companies must report on the actions they are taking to eradicate slavery and human trafficking in their supply chains. Under the Non-Financial Reporting disclosure (EU NFR), which applies from January 2017, large Public Interest Entities with more than 500 employees are also required to report on corporate due diligence processes on all human rights issues, not just trafficking or forced labour.

To support this TESS signposts you to Regulations and seafood-specific Codes of Practice that apply in the UK.

Committing to a social responsibility - helpful resources

STEP 2- ASSESS. Understand modern slavery risks in your supply chain

Step 2 in this business improvement cycle is to assess the modern slavery risks in your supply chain.

In the seafood industry, supply chains at land and sea are often complex, with multiple layers of activity. Concerns about labour and human rights issues, can affect many countries and a wide range of products, and the issues challenge the reputation of the seafood sector. It is important seafood businesses identify the risk itself and where it can be found and then, if a risk has been identified, look at how to address it.

Action to take

Businesses should identify where the greatest risks of slavery occur in their operational activities and supply chain. This involves mapping the supply chain to identify where the risks of slavery and human trafficking are greatest, but also where there is a lack of information about a business’s direct and indirect suppliers. This is a detailed process that will require gathering information about the business, the various tiers of the supply chain, the countries and sectors operated in and the risks associated with the operating environment. Risk factors to consider are: inherent factors such as country, industry, legislation, labour inspectorate; worker types; the supplier relationship considering length and the level of trust; supplier capability; and the presence and influence of trade unions and civil society. In assessing risk there is also a need to identify the business priorities to determine what factors mitigate those risks, what are the commercial priorities and what are the labour rights priorities?

This approach is based on the Stronger Together Toolkit for tackling modern slavery in global supply chains (Step 2. Pages 19 – 20). Stronger Together is a multi-stakeholder initiative aiming to reduce human trafficking, forced labour and other hidden third party exploitation of workers. Stronger Together provides guidance, resources and a network for employers, labour providers, workers and their representatives to work together to reduce exploitation. Their toolkit for tackling modern slavery in global supply chains provides guidance and good practice for responsible businesses to develop a robust strategy to prevent, uncover and report modern slavery. This outlines a strategic framework of six practical steps for businesses to take. Step 2 is for businesses to assess the risk of modern slavery in their supply chain.

Key considerations and resources that can help

Identifying risk

Seafood supply chains are global so it is vitally important to identify the risks and to understand the issues and where they are present at fishery and country level. There are resources that can help with this.

One example is the study commissioned by Seafish in March 2015 to assess the ethical issues impacting on seafood species landed into, and imported to the UK. This resulted in a comprehensive description and analysis of ethical concerns pervading seafood production and processing activities in a wide range of countries or regions that supply the UK seafood market, as well as domestic landings; wild caught and farmed species; different sectors of the supply chain; and all aspects of unethical practice.

To support this TESS signposts you to various publically available risk assessment tools that assess the probability and the severity of human rights abuses in the seafood sector.

Resources that monitor and document human rights issues

In addition there are a number of publically available resources that monitor and document human rights issues with a few key reports published on an annual basis. In addition: technical agencies; the international organisations with a direct or indirect mandate on this subject (and sometimes with field projects addressing the concerns); the various NGOs; the seafood industry and companies at the national and international levels; and also different government agencies (including foreign affairs, labour and social affairs, the environment and fisheries, and criminal justice agencies) all have websites and produce reports on this issue.  Some may be considered generic or awareness raising documents. Others are clearly designed as campaigning documents, often containing specific and quite detailed recommendations to governments, the seafood industry and other stakeholders.

For more general information look at the recommended reading section on the ‘Why social responsibility matters’ page’. In addition many of the organisations with records in TESS have published reports and the key media reports and published articles have been collated into one record.

To support this TESS signposts you to the main reports that are published on an annual basis which monitor human rights abuses and include the seafood sector. In addition recent media reports on the issue have also been collated for reference.

Assessing risks in your supply chain - helpful resources

STEP 3- IMPLEMENT. Collaborate and take action to deal with identified risks

Step 3 in this business improvement cycle is to take action to deal with identified risks.

Once a business has taken steps to assess their supply chain, to understand their risks and have assessed those risks businesses should develop an action plan to either reduce the risks of forced labour or to tackle cases of forced labour where they are identified.

Action to take

Immediate action can be taken at company, site-level and stakeholder level to mitigate or reduce risks where possible. At a company-level it is important to understand what supply chain knowledge is available and where transparent supplier relationships exist to fill any information gaps about supply chain and working practices. At site-level finding out where ethical audits have already taken place is necessary to see what actions are outstanding, as well as working with suppliers to address issues. At a stakeholder-level there may be opportunities for collaboration in the supply chain. In addition it would be useful to gain an understanding of who are the key stakeholders in any identified high risk areas, such as NGOs, trade unions, customers, other suppliers, government etc

This approach is based on the Stronger Together Toolkit for tackling modern slavery in global supply chains (Step 3. Pages 21 – 22). Stronger Together is a multi-stakeholder initiative aiming to reduce human trafficking, forced labour and other hidden third party exploitation of workers. Stronger Together provides guidance, resources and a network for employers, labour providers, workers and their representatives to work together to reduce exploitation. Their toolkit for tackling modern slavery in global supply chains provides guidance and good practice for responsible businesses to develop a robust strategy to prevent, uncover and report modern slavery. This outlines a strategic framework of six practical steps for businesses to take. Step 3 is for businesses to act to tackle slavery in their supply chain.

Key considerations and resource that can help

Consider third-party accreditation/certification schemes

Gaining third-party accreditation or certification at site or farm-level is one option to consider. Certification and labelling initiatives are progressively moving from environmental to social considerations but there is currently no global labour standard to improve conditions throughout the seafood supply chain. The seafood industry lacks a voluntary code of conduct on social dimensions but this is still a growing area. A number of certification and labelling schemes already have considerable coverage of social issues in their codes, while others have embarked on efforts to revise their earlier codes accordingly. By engaging with standard setters and certification entities the industry can help to ensure that seafood standards that include a social component are robust. These are auditable seafood standards and the guidance needs to be translated into user friendly checklists for auditors. By sourcing seafood that is accredited to a standard that has a social component there is some reassurance that the seafood you are purchasing has been independently verified with regards to social issues.

To support this TESS signposts you to the various seafood standards/certification schemes, highlighting those which have a social component.

Collaborative initiatives

It is important to be aware of the many collaborations that have developed between government, trade unions, industry bodies, seafood businesses and civil society groups when addressing human rights issues. This will help to minimise gaps. Collaborative, industry-wide, pre-competitive initiatives can help to identify problems and share the cost of developing and implementing solutions. These provide opportunities to share knowledge and insight, learn from others, build your own knowledge, share best practice, and network with others in the same situation.

There are a number of multi-stakeholder initiatives that are seafood-specific. The Seafish Seafood Ethics Common Language Group (Seafood Ethics CLG) convenes seafood stakeholders including major supermarket chains, smaller retailers, processors and suppliers throughout the whole supply chain, with government, NGOs, development organisations and charities in a ‘safe’ environment for discussion and debate. The industry needs to collaborate to consolidate messages and activities if ethical issues across the supply chain are to be addressed.

An on-the-ground regional example is the Seafood Task Force which has brought together a group of seafood processors, feed producers, buyers, retailers, government representatives and NGOs to address issues surrounding labour and illegal fishing in seafood supply chains currently focusing on the seas around Thailand.

To support this TESS signposts you to a number of multi-stakeholder initiatives that are addressing these issues in the seafood supply chain and offer opportunities for engagement.

Taking action to address risks - helpful resources

STEP 4 - REMEDY. Provide a solution for victims of slavery

Step 4 in this business improvement cycle is to look for, and provide solutions, for victims of slavery.

This addresses the issue of what you should do if you find problems in the supply chain and the levels of remedy that are available.

Action to take

Forced labour and human trafficking are crimes under international law and should be dealt with accordingly. This means at state level the apprpriate action needs to be taken whether this is administrative, legislative or by other remedy. At an operational level businesses should have in place grievance mechansms to provide remedy. In addition regional and international human rights organisations, as well as industry or multi-stakeholder collaborative options, can provide support and expertise in assisting victims of forced labour.

This approach is based on the Stronger Together Toolkit for tackling modern slavery in global supply chains (Step 4. Pages 23 – 24). Stronger Together is a multi-stakeholder initiative aiming to reduce human trafficking, forced labour and other hidden third party exploitation of workers. Stronger Together provides guidance, resources and a network for employers, labour providers, workers and their representatives to work together to reduce exploitation. Their toolkit for tackling modern slavery in global supply chains provides guidance and good practice for responsible businesses to develop a robust strategy to prevent, uncover and report modern slavery. This outlines a strategic framework of six practical steps for businesses to take. Step 4 is for businesses to provide a remedy for modern slavery victims.

Key considerations and resource that can help

Globally there are many initiatives (mostly voluntary) that seek to improve labour standards and support victims. Recognising the human rights campaigns that are aligning and supporting workers’ rights highlights the issues, provides a common understanding of the situation and social responsibility landscape, and provides the pressure to better support workers’ rights. By working with local workers organisations businesses can ensure that workers can access their rights with freedom and without discrimination.

To support this TESS signposts you to appropriate authorities, organisations, foundations and charities who are working to support the industry, and improve governance, safety and welfare within the global seafood industry.

Helping victims of slavery - helpful resources

STEP 5 - MONITOR. Support/guidance to help monitor progress in tackling social responsibility issues

Step 5 in this business improvement cycle is using the available support and guidance to help monitor progress in tackling social responsibility issues.

It is important that businesses monitor their progress towards agreed improvement measures by incorporating regular reporting and tracking efforts, using tools and indicators that are already used to manage suppliers e.g. complaints and feedback systems.

Action to take

From a pratical perspective establishing regular reporting mechanisms involves consideration of some key parameters: Why is the monitoring taking place? What will be monitored? How will it be monitored? Who will participate and what will be their level of participation? How often will it be monitored? Who is responsible for the monitoring? How will the data be used? How will your business respond to the data found? How will you fund the monitoring? Examples of reporting and monitoring include: having a dedicated sustainability website to report on progress; reporting publically on the percentage of audit non-conformities related to slavery and child labour; reporting internally on labour agency audit performance to senior management; and tracking audit non-conformance and trends and reports within the organisation on key issues by country.

This approach is based on the Stronger Together Toolkit for tackling modern slavery in global supply chains (Step 5. Page 25). Stronger Together is a multi-stakeholder initiative aiming to reduce human trafficking, forced labour and other hidden third party exploitation of workers. Stronger Together provides guidance, resources and a network for employers, labour providers, workers and their representatives to work together to reduce exploitation. Their toolkit for tackling modern slavery in global supply chains provides guidance and good practice for responsible businesses to develop a robust strategy to prevent, uncover and report modern slavery. This outlines a strategic framework of six practical steps for businesses to take. Step 5 is for businesses to monitor progress in tackling slavery.

Key considerations and resource that can help

There are a number of freely available resources which can help seafood businesses through the process of documenting human rights risks and provide guidance on good practice supply chain management. Posing the right questions about the origins and inputs of seafood suppliers builds accountability and coverage for this issue. Doing this systematically will reduce risks geometrically and show due diligence to investors, suppliers, regulators and customers.

To support this TESS signposts you to supply chain support and monitoring tools, as well as guidelines and guidance documents to support best practice from sea or farm to plate. There are a number of organisations that offer practical business support to help manage socially responsible business practices. There are also business level tools for risk management, auditing and monitoring to help identify issues and implement solutions at business and supplier level.

Tracking improvements in your supply chain - helpful resources

STEP 6 - COMMUNICATE. Tell people what you've done

Step 6 in this business improvement cycle is to share with stakeholders the steps that have been taken.

Businesses should identify what information to share and how to share with internal and external stakeholders.

Action to take

Open communication with stakeholders about the progress made and the challenges faced is a positive step forward, and it should be kept up-to-date and focus on actual activities and their impact. It is also important to be open about the challenges faced and the efforts to address the challenges. How this is communicated will depend on the size of the business and the type and amount of information to be communicated.

In the UK the Transparency in Supply Clause within the Modern Slavery Act 2015 requires organisations with a worldwide turnover of £36m or more and that have a ‘demonstrable’ presence in the UK to produce and publish a slavery and human trafficking statement each financial year. This provides a framework for such open communication.

This approach is based on the Stronger Together Toolkit for tackling modern slavery in global supply chains (Step 6. Page 26). Stronger Together is a multi-stakeholder initiative aiming to reduce human trafficking, forced labour and other hidden third party exploitation of workers. Stronger Together provides guidance, resources and a network for employers, labour providers, workers and their representatives to work together to reduce exploitation. Their toolkit for tackling modern slavery in global supply chains provides guidance and good practice for responsible businesses to develop a robust strategy to prevent, uncover and report modern slavery. This outlines a strategic framework of six practical steps for businesses to take. Step 6 is for businesses to communicate progress progress in tackling slavery.

Key considerations and resource that can help

It is important to note that these Modern Slavery statements, which have to be evident on the home page of a website, will be examined, ranked and scored by clients, customers, prospective clients, investors and NGOs. Companies will be rated against legal compliance, length and degree to which they publically disclose policies, standards and management approaches to mitigating forced labour in their supply chains and in accordance with the UN Guiding Principles. There is published guidance on writing a Modern Slavery statement to help in this process

To support this TESS signposts you resources that can help businesses in the UK to draft their Modern Slavery statements, as well as the equivalent in the United States. There are also examples of other methods of communicating on this issue and some good practice examples.

Reporting your progress - helpful resources

Further info

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