Director of Modern Slavery Risk Assessments
Wilberforce Institute, University of Hull
For over 15 years, Waitrose has had a strategy in place for the responsible sourcing of wild-caught and farmed fish. The retailer has placed great emphasis on ensuring they sell only high quality products sourced from known and approved farms (Waitrose’s supply chain information can be found on the Ocean Disclosure Project website). However, these farms (and fisheries) are located across the world and include some high-risk countries with regards to human rights abuses. Some of them have been widely reported in the press, with headlines focussing predominantly on seafood supply chains in south-east Asia and Central and Latin America. Examples include incredibly long working hours which have led to workers allegedly consuming drugs, such as amphetamines, just to keep going.
In March 2019, Waitrose commissioned the Wilberforce Institute to map out the risks associated with labour and human rights in their seafood supply chains for prawns, scallops, mussels, squid, ray, herring milts and clams amongst others.
The Wilberforce Institute conducted a desk review and interviewed HR personnel and managers from 11 seafood companies in Chile, Ecuador, Honduras, Indonesia, Madagascar, Nicaragua, Peru and Vietnam. The aim of this was to understand worker recruitment and management practices and consider the risk that modern slavery and labour exploitation could take place. The 11 sites covered a workforce of 8900 permanent workers and 1100 temporary workers employed on farms, hatcheries and feeding centres.
The interviews provided Waitrose, and their direct UK based suppliers, with an overview of the specific labour and human rights risks affecting the selected seafood supply chains. Below is a summary of the findings which were based entirely on information provided by site managers:
Gender: 95% of the workforce identified on farms and hatcheries and feeding centres were male. It was therefore considered that in the scenarios being assessed, men were at a much higher risk of human rights abuses than women. One of the reasons given for the gender disparity was that farms and hatcheries are remotely located and the tasks performed by workers are more physically demanding. It is notable that at the packhouse, the gender ratio changes with women representing 50% of the workforce. Packhouses are located nearer to local communities and the work is less physical.
Recruitment methods: Most sites appear to use labour agencies for the purpose of recruiting workers, but not for managing them.
2 out of 11 sites (12%) reported that they used labour agencies and/or subcontractors in Indonesia and Vietnam at hatcheries and farms in more remotely located areas.
5 out of 11 sites (45%) reported that labour agencies carried out recruitment, but that they directly employ the workers once they arrive on site.
Hours: It was found that there was often a lack of transparency regarding working hours. This, in turn, often translated into a lack of transparency on worker’s wages as it is unclear what hourly wage is being paid and whether overtime premiums are being paid.
2 out of 11 sites (12%) had no transparency on working hours and therefore there was a high possibility that wages were being incorrectly calculated.
5 out of 11 sites (45%) reported excessive working hours and working days. On one site, workers undertook four weeks of work without a day off.
Accommodation: Hatcheries and farms often house workers. The sites are remotely located and accommodation is provided at 7 of the 11 sites (64%). These house hundreds of workers at a time and this is where the risk of forced labour is highest. Processing sites tend to be closer to the towns providing better transport links and communication with the outside world.
Loans: It is recognised by the farms that loans can be of benefit where there is no welfare structure to support the most vulnerable. The loan amount must not be more than can be reasonably paid back, as this would create debt bondage. Loans were offered in 7 out of 11 sites (64%).
Worker voice: The effectiveness of current worker voice/feedback mechanisms at the farm sites is questionable.
6 out of 11 sites (55%) reported that they had trade unions in place: 4 of these were in Vietnam and 1 in Indonesia. To date, in Vietnam, there is only one representative organisation of workers, the Vietnam General Confederation of Labour (VGCL), however in December 2019 the New Labour Code of Vietnam was passed, for enactment in January 2021. In order to observe Vietnam’s commitments under the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), EU-Vietnam Free Trade Agreement (EVFTA) and ILO Conventions, the New Labour Code recognises the right of employees to set up their own representative organisations. The 2020 ITUC Global Rights Index rated Indonesia as a 5, which means there is no guarantee of worker rights in the country. There is also evidence that arbitrary arrests of union representatives were made there in 2019.
In South America, there was no trade union representation at any of the farm sites. Ecuador and Honduras were both rated as a 5, which means that there is no guarantee of worker rights, whereas Chile and Peru were only slightly better with a rating of 4, meaning there are systematic violations of rights. Nicaragua did not have a rating.
There has been considerable unrest across South America in recent years, and at one site, workers (who are housed in employer’s accommodation) were not allowed to contact the ‘outside world’, which was considered by the farm management as a safety measure but could also be viewed as a forced labour indicator.
As a result of these risk assessments, Waitrose engaged direct suppliers, sharing the findings of the assessments with them and following up on the individual corrective actions taken at the farm sites. They also issued a call to action for the industry to collaborate on greater transparency within seafood supply chains as the best opportunity to tackle both illegal fishing and human rights abuses within the seafood sector. To this end, Waitrose signed the Environmental Justice Foundation’s 10 point Charter for Transparency in 2019. Waitrose also recognised that there was a clear need for further investigation and research into the human rights risks in seafood supply chains, especially at the hatcheries and farm sites which are often remotely located and appear to be high risk. Industry collaboration is required to conduct and fund risk assessments on sites in the highest risk countries and could be supported by experts on modern slavery such as those at the Wilberforce Institute.