Canned Tuna Brands - Questions on Human Rights in Pacific Tuna Fishing Operations and Supply Chains (2018/19)
*The term ‘modern slavery’ used in this survey is taken to include forced labour, slavery, human trafficking, servitude, bonded and child labour.
Name of company: _____________
Headquarters address: _____________
Canned tuna brands: _____________
Human Rights Policy
1. Has your company made a public commitment to respect human rights? If so, please provide a link.
2. If yes, does the company’s commitment address modern slavery* and does it apply throughout your supply chains? Please provide details.
3. Does the company have a responsible sourcing or supplier code of conduct that prohibits modern slavery? Please provide details.
Human Rights Due Diligence Process
4. Has your company mapped its tuna supply chains, in whole or part?
5. Does the company source tuna from the Pacific region?
6. Does your company have a human rights due diligence policy, process or procedure to identify, assess and manage human rights risks (actual or potential), including modern slavery, in its operations (and those of its subsidiaries) and supply chains?
If so, please provide details and describe the human rights due diligence process. Key steps include: (i) identifying and assessing human rights impacts; (ii) integrating and acting on findings; (iii) tracking the effectiveness of the company’s response; and (iv) communicating externally about how the company is addressing its human rights impacts.
7. Has the company taken practical action to ensure that modern slavery does not occur in the company’s (or its subsidiaries’) operations and supply chains for tuna procurement from the Pacific? If so, please describe.
Examples might include:
(i) training staff and management, workers, suppliers or business partners about rights, risks, responsibilities and remediation;
(ii) engaging with NGOs, fishers/ their representatives (including unions) and policy-makers;
(iii) cascading contractual clauses in supply agreements;
(iv) digital traceability of fish (across entire supply chain, or part only);
(v) prohibition on recruitment fees;
(vi) protective measuresto protect against exploitation of migrant fishers;
(vii) prohibition on sourcing from suppliers that transship at sea, or use flags of convenience;
(viii) ensuring freedom of association and collective bargaining by fishers/ their representatives (including unions);
(ix) oversight of recruitment or labour hire entities; and
(x) independent supply chain auditing.
Please provide details.
8. If the company has taken steps to identify and address human rights risks, how does it (a) prioritise which risks to address first; and (b) assess and track the effectiveness of its actions and reponse?
9. Per the UN Guiding Principles on Business and Human Rights, does your company have a grievance/ complaints mechanism through which workers, including fishers in your supply chains, can raise concerns about human rights? If so, can they access this in their own language and in a way that allows grievances, or concerns, to be reported safely, in confidence and without intimidation? Have any human rights concerns connected with the Pacific tuna sector been reported via the company’s complaints mechanism? Please provide details.
10. Do you have a corrective or remediation plan if instances of modern slavery are identified in your operations, or supply chains? Can you describe it?
11. How many instances of modern slavery has your company identified in 2018 in its own operations (including subsidiaries) or in its supply chains that relate to tuna procurement from the Pacific? Do you know where they occurred and can you describe them? How did the company respond to address the issue(s)?
12. Does the company communicate, or report, externally on steps taken to address modern slavery? If yes, please provide details.
13. Has your company encountered obstacles or challenges in implementing its human rights commitments, taking practical action against modern slavery in tuna supply chains and/or in relation to any of the areas mentioned above? If so, please explain and provide details of any strategies to overcome them.
14. Does the company participate in any regional, or sectoral, multi-stakeholder initiatives that address modern slavery in fishing, eg:
(a) Seafood Task Force;
(b) BaIi Process Government and Business Forum;
(c) Tuna 2020 Traceability Declaration; and
If yes, please provide details.
15. Please provide any other information about your company’s policies and practices on human rights that may be relevant.
Further information and guidance: