What’s the difference between the Labor Safe Screen and other tools?

Last week NPR and other news media published a story about the Seafood Slavery Risk Tool published by the Monterey Bay Aquarium and Sustainable Fisheries Partnership.  The Labor Safe Screen was referenced in the story and so was the Slavery and Trafficking Risk Template by compliance firms Assent Compliance, Baker and Hughes, and Ropes and Gray.  I’ve been asked, what’s the difference between these tools?  I went through the purpose and methods for all three and here are the results.

Note that I am striving to be fair and objective about Labor Safe Screen vs the other tools here in order to help people find the right thing they can do right now.  All three are helpful and stand out as green sprouts on a desert landscape.

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OECD stepwise

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The following tables contain the same info as above but are in a larger font which may be easier to read.

Track record: Labor Safe Screen

188 seafood products screened for 18 companies; Automated version now available in Trace Register; Partnership for Freedom  Grand Prize winner

MBA/SFP Slavery Risk Tool 


Slavery and Trafficking Risk Template

New to seafood sector

What’s in scope? End-to-end supply chain screening for products. Companies gain coverage for all products right away in the automated program because they are screened at tier 1 at the push of a button. Slavery risk is assigned to fishery profiles defined by species, gear, FAO area.  Results are said to apply to fishing vessels, but vessels are not a unit of analysis in this tool. The company answering the questions and their immediate suppliers are asked to complete the template to show good corporate citizenship on slavery risk.
Purpose Risk reduction. Labor safety coverage for all products, all chains.  Real conditions and real gaps and real needs for protection are identified (safety equipment, contracts, legal status) to benefit the human beings at the frontline of work. Raise awareness of slavery in fisheries Address the slavery risk to business and disclose the efforts the company takes to protect itself.
How achieved? Risk-based due diligence following the OECD pathway (graphic below). This is an interactive improvements program where suppliers can actively lower the risk scores for their products with proof points to show the protections in place. Analyst at the aquarium will look for information online to fill fishery profiles. Monterey Bay Aquarium and SFP will publish their findings in association with their environmental grading of fisheries CSR approach. Self assessment.  The template is generic for all sectors. The idea is all businesses will self-report in the same way to show they have done risk ID in their immediate reach. Can be effective if transparent. However if your company has a lot of ‘no’s’ in the answers it may not be easy to share the results.
Inputs Determinations by competent authorities of where forced labor is significant in seafood production (labor risk) and where there is adequate protection for workers from forced labor (labor safety).  Suppliers can lower risk scores with proof of protective practices in the supply chain and onsite.  Zero speculation in scoring. Any country-level and media articles online re. trafficking, slavery, forced labor, labor abuse, or poor working conditions will be tagged to fisheries. Each company prepares a template by referencing its own activities and those of its immediate suppliers.  Filling the template reveals gaps in coverage that companies could try fill, but no process for that.
Outputs Risk scores for products, goal is to have everything in the safe zone above 60 Online profiles Disclosure doc which could be helpful in case of investigations
Follows the Respect, Protect, Remedy guidance of the UN Guiding Principles on Business and Human Rights? Respect, Protect, Remedy Respect only, Fishery level only (not on land, not in transshipping, not in aquaculture, not in processing) Respect only, immediate suppliers only.
Partners to the tool Sustainability Incubator, Trace Register, Humanity United, Freedom Fund, Partnership for Freedom, Nexus Institute, UN-ACT, Labour Rights Promotion Network MBA, SFP, Liberty Asia Board is comprised of compliance executives from Assent Compliance, Baker and Hughes, Ropes and Gray.
Validation of the tool and track record Partnership for Freedom Grand Prize, developed with support from Humanity United and the Freedom Fund. Human rights experts in trafficking in fishing and IUU fishing experts were a vital part of its development. MBA led Used in compliance/CSR circles, formerly as the Human Rights risk tool


Here’s what each of the tools looks like on the inside:

  Pros Cons
Labor Safe Screenwww.laborsafescreen.comOverall: Risk-based due diligence for whole supply chains. The approach to product screening combines traceability, compliance and procurement approaches and combines findings from competent authorities in the human rights sphere (only) with supplier data.  No inference on risk.   Independent and confidential service which will generate Industry hasn’t come to grips yet with risk-based due diligence as a source of security on labor.  Risks are manageable, but seeing the gaps in coverage in the chain is still quite scary!  It’s a learning curve.
Automated for instant results All products run through tier one will receive a risk score based on the country of origin data already available in Trace Register (fishing, farming, processing and exporting countries).
Tier Two Scoring All products run through tier two will receive a risk score based on protective practices in the supply chain.  Suppliers will be engaged and asked to identify protective practices and will have support to build them up. Suppliers are engaged and scores reflect their contribution of data.  We accommodate this challenge in scoring and offer support.  We focus on de-risking the process for suppliers.
Tier 3 Scoring Products with persistent high ³60 scores can be run through tier three.  At tier three the facility owner is asked to provide proof points to demonstrate a minimum floor of protection for all workers in the facility (including subcontracted and migrant workers) Suppliers could game the proof points, for example by producing a list of names.  However, the object here is to locate the accountability for the score with the right organization, and put the onus for coverage at the right place.
MBA/SFP Slavery Risk Toolhttps://ssrtool.s3.amazonaws.com/Seafood_Slavery_Risk_Tool_Methodology_3-Feb-2018_Final.pdfOverall: This is an educational service which will publish in one place all easy-find allegations and findings of slavery and human trafficking in the public domain, including any questions raised about forced labor or child labor by the media.  This fulfills Liberty Asia’s mandate, which is to let bankers and investors know. “Fishery” scope is not a unit used in human rights research so the analyst must infer every risk relationship.
  Findings will associate to MBA and SFP fishery ratings Findings will associate to MBA and SFP fishery ratings
  Country-level risk scoring is the right place to start because competent authorities have rated countries on forced labor risk.
High Risk Path 1 Assigns country level risks outside of seafood production agriculture, forestry etc) to seafood with no basis.
High Risk Path 2 vs Moderate Risk Path 2High Risk Path 2 is a finding of no risk in the fishery but risk in other sectors in the country. High Risk Path 2 and Moderate Risk Path 2 are virtually identical
Slavery & Trafficking Risk Templatehttps://www.socialresponsibilityalliance.org/strt/resources/Overall: This is a disclosure approach which addresses one of three pillars of the UN Guiding Principles on Business and Human Rights. Asks the right general questions about where risk occurs to business. Good stuff to have in a company code of conduct. Missing perspective and problem definition from seafood and also from the human rights sphere.  Not specific enough to catch seafood work realities; for example most fishers are paid by share not salary.


Are we there yet? –Solutions

When we started building the Labor Safe Screen in 2013 it was a tough sell.  No-one, not even sustainability NGOs, wanted to acknowledge the problem of forced labor in seafood.   That did not make it easy for food companies to come to grips with it.

Today in 2018 we know the problem is significant. We know it will be dealt with.  What changed? Human Rights Watch and the Nexus Institute spoke to workers in fishing and seafood production and published what they heard. Competent authorities in the human rights sphere then summarized the scale and significance of the problem.  They include the International Labour Organization, UN Action for Cooperation against Trafficking in Persons, US Department of State, and the remarkable team at US Department of Labor’s International Bureau of Labor Affairs.  Its List of Goods made from a significant incidence of forced labor and child labor includes fish from Bangladesh, Cambodia, Ghana, Indonesia, Kenya, Peru, Philippines, Thailand, Uganda, Vietnam, Yemen, shellfish from El Salvador and Nicaragua, and shrimp from Bangladesh, Burma, Cambodia and Thailand.

Fabulously, now that the problem has been defined by the authorities it’s time for solutions.  This blog is about solutions.  Are we there yet?  Yes and no.  The key to solving the problem is found in how the problem is defined, and also the competent authorities who defined it. The solutions live in the human rights sphere with these organizations.

It is important to recognize that the industry has come to the table.  Remarkable strides were made after The Guardian newspaper published its investigative account of forced labor in Thai seafood.  Most big companies today have a human trafficking statement.  Most have said they have zero tolerance for forced labor.

Some companies have engaged with human rights organizations, for example the Issara Institute in Thailand, and stepped onto a solid track for resolving problems specifically there.  Similar casual working conditions are found worldwide.  Few companies have partnerships with human rights organizations in other countries.  How then can global companies see where the problem lives in their supply chain?  Where are improvements needed?  Where do workers need safer work, and help to be paid?

The reason the Labor Safe Screen was founded was to help bridge the gap between food companies and the human rights sphere.

In 2013 we learned that on the one side, human rights organizations worldwide were compiling evidence of working conditions in the supply chain.  Many maintained direct relationships with workers.  On the other, executives at retailers, distributors and importing companies had their suppliers’ word there wasn’t a labor problem in the supply chain.

Before the 1980s, that may have been good enough.  But today’s work environment is subcontracted.  People move for work.  People from impoverished areas often move for work through agents.  This work is contracted by large exporting facilities as often as it is by small facilities.   In many sectors today there is a tremendous reliance on work with terms and conditions which are hidden by agent relationships.  Where insecurity builds it can make a supply chain unstable.

In five years of building, testing and now running the Labor Safe Screen we have learned that input from industry and human rights authorities is essential to marry the realities of the fishing industry with the experience of workers.  Science and technology help capture the human experience of the working conditions.

What’s left to do is accept that the authority for solutions resides with workers themselves and with the approaches authorities recommend.  The consistent advice to industry is to take risk-based due diligence across the supply chain.

Labor risk in supply chains appears to be complex, and it is, but the outlines of solutions are ever more clearly laid out in the expectations of the competent authorities on human rights.  The proof?  Read the new Human Rights Watch report.  Ask, why would Human Rights Watch continue to invest in the state of human trafficking in seafood, if current approaches were sufficient to end forced labor?  Like following the money, read the new Human Rights Watch for their perspective and the seeds of solution in it.  Follow Nexus Institute, follow ILRF, follow UN-ACT.  Especially, follow the new ILO-FAO partnership for decent work in fishing and seafood.  The light at the end of the tunnel can be seen from here.


Overcoming the double whammy of slavery in seafood


If a CEO wakes up to a 911 phone call over a newspaper headline linking the company name to fishing by slaves, what should they say?  Ideally: “We’re on it.  Let me show you what we have done to reduce risks of exploitation for the fishing crew and factory workers in our supply chains”.

If a seafood importer receives a 911 phone call because a consignment of seafood has been pulled by US Customs to investigate ties to slavery, what should they say?  Ideally, exactly the same thing.

For now though, before this option has materialized, speaking up is still fraught with risk of association to the issue.

US companies are suddenly exposed to any product ties to slavery.  In 2015 the US Department of State cited trafficking in fishing in 55 countries and nine of the countries appear on the Department of Labor’s (DOL) list of fish goods produced with exploitative labor, flagging them for scrutiny under the 2016 import ban.

The first step for showing compliance is figuring out the supply chain and prioritizing the risk.  BUT… in a market where even the national trade association is keeping quiet on the issue, a company that acts could cause itself brand damage.  Any reporting on it (even positive press) means Google could inadvertently link the word “slavery” to the company’s name.


Petitions against the new trade rule for goods from Thailand, Indonesia, and the Philippines and other countries appearing on the DOL list will trigger seafood inspections.

Yet amid a stream of media accounts and class action suits associating the US seafood industry to modern day slavery, and even an Executive Order obliging federal contractors to certify they’ll act to eliminate recruitment fees, ID confiscation and so on, US companies largely have not initiated due diligence measures.

Further, ‘acting’ is not simple for US retailers and importers who may purchase up to 100 species of fish from close to 200 fisheries worldwide.  Their seafood departments often lack the domain expertise, information and tools that would allow them to understand trafficking risks within their supply chains and to proactively work with them to reduce and mitigate the risk of buying illegal products that could lead to brand damage, lawsuits, broken relationships and supply chains and lost supplies.



There are things businesses can do to reduce their own risks.  These are not necessarily the same things as are needed to reduce risks of slavery for the human beings held captive and unpaid in seafood work.  Both need urgent progress.

Many sectors have gone through it and offer clear lessons.  Seafood is tricky due to the intricacies of trading across multiple platforms and watery geographies.  However, two things are constant:


1.) Companies who can show they are already doing something will fare better than if they were doing nothing. 

When a particular shipment is tied to a particular facility and an association is made, where companies are doing more ‘stuff’, that will be considered a mitigating circumstance, according to Shawn Macdonald from Verite.   Customs officials (Inspections and Customs Enforcement-ICE) will be looking at how to trace products from high risk origins.  They will make associations based on the evidence.  In US investigations, companies who link their risk profile to product tracing look better than if they didn’t.

What ‘stuff’ also reduce risks of slavery — in any meaningful way for real people??

2.) Ultimately, the only way the promises stick from certifications or codes of conduct is when all of the elements are pushed down through contracts.

Understanding there is no simple way to create an assurance of completely eliminating slavery from fishing and fish processing, seafood buyers now have the challenge of proving they don’t condone it passively in their purchasing.

Contact us for assistance.

Safe Seafood = Safe Fish + Safe People

Seafood sustainability is a value-adding proposition.  Ethical seafood on the other hand is a deal maker or breaker.  Today the market needs assurances food is safe, not only from tests along the cold chain showing food is safe to eat, but environmentally and ethically.  The big retailers have environmental procedures their vendors comply to, but what about tests to verify the production conditions behind the food are safe for people?  For food producers?

Not yet, but they are coming.

Today I was on the phone with an executive at a large US retailer who will be conducting vessel audits when he could be Christmas shopping.  He is a higher up who is going in person to the audits to make sure they are done right for his company but also potentially industry-wide.  He’ll be coming here to Hawaii where we are also preparing a model for protecting the rights and entitlements of fishing crew, which we have been working out together with the US Department of Labor’s Bureau of International Labor Affairs (ILAB). We have an “auditable” set of procedures now and we are curious to see if they align with the retailer’s set.   It’s a great sign that agreement is around the corner and alignment is near, which means safe labor controls could be added to control systems for keeping food safe, alongside temperature and time controls.

It’s been awhile since I have made a post because I’ve been preoccupied with working out this equation, Safe Seafood = Safe Fish + Safe People.  I think we are getting there, and that is why I am speaking up.  There have been breakthroughs over the past months.  I’ve had the pleasure of hearing people speak up and asking questions about the producers behind our seafood.  They were always there, but we are starting to see the human face, and it is wonderful.  It is wonderful because there are a lot of honor and grace in seafood work, and there are benefits as well as risks, and we need to start putting these things back together in our programming.  Something I’ve been keen to rediscover in sustainable sourcing is the role of the customer and people passionate about good food.  I’ve been listening to executives and academics, policy makers and grant makers and also to school kids, fishers, processors and exporters these past months.  I was invited to speak at a number of events but have  focused on listening.

For a mini 2016-in-review these include the US-Japan Ocean Conservation Symposium in September, the Sustainable Shrimp Task Force meeting in Bangkok in June, the policy makers table at a celebration of sustainable seafood hosted by the Prince’s Charitable in London in June, the USAID Feed the Future Asian Agriculture Summit in Bangkok in May (GREAT event), an event to define the “high road” for firms at the Robert F. Kennedy Center for Human Rights in Business at NYU-Stern in New York City in April, Partnership for Freedom bootcamp in Washington DC in February, and the SeaWeb event in Malta in January.

I listened for: what are people perceiving as risk?  What about seafood makes them feel healthy?  Where do they seek information? What are the factors they loofe Seaffok at to make up their mind?

I was surprised by what I heard.  Attention has shifted from fish to people.  Seafood producers are characters in the story behind the food.  They are starting to be seen.  It won’t take long, I predict, for sector leaders to come to see producers as the key to future success, like in agriculture.  In 5 years we’ll be in a better place on ethical sourcing, and customers too.

Thank you and Aloha to the many people contributing to the shift.

Tech Fix

Slavery is a human problem.  Slavery in supply chains is a business problem.  Supply chains can solve some big problems, for example seafood supply chains solve food safety problems with cold chain solutions built on hazards analysis and control points — tech fixes.

Slavery can not be ‘solved’ by tech fixes. Some supply chain problems can be, like untangling human rights risks and checking procedures are in place to protect worker safety.

Labor Safe Screen is both a tech fix and a human solution.  It presents an opportunity to manage knowledge and conditions in workplaces throughout a supply chain.  Designed for seafood, Labor Safe Screen is built for complicated and fragmented supply chains weaving across the planet through high seas and developing countries.  Not all parts of the chain have the same regulatory environment or the same procedures.  Not all organizations in the chain can be seen, not all facilities are visible, but perishable food products arrive in end markets safe to eat, because the safety hazards are controlled.  If fish handling can be managed safely then labor handling can be managed safely.

Safe Seafood = safe fish + safe people. That is the premise of the Labor Safe Screen.

What’s the tech fix?  Information systems and technology.   Put risk screening into food traceability software and voila, safety hazards can be controlled.   This year the Labor Safe Screen is being built into Trace Register food traceability software, which is used widely in the U.S. grocer retailer community.

The LABOR SAFE DIGITAL CERTIFICATE presents an opportunity to companies in a supply chain to work together to pool knowledge of worker rights, entitlements, and labor conditions to spot risks in the workplace, manage the response, and respond with procedures to close out hazards and remedy breeches.

Winner of the Grand Prize in the Partnership for Freedom challenge to rethink supply chains to combat modern slavery, the Labor Safe Screen Digital Certificate is a tech fix companies can take up to act on a huge global issue.  Joining into the solution provides not only assurances and proof of efforts but real information about product origins, material inputs, and vendors for procurement teams to source smarter and a competitive advantage for food businesses to thrive and grow.

Contact Sustainability Incubator or Trace Register to look into it or for a demo.

With Aloha,

Winner of the Rethink Supply Chains Innovation Challenge!


Sustainability Incubator and Trace Register, a seafood traceability firm, have teamed up to offer the Labor Safe Digital Certificate, winning the Rethink Supply Chains Challenge on May 15, 2016.

The Innovation Challenge to Rethink Supply Chains is a technology competition hosted by the Partnership for Freedom.

Announced by President Obama September 2012, the Partnership for Freedom is a public-private partnership to spur innovative solutions to human trafficking challenges.

Partners include Humanity United, the Department of Justice, the Department of Health and Human Services, the Department of Housing and Urban Development, the Department of State, and the Department of Labor. Private efforts are supported by Steven Spielberg’s Righteous Persons Foundation, Goldman Sachs’ 10,000 Women Initiative, the Ray and Dagmar Dolby Family Fund, and a growing list of private donors. All funding for prizes is provided by private donors.

We’re fit for purpose. Why is that so radical?

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The idea of the Labor Safe Screen idea came from a handful of people committed to sustainable fishing and livelihoods:

Transfers of fish and people at sea are very complicated, but generally records are available to identify the landing vessel and the subsequent supply chain.  Factories in seafood hubs like Thailand are generally well financed and have systems in place to segregate materials from different catching vessels if there is a reason to do so.  If there is demand or a specification from a buyer to trade in this way then it is possible from a systems perspective.  Subsequent audits can be carried out to check compliance.

This idea is radical because it’s just regular food business.   What sets it apart is the topic of slavery, and its nuances and tremendous consequences for business and producers.

Sparked by a question in 2012 about unpaid working conditions for Burmese crew on Thai boats, asked by Yangon-based Andrew Kirkwood, head of the UN Lift Fund (Livelihoods and Food Security Trust Fund), Dr.s Katrina Nakamura, Trevor Ward, Pramod Ganapathiraju, and Iain Pollard had a series of conversations about what if..?   What if seafood companies could address slavery like they do sustainability, meaning directly between buyer and seller?  Could the same type of benefits be generated, like preferred standing with buyers?  Food companies look into fishing origins to better manage their supply chains, say for food safety and regulatory compliance.  Could their own working knowledge and trading requirements make a difference for producers?

If we could build it into procurement, in a really simple way, and companies used it, great, but how would we know if things are getting any better?

Honestly we didn’t know.  Together we acknowledged this is consequential stuff and took a vow to do no harm.  Then, we dove in.  We made ourselves accountable to human rights experts and in return they significantly improved our naive ideas.  (We thought we were rigorous scientists, holy cow, we were awed by Lori Bishop, Rebecca Surtees, Paul Buckley, Matt Friedman, Phil Robertson, Lisa Rende Taylor and more).  We completed a tremendous amount of experimentation, design, peer review and trips back to the white board before we got to workable units scientifically and the technological side parameterized in 2014, thanks to support for development from Humanity United. Then artist Jakkai Siributr asked, who are you working with on the ground?  We’d been working with experts at the agency and institute level but not on the ground.  We were blessed to meet the team at the Labour Rights Promotion Network in Thailand.  We started listening and finding ways to bring their sightline into the screen to ask better questions about recruitment and producer safety.  Dominic Chakra Thomson joined us and worked with Thai Union on a supplier survey.  It’s not a slavery survey.  It collects the kind of information seafood sellers want to know about origins and inputs.

Two years more were invested and the Labor Safe Screen is grounded.  It’s connected with the authorities, with frontline and seafood conservation NGOs, and with food companies.  It is a low cost plug-in offering risk assessment and verification practices from inside the sourcing programs food companies use every day.  It’s going inside Trace Register.  It’s powering the Social Responsibility Risk Tool for Global Fisheries.

Why is this fresh?  The Labor Safe Screen is a plug-in, not an add-on.  Its purpose is to build more security into seafood trading for its user, and for the product they want to continue to trade, which is made of course by a producer who deserves to be safe.  Labor Safe Screen is not a standalone, comprehensive, or labor-overhauling program.  There are no open-ended consulting fees or membership rates.  The food company decides how far it wants to go.  Every dollar invested goes directly to risk ID and product advancement to labor safety.  How? Suppliers’ knowledge is employed to close out risks. Checks and balances are provided by the evidence published by authorities (U.S. Departments of Labor, State and Homeland Security) and the frontline organizations and human rights organizations with eyes on the ground.

The Labor Safe Screen is offered by an independent, for-profit company based in Honolulu and operating with very low overhead.

The Sustainability Incubator is an advisory firm helping food companies advance and solve human rights challenges.  We are a tactical company putting teams together wherever needed to help companies face issues with a clear strategy.   It’s all user-designed and user-operated.  Why did we set up this way, instead of crafting ourselves as standards-setters or trying to build a big program?

Gets back to the vow and the biggest question:  How would we know if things are getting better?

Food will taste better when producers are safe from slavery.  We will know things are better when human rights experts can adjust their programming support away from seafood to another sector needing it more.  Our premise is business is a force for good in society and helps this shift, in seafood as in apparel and minerals.  Buyers and sellers of our food, much of which is imported with a mix of contents including some unknown origins, are good and honest and courageous people wanting the same dignity for producers as they expect for themselves.  Buying and selling moves money and reaches places which change peoples lives.

Where slavery has been abolished, it didn’t happen because slave owners suddenly saw the light.  It happened because of adjustments, in the economy and the culture, and in individuals, realizing it would not make life unlivable or business less profitable, and might even make it more secure for the long-haul.  Slavery ends when people can see one another.  Modern day slavery ends in food when we connect what we eat everyday to who made it for us and what that life might be like.  We will know things are better when the idea of ending slavery in food production is not fraught with risk itself, but is a completely normal even joyous part of food business.

Information for trading

Seafood is a no frills business sector.  Traders need fish to fill orders and they need information — to clear customs swiftly, to show the quality details to meet buyer specs.  Seafood is also a sensitive food product.  Supply chains manage these sensitivities and good-tasting seafood is delivered every day.  There’s no fluff, but it’s sophisticated.

This is the basic frame for the Labor Safe Screen, really for all programs of the Sustainability Incubator.

The Labor Safe Screen isn’t a gotcha tool but rather a way for seafood buyers to screen, prioritize, and drill down where needed.  If corrective actions are needed among buyers and sellers, we help focus to reduce risks.  We don’t dictate or prescribe or rank.  We don’t offer a green check mark for signing up. We help companies close out risks taking a “roll up your sleeves” approach.

Now, this approach is nothing new and already embedded in the industry and used everyday for multiple things.  Equally it can be used for a food safety issue, for example for managing mercury levels in a finished product.  The twist is the Labor Safe Screen finds slavery hotspots.  We scan production for any places where risks to business are severe or high because the authorities say slavery is occurring.  We are especially vigilant looking for those slavery risks to business which are the most consequential to vulnerable human beings. Where would an effort to reduce slavery risks to business truly improve the safety for producers?  We are especially committed to finding these overlaps because our goal is to help investors in seafood to face issues with a clear strategy, and producers are investors too.

What can one company do?

To tackle human rights issues down supply chains to producers, and up chains to regulators, there must be provisions for trading information and sharing costs, or definitely for sharing capacity with suppliers at no extra cost.

For a company with a strong relationship with a few suppliers, it may be possible to close out exposures directly. For larger companies, getting the information and accountability needed will require a tiered or phased approach that shows a little more understanding of how difficult it’s going to be to show full visibility behind a product.

If, for example, you buy shrimp that comes from a large importer or distributor, under their proprietary brand, you may have no relationship with the importer, much less the producer. So it starts with asking the importer or distributor where they get their shrimp. They’re not going to give a clear answer because they won’t immediately know and must leave room for themselves to buy shrimp on the open market if needed. So it’ll mean contacting the producers that provide the majority of the distributor’s private label shrimp and starting to ask about working conditions. They’ll simply say there is no slavery in their supply, so it’ll require preparations on the background and having the right questions to drill down into subbed arrangements, auction and spot buys, and so on.

In some cases, finding a new supply is an option, but it shouldn’t be the first choice. Instead, engaging suppliers and improving oversight can cause more positive impact.  Posing the right questions about the origins and inputs of seafood supplies builds accountability and coverage for this issue.  Doing this systematically will reduce risks geometrically and show due diligence to investors, regulators, and others.

These steps work because they build a knowledge system and produce information that has value in trading.  Again, you could use these same steps to close out risks of many different kinds.

Slavery risks can be addressed in this way by business, but beyond the technical, beyond the technological, we are still talking here about an issue so deeply troubling that talking about it produces a very human experience.  The ‘will’ to roll up the sleeves and deal with this directly is not something automatic to be expected from companies.  I’ve written before about the double whammy of slavery in seafood.  I’ve also written about the difference  TLC makes to seafood’s taste. (See earlier blogs.)

Over the past months I’ve been trying to figure out how best to communicate the “facts” about slavery in fishing and seafood in a way which can motivate and inspire rather than discourage.  One of the things which needed to happen was for people to see it’s real, and documented by policy-makers worldwide.  Beyond that, where does it happen in fishing and how severe?  The ILO, US Departments of State and Labor, the media, and some NGOs like Environmental Justice Foundation have taken the steps of pushing the evidence into the public domain.  The US and UK governments have proceeded to regulatory reform.  However, something’s still missing.  The big thing is how to inspire?

How can seafood businesses help governments regulate these matters better?  Does it mean starting with private regulation inside some supply chains, where things have gotten carried away?  The Shrimp Sustainable Supply Chain Task Force is doing this.  It hasn’t spread to other products beyond shrimp, but is incredibly effective.  Check out their website.  There are 38 companies signed on.  Some of them like Morrisons in the UK are having suppliers complete vessel registers.  It’s fantastic.

The Labor Safe Screen was produced by a barn raising.  We have had an enormous investment from people who care about moving the dial on modern day slavery AND care about good food — from human rights and seafood experts and terrific organizations like Humanity United.  Offering to try help make this issue go down a little more gently is our way of sharing back the TLC.  We offer a plug in with an algorithm and survey and reality checking safeguards for risk ID, but it’s not a panacea and nothing if it doesn’t make people’s livelihoods safer, from boat to boardroom.

We are looking for partners in seafood and beyond seafood who see business as an agent of good in society, who respect food business like we do as a provider we all rely upon.  Who doesn’t want to eat food made with the best information?  It’s pretty personal.


Katrina Nakamura

Founder, Labor Safe Screen


Freedom of expression

This past week I attended a workshop about corporate performance on human rights in business.  People from different sectors were brought together to sort out the “high road” for firms.  We were asked to suspend our thinking about the daily puzzles we work through and try to see the big picture.  What are the biggest targets for the largest of corporations to advance human rights?  How can corporate performance be measured against big goals?

The workshop set a broader scope than I am used to thinking within.  The end of the supply chain isn’t the retailer, they emphasized, but the investment manager.  On behalf of clients they are tasked with weeding risks like slavery and paramilitary and political deals out of their portfolio.  They need to knit positive advancements on environment, social and governance into their portfolio.  Environmental, social and governance (ESG) refers to the three main areas of concern that have developed since 2014 as central factors in measuring the sustainability and ethical impact of an investment in a company or business (thank you Wikipedia).

For part of it, I was confused.  At Sustainability Incubator we work on very simple things about real people even if some of the themes are large and challenging (“combating slavery in supply chains” and “improving fisheries”).  Most days I have my head dug into “what business can do” …can corporations set big human goals anyway?  It was harder than it may sound to think about it and to be a good contributor to a diverse group.

The reason for initial confusion was I couldn’t see a direct link in the fishing industry.  Then one of the people in our smaller breakout group for food business used a word, future-casting.  I didn’t get it right away because I’ve been drilling into the present concerns of sustainable seafood for some time.   Others at our table shared ideas about a dignified life with freedom of expression and self determination for producers.  I’ll be honest, I couldn’t at first square with the realities I face everyday around an absolute lack of agency for millions of migrant crew on fishing, reefer and supply vessels worldwide.  I almost felt we were projecting our privilege onto the most vulnerable people in a naive way.

But that was my shortcoming.  For the ball to drop it took not only a very long flight series home and a very big sleep but listening to music.  Prince and David Bowie of course.  What do these genius artists share?  Why, they represent a dignified life.  A single person on this planet can create dignity through freedom of expression and self determination.   They showed it in music which touches us.

It turns out I was doing the very thing I was afraid of at the workshop.  Surrounded by high level people there’s me, born and raised in a mining town and holding tight to the negative experiences of people affected by big industry, in places like where I come from, when their realities aren’t factored into the business model.  But my own life is proof there are positive, expansive and incredible opportunities for growth and change as well.  I betray what I’m here for when I forget it.

When respect for dignity is part of an investment to reach people at the front end of supply chains the return is better profitability and a longer run of success.  When it isn’t well we know what happens.  Maybe not all agree but it’s truth for me and I have lived it in seafood since 1995.  It has not been easy — because it is not easy — but I love seafood and its future.  There is nothing to do but roll up the sleeves and keep going with a smile.

It was amazing to share the middle of a work week with sector-level decision-makers and a privilege to focus on advancing the shared responsibility for human rights in business.   It was an interesting time to be in New York City.  Glorious Spring weather and political times.  I felt a part of the experiment of democracy which is singular and beautiful in this country.  It is a very special thing about living and working in the USA.


Remember the minimum wage poster? It’s back, but for boats & overseas plants

At sea, the golden rule for work on fishing boats, reefer vessels and supply vessels can be less than obvious due to the global nature of fishing and the number of countries involved.  Not surprisingly, international instruments exist to provide guidance to business on respecting workers’ rights.  These apply to companies and governments and so to all industries whether they occur on land or water.


There are three to know.  The first is the Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy.

The second is the OECD Guidelines for Multinationals.

The third are the UN Guidelines for Human Rights in Business.


Basically, these are meant for big companies operating in and across many countries who can’t easily see all aspects of production at all parts of every supply chain.  Below are their basic recommendations.


The ILO guidance reminds me of the workplace posters I used to see as an auditor, the large ones posted obligatorily in every business stating the minimum wage requirements:


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The OECD guidance says what due diligence looks like, using the mining sector as an example but the steps apply for other commodity sectors:

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The UN Guiding Principles provide guidance for companies and corporations to ‘Protect, Respect and Remedy’ human rights in business:

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Safe Seafood = Safe Fish + Safe People