External Resources

Seafood Compliance Tools

Creating Strong Policies in Seafood Supply Chains

Creating the right policies and procedures is the foundation of an effective management systems approach to combatting trafficking in your supply chain. Putting clear expectations in contracts and other agreements is essential as the first step in changing behavior throughout your supply chain and models expectations for how suppliers interact with their own suppliers and labor recruiters.

Tool 1: Sample Code of Conduct Provisions for Seafood Supply Chains

A supply chain Code of Conduct establishes basic performance expectations for subcontractors, suppliers and agents. It is important that your company sourcing policy or Code of Conduct explicitly prohibits human trafficking and sets out protections for workers.

Tool 1A: Benchmarks of Good Practice in Recruitment and Employment in Seafood Supply Chains

Benchmarks are vital to demonstrate how anti-trafficking policies should be implemented. Clear performance indicators enable companies and others to evaluate whether genuine changes are made in the labor and recruitment practices of suppliers.

Tool 2: Sample Social Responsibility Agreement for Seafood Suppliers

A formal record of commitment to anti-trafficking requirements from all suppliers throughout the entire supply chain is important to establish accountability expectations for all parties.

Screening and Assessment in the Seafood Supply Chain

Screening of suppliers and assessing their performance are tools for determining robust responses to right any wrongs in business practices that are facilitating human trafficking.

Tool 3: Mapping the Seafood Supply Chain

By mapping their supply chain, seafood companies can identify their suppliers at all levels of production, including inputs of raw materials. The supply chain for each product will be unique, so supply chain mapping should be conducted on a product by product basis.

Tool 4: Risk Assessment in the Seafood Supply Chain

Risk assessments in the seafood sector must take into account conditions in multiple levels of the supply chain and in relation to the risks association with practices of coast state, flag state, fishery, port state, processing plant state, and aquaculture state.

Tool 5: Criteria for Screening and Evaluating Labor Recruitment Candidates

When direct recruitment is not possible, companies must exercise careful due diligence in the screening and selection of labor recruiters to minimize the risk of human trafficking as a result of fraudulent or misleading recruitment practices.

Tool 6: Sample Seafood Supplier/Subcontractor Self-Assessment

An important part of a systems approach to preventing human trafficking is to assess current and prospective suppliers for potential risks, including the strengths and weaknesses of anti-trafficking systems in place.

Tool 7: Monitoring the Performance of Labor Recruiters in the Seafood Supply Chain

Careful due diligence of labor recruiters must include regular independent monitoring of actual performance against legal and Code of Conduct requirements.

Tool 8: Conducting Migrant Worker Interviews and Potential Red Flags

All compliance efforts must put worker input at their core, including those related to monitoring the behavior of suppliers and labor recruiters. Careful attention is warranted in creating systems for gathering information from migrant workers through interviews and other mechanisms.

Compliance Management in Seafood Supply Chains

It’s important to have a larger vision of how to create and maintain a continual improvement system to fight trafficking in your supply chain, based on systematic, on-going risk identification, solution implementation, and performance monitoring.

Tool 9: Sample Supply Chain Assurance Program in Seafood Supply Chains

The underlying principles of a systems approach to combatting trafficking is based on a fundamental systems approach to risk management, known as ‘Identify, Evaluate, Control and Monitor.’

Tool 10: Seafood Sector Compliance Plan Template

This tool is intended for use specifically by companies that need to demonstrate compliance with the Combating Trafficking in Persons requirements of the Federal Acquisition Regulation (FAR) and submit certifications under 52.222-50(h) and 22.1703(c).--