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Seafood Sector Toolset

Prevent and Address Forced Labor in Your Company’s Supply Chains
Due Diligence toolkit. The 12 tools are arranged in the shape of a circle, each numbered from 1 to 12. Establish Policies and Performance Standards (Tools 1 to 5). Assess, Address, and Monitor (Tools 6 to 11). Compliance Plan (Tool 12).

Introduction & Framing

The seafood sector is characterized by long, intricate supply chains extending to small, isolated aquafarms and large distant water vessels that may not return to port for years. With multiple layers of middlemen, and limited connectivity at sea, visibility to conditions for fishers is especially low. Fishers are often migrants, highly vulnerable to unethical recruitment, and have been known to be trapped at sea for months and even years.

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Tool 1: Supply Chain Due Diligence Process

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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.’

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Tool 2: Code of Conduct

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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.

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Tool 3: Performance Benchmarks

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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. The suggested benchmarks in this tools are aligned with relevant guidance from the International Labour Organization, particularly the Work in Fishing Convention (C188), which sets standards around issues such as health, safety, and medical care at sea as well as requirements for work agreements.

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Tool 4: Country-Level Review of Legal Protections Against Human Trafficking

This tool describes how companies can undertake risk assessments at the level of country of production, port state, country of labor supply and specific supplier. It also provides suggestions for external resources that can be consulted.

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Tool 5: Supplier Agreement

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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.

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Tool 6: Supply Chain Mapping and Risk Assessment

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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 6.1 Data Gathering and Risk Assessment in Seafood Supply Chains

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Tool 7: Criteria for Screening

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This tool lays out criteria for screening individual labor agents based on their ability to comply with all applicable legal requirements and Code of Conduct standards for ethical recruitment.

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Tool 8: Supplier Self-Assessment

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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.

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Tool 9: Monitoring Labor Agent Performance

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Once a labor agent is engaged, their performance must be monitored for ongoing compliance. This tool contains a set of criteria used for monitoring labor agents in supply chains.

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Tool 10: Conducting Worker Interviews

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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.

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Tool 11: Worker Engagement

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The ability for workers to gain awareness of and advocate for their rights, to discuss workplace issues of concern and interest, to have channels for individual and collective advocacy and to communicate grievances is essential to the prevention of trafficking in persons. It can also serve to provide companies with effective means for information exchange on workplace conditions and potential risk areas. In fact, workers themselves are often the best source of information regarding labor conditions.

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Tool 12: FAR Compliance Plan

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This tool is specifically intended for use by companies that need to demonstrate compliance with the requirements of the Federal Acquisition Regulation (FAR): Combating Trafficking in Persons and submit certification 52.222-56 set forward by 52.222-50(h) and 22.1703(c).

Dive deeper into forced labor case studies, compliance, and more in our Resource Library.