Target’s Vice President of Corporate Responsibility announced a new Sustainable Seafood Policy that commits the company to collaborate with companies and NGOs to promote ethical working conditions and support for public policy that will ensure implementation of core labor standards. CBIS has been calling for worker protections for two years and was pleased the company took these steps in November 2018.
In a call with Target in February 2017, CBIS encouraged the company to release details of audits of its Thai seafood suppliers in light of egregious forced labor violations over the past 3 years, and share information about its participation in The Seafood Task Force, an influential, diverse coalition tackling human rights in Thailand, which Target joined at CBIS’ urging.
In October 2016, CBIS participated in a call with Target regarding Target’s new Responsible Sourcing and Sustainable Design 2020 goals. The company shared its key areas of focus: improving worker well-being, achieving net-positive manufacturing, and deriving key raw materials from ethical and sustainable sources. We have asked for additional detail on each of these areas of focus. The company made clear that it is committed to collaboration and transparency, including to the Seafood Supply Chain Task Force, a key area of interest for CBIS given our ongoing concerns regarding slave labor in the seafood supply chain in Thailand. The company is making headway to make sure that workers do not pay a fee for jobs, as is the case with unscrupulous labor brokers. In related news, we were pleased that Target is now having its fresh and frozen shrimp certified by Marine Bay Aquarium Project, and the company is also looking to certify tuna. The company also shared its recently published factory matrix that outlines the nearly 500 factories, by country, it is using to produce its goods. Shareholders welcome transparency of this kind since it can help to identify leading and lagging factories in terms of worker safety, environmental performance and human rights standards.
We are pleased to announce that Target joined the Shrimp Sustainable Supply Chain Task Force in September 2016, a longtime ask of CBIS. Key goals of the Task Force include: Creating a standard code of conduct model for Thai ports, brokers and vessels; conducting audits of vessels; and tracking and tracing systems from vessel to feed mill. The multi-stakeholder alliance includes European and American retailers, their suppliers, NGOs and the major Thai shrimp processors and feed companies. Members include Costco, Walmart, World Wildlife Fund and our own Thai Union. We believe Target’s advances can help to reduce reputational risk, protect at-risk workers, and ultimately make its seafood supply chain more resilient. We continue to urge Target to publicly report on its progress and to join additional programs that help migrant workers choose good employers, find safe work and living conditions, and avoid exploitative labor brokers. Target mentioned that it is now looking to take additional steps to trace its tuna supply chain.
In early 2016, Target hired a labor and human rights experts to be onsite in Bangkok to assess the seafood supply chain in Thailand. This is one of many steps Target has detailed to address human trafficking in the seafood supply chain in Thailand, including furthering knowledge of abuses in the shrimp supply chain through in-country meetings with the Thai government, the International Labor Organization, and key vendors; working with other retailers to communicate the need to address this issue with the Thai government; and implementing a process to trace the supply chain from ocean to table. Target audits its seafood processing facilities but does not currently make audit findings public.
After an investigation in January 2016 revealed that poor migrant workers and children were sold to factories in Thailand and forced to peel shrimp that ended up in global supply chains (Slave-peeled shrimp tied to major retailers, restaurants — 12/14/2015) CBIS contacted Target. Target is aware of the investigation and the need for even more productive multi-sector collaboration on this critical issue. As part of its traceability commitment, Target has been vigilant in evaluating its own supply from Southeast Asia and is working with a wide range of stakeholders (industry, NGOs, government, etc.) to address human rights violations. Target is currently assessing the opportunity to engage more formally with the Shrimp Sustainable Supply Chain Task Force – a group of retailers, manufacturers, government, and human rights organizations working to create procedures for ports, and to trace the seafood supply chain from vessel to feed mill – and its collaborative plan to achieve more oversight.
In September 2017, CBIS met with Coca-Cola’s director of global workplace rights and a small working group of ICCR members to strategize around best practices in respecting human rights in the company’s operations and supply chains. This intelligence can help us assess human trafficking policies at other major companies that are sourcing commodities around the globe.
In the second quarter of 2014, Coca-Cola published its Human and Workplace Rights Issue Guidance for its suppliers and bottlers that seeks to protect human rights in its supply chain. Although CBIS’ focus with Coca-Cola is on water stewardship, the guidance document is an important step for a major corporation in recognizing worker rights and establishing clear expectations for its partner companies. A particular focus of the guidance is on the ethical recruitment of workers including no worker-paid recruitment fees, employer-paid transportation to host countries, and full payment of earnings to workers (no automatic debiting of payments to cover expenses).
CBIS has been pressing Campbell’s Soup for two years to address the chain of indebtedness and worker dignity in their supply chain. In June, Campbell Soup released a Code of Conduct for suppliers that addresses labor trafficking:
- Forbids suppliers from charging workers fees or retaining passports, so workers have freedom of movement.
- Requires suppliers to provide workers with itemized wage statements, in a language understood by the worker.
- Calls for audits of vendors, subcontractors and independent contractors.
When we next meet with the company, we plan to discuss the rollout of the Code to suppliers, to better understand implementation, effectiveness and adherence.
In May 2016, CBIS attended the Nucor annual shareholders’ meeting to question executives on initiatives to prevent slave labor in the company’s Brazilian supply chain, and its disclosure to shareholders of its progress.
In the fourth quarter of 2014, Nucor issued an update of steps it is taking to combat human trafficking in Brazil. In 2007, investigations revealed the prevalence of forced labor and armed surveillance by charcoal producers in Northern Brazil. Because charcoal is an input in Nucor’s steel production, the company has taken steps to eradicate slave labor from its supply chain. A new update from Nucor reported that between May 2010 and June 2014, 822 random, unannounced audits of charcoal facilities supplying its member pig iron manufacturers were conducted, covering ~25,000 laborers, and the ICC found no instances of forced labor or armed surveillance by employers or hired guards.
In January 2017, CBIS met with management to discuss human trafficking initiatives and establish a rapport with the company. In response to a shareholder proposal filed with United Continental, the company has substantially strengthened its human rights policy. It applies to all 85,000 employees of which 23,000 are flight attendants. CBIS and investors will continue to provide input and resources toward effective implementation of the human rights policy that includes further training to monitor and act on human trafficking activity. Specifically, we are encouraging United to train its flight attendants to identify signs of human trafficking and to disclose the effectiveness of such programs, continue to improve its human rights policies to include stricter requirements on forced labor and child exploitation, and to sign The Code of Conduct for the Protection of Children from Sexual Exploitation.
In 2016, CBIS began to engage United on the issue of human trafficking in the airline sector. Airport personnel are in a unique position to discern possible trafficking situations. As the fourth largest airline in the world, United has the potential to play a vital role in identifying and assisting trafficking victims. While other companies are taking action, United’s reporting does not indicate if the company has developed effective internal controls. United published a human rights policy statement last year that repudiates forced labor, child labor and sexual exploitation and a commitment to cooperate with law enforcement. CBIS will work with United to ensure the company is demonstrating implementation by training flight attendants, developing programs with law enforcement, raising awareness and reporting annually on progress and challenges.
In 2016, CBIS began to engage Thai Union on the issue of human trafficking in the seafood section. Human trafficking abuses in the shrimp supply chain in Thailand have been well documented. As the largest seafood company globally by sales, Thai Union has the ability to have far-reaching impacts in the sector to improve labor standards. CBIS will work with Thai Union to ensure the company is assessing its immediate and extended seafood supply chain for human trafficking.
Thai Union came to CBIS’ office in the third quarter of 2016 to outline its progress to eliminate slave labor from the seafood supply chain in Thailand. The company has taken a number of steps since widely circulated investigations uncovered abusive working conditions at a number of Thai Union suppliers. This external attention has pushed Thai Union to make significant changes in its business operations, including hiring workers directly rather than rely on labor brokers, some of whom charge workers exorbitant fees, promise jobs that never materialize, confiscate identity documents so workers are unable to leave, and often withhold pay. Thai Union is working with a variety of NGOs to provide grievance mechanisms for workers in factories and at sea and is now auditing its shrimp supply chain from vessels to fishmeal plants and farms to ensure suppliers comply with its code against forced labor. Violators of human rights stipulations are immediately terminated. Thai Union is taking an active role in the Shrimp Sustainable Supply Chain Task Force (which actually covers the whole of seafood, in spite of the name). In addition to corporate representation, government representatives are included and NGOs act as an external advisory body to provide oversight. The Task Force is creating a code of conduct, auditable standards, and a model for monitoring that they will all agree to adhere to. The company also hired a Director of Sustainability who has been given free reign by senior management to implement changes. The company is now one of the leaders in the industry. Since much of its program is in its infancy, CBIS will follow the company’s implementation closely.