Supply Chain Traceability

The California Transparency in Supply Chains Act of 2010 – S.B. 657
The California Transparency in Supply Chains Act (the “TSCA”) require certain companies in California to publicly disclose their efforts to eradicate slavery and human trafficking from their direct supply chain for goods offered for sale.

Chicken of the Sea International stresses and supports ethical procurement in its entire supply chain. This applies not only to the raw materials and fisheries it sources from, but very importantly, to the entire supply chain process including the manufacturing of its products. Below, we describe some of the actions we have taken to ensure that workers in our supply chain are freely employed and assured their basic rights.

Supplier Standards
Our Supplier Code of Ethics includes provisions on labor and human rights, including specific reference to each worker’s right to freely chosen employment. We strictly prohibit forced, bonded, indentured, or involuntary prison labor. Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice. We prohibit any use of slavery or human trafficking in our supply chain, and are required to take reasonable precautions to ensure that its own suppliers do not engage in these practices.

As part of our Supplier Code of Ethics, Chicken of the Sea requires its direct suppliers to ensure that the materials they use in the products they produce for us comply with all applicable laws on slavery and human trafficking. While there is currently no official “slavery-free” certification – and indeed it may be technically impossible to guarantee that second and third tier suppliers are in total compliance – suppliers are expected to take reasonable and proactive measures to minimize risk of slavery and human trafficking throughout their supply chain and eradicate it in places that it is found to exist.

Vendor Evaluation
We have a robust vendor evaluation process that applies to all suppliers that provide inputs to our product and its packaging. The evaluation looks at issues of quality, capacity, compliance, and good business practices. While we do not specifically have criteria to evaluate new vendors on labor and human rights issues, this is something we are investigating for the future.

Audits and Verification
Chicken of the Sea currently works with independent auditors, who make announced and unannounced visits at supplier facilities that provide material inputs to our products. To date, these audits have focused mainly on quality, compliance, and health and safety, and good business practices. In 2013, we engaged auditors with specific labor and human rights experience to audit several of our key supplier facilities to investigate areas of environmental responsibility, labor practices, and human rights – including slavery and human trafficking.

These results have helped us identify the biggest risks and opportunities for improvement across our supplier base. In 2014, we will be investigating the best way to roll out the auditing process to additional suppliers.

Employee Training
Since 2012, Chicken of the Sea has required all of its management, and any employees who are responsible for supply chain management, to undertake an online training course on Human Trafficking and Slavery Risks, designed specifically for supply chain professionals. The training focuses on presenting real-world scenarios to help participants identify both the obvious and more subtle indicators of trafficking or forced labor, and how to take appropriate actions necessary to mitigate the risk of slavery and human trafficking

Continuous Improvement

Chicken of the Sea is committed to work closely with its suppliers and others in the industry to help raise awareness and also take appropriate steps to eradicate slavery and human trafficking. We are constantly seeking to improve our sourcing practices and are currently undertaking major sustainability projects with independent consultants in order to improve the entire product supply chain and reduce our overall impact on the environment and society.