Fish

• Seafood supply chains are highly complex with multiple levels of middlemen and processing. Varying procurement practices in downstream nodes add to this complexity. Traceability systems in the seafood sector should aim to maintain integrity through multiple points of transformation and aggregation; traceability approaches that track product at the lot level might be appropriate in this context.
• Many seafood supply chains include a large number of small and artisanal fishers who often have low administrative and technological capacity. Therefore, traceability systems should be flexible, allow for interoperability, and maintain feasibility in contexts where recordkeeping is paper-based rather than digitized.
• Fishing activities conducted at sea are unique in that the worksite is mobile, creating visibility challenges. Satellite technology can help provide insight on the geospatial location of vessels over time; however, these systems in isolation do not provide insight on working conditions aboard the vessel.
• Forced labor and child labor exist in multiple nodes of seafood supply chains across multiple geographies, including in the catching/harvesting, processing, packing, transport, and retail nodes. The specific nature and potential severity of risks vary by geography and node. To enable prioritization of social risks in supply chains, traceability systems should provide insight into the geographic footprint and types of worksites present in a company’s upstream supply chain.
• In seafood supply chains, migrant workers and women are at particular risk of forced labor.¹“In fishing industry, women face hidden hardships: study.” Conservation International, 2021, https://www.conservation.org/blog/in-fishing-industry-women-face-hidden-hardships-study.   Additionally, the use of third-party labor recruiters is a common practice.²Hidden Chains: Rights Abuses and Forced Labor in Thailand’s Fishing Industry. Human Rights Watch, 2018, https://www.hrw.org/report/2018/01/23/hidden-chains/rights-abuses-and-forced-labor-thailands-fishing-industry. Traceability systems that enable identification of individual vessels and suppliers – or at least identification of a specific region or port – can aid in later efforts to assess of labor broker practices.
• For more information, see this guidance from the Global Dialogue on Seafood Traceability.

• The U.S. Department of State’s Trafficking in Persons Report has highlighted indicators of forced labor in fisheries in Angola, Bangladesh, Burma, Burundi, Cambodia, China, Comoros, the Republic of the Congo, Ecuador, Fiji, France, Guinea, Indonesia, Ireland, Jamaica, Japan, the Republic of Korea, Maldives, Marshall Islands, the Federated States of Micronesia, Mongolia, Pakistan, Palau, Papua New Guinea, the Philippines, Poland, the Seychelles, Sierra Leone, Singapore, the Solomon Islands, South Africa, Suriname, Taiwan, Tanzania, Thailand, Timor-Leste, the United Kingdom, Uruguay, Vanuatu, and Vietnam.³Trafficking in Persons Report. United States of America Department of State, 2021, https://www.state.gov/wp-content/uploads/2021/09/TIPR-GPA-upload-07222021.pdf.  The U.S. Department of Labor’s List of Goods has reported forced labor in Bangladesh (in the production of dried fish), China, Ghana, Indonesia, Taiwan, and Thailand.⁴List of Goods Produced by Child or Forced Labor. Bureau of International Labor Affairs, 23 June 2021, https://www.dol.gov/agencies/ilab/reports/child-labor/list-of-goods?tid=All&field_exp_good_target_id=5789&field_exp_exploitation_type_target_id_1=All&items_per_page=10.
• The U.S. Department of State’s Trafficking in Persons Report has found indicators of child labor in fisheries in Angola, Bangladesh, Burundi, Cambodia, Cameroon, Chad, Ecuador, Gabon, Ghana, Guinea, Haiti, Indonesia, Kenya, Madagascar, Malawi, Mauritania, Namibia, Pakistan, Papua New Guinea, the Philippines, the Solomon Islands, South Africa, Suriname, the United Kingdom, Uganda, and Zimbabwe.⁵Trafficking in Persons Report. United States of America Department of State, 2021, https://www.state.gov/wp-content/uploads/2021/09/TIPR-GPA-upload-07222021.pdf.  The U.S. Department of Labor has noted the presence of child labor in fisheries in Bangladesh (specifically in the production of dried fish), Brazil, Cambodia, El Salvador, Ghana, Indonesia, Kenya, Nicaragua, Paraguay, Peru, the Philippines, Tanzania, Uganda, Vietnam, and Yemen.⁶List of Goods Produced by Child or Forced Labor. Bureau of International Labor Affairs, 23 June 2021, https://www.dol.gov/agencies/ilab/reports/child-labor/list-of-goods?tid=All&field_exp_good_target_id=5789&field_exp_exploitation_type_target_id_1=All&items_per_page=10.
• Identifying and understanding the geography of abuse in offshore fishing is complex. Abused workers may have travelled transnationally from their home countries and boarded vessels in foreign ports. Further, those ships may be registered and flagged in a third country while fishing in international waters or the waters of a fourth. It is not uncommon for a country to be included on the U.S. Department of Labor’s List of Goods Produced with Forced Labor or Child Labor for labor risk in the fishing sector due to abuses of workers on vessels that operate far from its ports.
• Migrant workers in the offshore fishing sector may experience a wide-ranging set of forced labor indicators, including deceptive recruitment, induced indebtedness, and document retention. As in other sectors, workers in the seafood sector may pass through a series of informal labor brokers, each adding an additional debt burden through fees for their services. Often, workers recruited through brokers have no advance knowledge of their actual employer, with whom they may be required to spend months at sea. Underpayment, non-payment, and withholding of wages are also relatively common in the fishing sector, particularly for workers aboard fishing vessels. The risk of exploitation faced by these workers is compounded by the fact that many workers do not understand how their pay is calculated and boat captains do not clearly communicate payment systems and structures. Given the severity of these risks, the difficulty assessing risk tied to geographic ownership of a vessel, and the challenges in communicating with workers on long-haul fishing voyages, companies attempting to assess and address labor risk in their upstream fishing supply chains should prioritize the design and implementation of traceability efforts that can identify vessels, fishing companies, and the geography of ports in their supply chain. These measures would allow more detailed risk assessments to be conducted.
• There may be different points of transformation throughout the supply chain due to diverse uses of fish. Some fish may pass through multiple levels of processing, while others may be sold as fillets or other types of fresh products. Fish canning and other processing facilities can also be sites of labor abuse. Traceability efforts in the seafood sector should be designed to accommodate these multiple points of aggregation and transformation, when relevant.

• There are approximately 59.51 million people who work in primary fish production. Most of them are employed in small-scale, artisanal fisheries and aquaculture businesses.⁷The State of World Fisheries and Aquaculture 2020. Food and Agriculture Organization of the United Nations, 2020, https://www.fao.org/documents/card/en/c/ca9229en.  
• The seafood supply chain includes multiple levels of middlemen and can more closely resemble a complex web due to its intricacy and opacity. Different procurement practices, like the buying and selling of fish via auction, broker, or market system, increase the complexity of the supply chain.

• Fishing is a labor-intensive occupation that can involve traveling a significant distance from shore (including into international waters). The offshore nature of fishing can make it difficult for vulnerable workers to escape forced labor risks.⁸“Fishing.” Global Slavery Index, Walkfree Foundation, 2018, https://www.walkfree.org/global-slavery-index/findings/spotlights/forced-labour-at-sea/.  Additionally, the nature of this work limits visibility into the living and working conditions of workers and hinders timely interventions and remediation.
• Certain types of vessels and fishing activities may have heightened risk for forced labor – specifically, vessels that fish in deep ocean and stay off-shore for long periods of time.⁹Selig, E.R., Nakayama, S., Wabnitz, C.C.C. et al. “Revealing global risks of labor abuse and illegal, unreported, and unregulated fishing.” Nat Commun 13, 1612 (2022), doi.org/10.1038/s41467-022-28916-2.  In these cases, without specific processes and protocols, workers on board may lack adequate access to the social supports of shore as well as the physical ability to leave the ship.
• Forced labor risks exist at the catching/harvesting node, the processing and packing node, and the selling node.

The seafood sector is characterized by complex supply chains. In fact, “chain” can be slightly misleading; the layers, including multiple levels of middlemen, can be so intricate and opaque as to more closely resemble a web. Fish and shellfish are harvested in open waters or raised via aquaculture in ponds, tanks, or bounded coastal waters. Transshipment vessels may transport wild-caught fish from the catching vessel to the market. After harvest, fish are sold via auction, broker, or market system and then packed and transported to processing facilities or wholesalers. Fish may be sold as fillets or other fresh products. It may also be processed into consumer goods such as canned, frozen, or smoked products. Some fish may pass through multiple levels of processing, while others, such as certain kinds of shellfish, are transported live. Wholesalers receive processed products and fresh fish from both foreign and domestic sources. The wholesalers then distribute the products to retailers and restaurants, where consumers purchase them.¹⁰“Fish.” Responsible Sourcing Tool, https://www.responsiblesourcingtool.org/visualizerisk.

• 1
  “In fishing industry, women face hidden hardships: study.” Conservation International, 2021, https://www.conservation.org/blog/in-fishing-industry-women-face-hidden-hardships-study.  
• 2
  Hidden Chains: Rights Abuses and Forced Labor in Thailand’s Fishing Industry. Human Rights Watch, 2018, https://www.hrw.org/report/2018/01/23/hidden-chains/rights-abuses-and-forced-labor-thailands-fishing-industry.
• 3
  Trafficking in Persons Report. United States of America Department of State, 2021, https://www.state.gov/wp-content/uploads/2021/09/TIPR-GPA-upload-07222021.pdf. 
• 4
  List of Goods Produced by Child or Forced Labor. Bureau of International Labor Affairs, 23 June 2021, https://www.dol.gov/agencies/ilab/reports/child-labor/list-of-goods?tid=All&field_exp_good_target_id=5789&field_exp_exploitation_type_target_id_1=All&items_per_page=10.
• 5
  Trafficking in Persons Report. United States of America Department of State, 2021, https://www.state.gov/wp-content/uploads/2021/09/TIPR-GPA-upload-07222021.pdf. 
• 6
  List of Goods Produced by Child or Forced Labor. Bureau of International Labor Affairs, 23 June 2021, https://www.dol.gov/agencies/ilab/reports/child-labor/list-of-goods?tid=All&field_exp_good_target_id=5789&field_exp_exploitation_type_target_id_1=All&items_per_page=10.
• 7
  The State of World Fisheries and Aquaculture 2020. Food and Agriculture Organization of the United Nations, 2020, https://www.fao.org/documents/card/en/c/ca9229en.  
• 8
  “Fishing.” Global Slavery Index, Walkfree Foundation, 2018, https://www.walkfree.org/global-slavery-index/findings/spotlights/forced-labour-at-sea/. 
• 9
  Selig, E.R., Nakayama, S., Wabnitz, C.C.C. et al. “Revealing global risks of labor abuse and illegal, unreported, and unregulated fishing.” Nat Commun 13, 1612 (2022), doi.org/10.1038/s41467-022-28916-2. 
• 10
  “Fish.” Responsible Sourcing Tool, https://www.responsiblesourcingtool.org/visualizerisk.
• 11
  List of exporters for the selected product in 2021 Product: 03 Fish and crustaceans, molluscs and other aquatic invertebrates. ITC Trade Map, www.trademap.org/Country_SelProduct.aspx?nvpm=1%7c%7c%7c%7c%7c03%7c%7c%7c2%7c1%7c1%7c2%7c1%7c%7c2%7c1%7c1%7c1.
  
• 12
  The State of World Fisheries and Aquaculture 2022. Towards Blue Transformation. FAO, 2022, www.fao.org/3/cc0461en/cc0461en.pdf.
• 13
  Fisheries and aquaculture production, European Union, 2019. oceans-and-fisheries.ec.europa.eu/facts-and-figures/facts-and-figures-common-fisheries-policy/fisheries-and-aquaculture-production_en.