Supply Chain Transparency

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 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. This disclosure is made on behalf of both Chicken of the Sea International and Chicken of the Sea Frozen Foods, except where specifically noted.

INTERNAL ACCOUNTABILITY

We use the Supplier Code of Conduct developed and implemented by our parent company, Thai Union, to set expectations and requirements for suppliers. This Code of Conduct 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. The Code also provides protection for any individuals or groups that file a complaint or grievance, providing whistleblower protection and prevention of retaliation. Members of the procurement team work directly with suppliers to communicate the Code of Conduct and obtain written confirmation and acknowledgement of the Code when appropriate. Our Director of Sustainability collates this information and shares it with executives as part of ongoing internal sustainability reporting.

In 2015 and 2016, our main focus was to roll out the Code of Conduct to our primary raw materials, ingredients and packaging providers. Our intent is to continue to communicate and obtain signed acknowledgement of the Code from all directly contracted suppliers by 2020.

INTERNAL VERIFICATION

As part of our Supplier Code of Ethics, Chicken of the Sea requires its directly contracted 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. Any supplier who is later found to be in violation of those laws is subject to termination. In line with internationally-recognized best practices and the recommendations of labor and human rights experts, however, our preference is to engage with suppliers to implement corrective actions and achieve full compliance with laws, regulations and our Supplier Code of Conduct. Should suppliers be unwilling or unable to engage with us to our satisfaction, we reserve the right to terminate our relationship. Engaging a socially responsible supply chain is an important part of our strategy and values.

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. Our procurement team looks for labor and human rights policies and practices during onsite visits and reports back to the Director of Sustainability on these matters. Supply chain risk mapping and risk mitigation practices are continuously reviewed and further standards for supplier verification are under development.

THIRD-PARTY AUDITS AND VERIFICATION

In 2013, Chicken of the Sea International began a supplier auditing program to provide independent verification of vendor sustainability practices. This audit program evaluates supplier performance against international, national and local laws as well as our Supplier Code of Conduct, with a specific focus on labor and human rights, as well as environment, health and safety.

In 2014, the audit program shifted to a “Performance Improvement Program (PIP)” approach, that includes support and capacity building for suppliers in the 12 months after their initial audit. This approach provides labor and human rights guidance and tools for suppliers to more effectively address any corrective actions found in the initial audit, and provides Chicken of the Sea International with updates on remediation that are more useful than an “audit only” approach.

In 2015, Chicken of the Sea International met its goal to have 90 percent of its seafood supply chain audited by an independent third party on a rolling three-year basis.

Chicken of the Sea Frozen Foods does not employ third-party auditing of its own, but does ask suppliers to provide a recent copy of any social audits that have been conducted. Copies of these audits are kept by Chicken of the Sea Frozen Foods in a central location where the procurement team and executives can review them.

CERTIFICATION

We are committed to a supply chain where workers are safe, legally employed and empowered. At this time, there is no official certification to ensure compliance with all labor standards, particularly with respect to human trafficking. As detailed herein, we employ a variety of procedures designed to ensure that our direct supply chain is free of products sourced from any illegal activities. In order to limit labor abuses among second and third tier suppliers, all direct suppliers are expected to take proactive and reasonable measures to minimize the risk of slavery, human trafficking or other labor violations throughout their supply chain and eradicate such abuses in places that they are found to exist. Management of the full supply chain to ensure compliance with labor laws and standard is an ongoing pursuit.

TRAINING

In 2012, Chicken of the Sea 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 subtler indicators of trafficking or forced labor, and how to take appropriate actions necessary to mitigate the risk of slavery and human trafficking.
Our intent in 2017 is to renew that training for executives and procurement teams at both Chicken of the Sea International and Chicken of the Sea Frozen Foods.

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 in order to improve the entire product supply chain and reduce our overall impact on the environment and society.