The 18th of this month marked Anti-Slavery Day for the fifth consecutive year in the UK. Anti-Slavery Day was created by Act of Parliament and instigated by the Human Trafficking Foundation. However, there are still 21 million slaves in the world today, 7% of whom live in North America or the EU. The UK alone is estimated to be home to 10,000-13,000 potential victims of modern slavery.
Modern slavery can take on various forms, such as forced and bonded labour, child slavery, early and forced marriage, people trafficking and sexual exploitation in the private economy, agriculture, fishing, construction and manufacturing. Modern slavery is a crime and a violation of human rights and human dignity – but is also one of the world’s most profitable criminal activities generating $150 billion in illegal profits every year.
Modern Slavery Act
The UK’s Modern Slavery Act came into force in 2015. The Act requires companies with an annual turnover of £36 million that carry out business or part of a business in the UK to publish an annual slavery and human trafficking statement to disclose the relevant policies and due diligence processes they have applied during that year to ensure that slavery and human trafficking do not take place anywhere in their supply chains or of their own businesses.
The Modern Slavery Act is not the first modern anti-slavery law of its kind but is seen as a critical step forward in strengthening disclosure for more than 12,000 companies active in the UK on efforts to prevent human and labour rights abuses that exist in today’s global supply chains. These include precarious working conditions, forced and child labour, health and safety risks, migrant labour, slavery and human trafficking, a lack of or low wages, gender discrimination, restricted union activities and verbal abuse.
Learnings from the seafood supply chain
Traditionally human and labour rights have focused on industries such as coffee, minerals and textiles. In the seafood industry, concerns over the last 10-12 years have concentrated on the fish, while the human element in the supply chain has been overlooked. This all changed in 2014 when a seafood supply chain scandal in Thailand exposed a range of reputational, financial and regulatory risks facing the food industry. The scandal centred on Charoen Pokphand Foods (CP Foods), the world’s largest shrimp farming company, which supplies many supermarkets from around the world. The company was alleged to have sourced fishmeal from suppliers that own, operate or buy from fishing boats using slave labour. The abuses reportedly took place against a background of widespread corruption and conflicts of interest between boat owners, companies, police officials and government officials, all who are said to have benefited from the trafficking.
Unfortunately, this example is not a one-off incident. Human and labour rights abuses remain widespread in Asia’s and Africa’s marine fisheries but also occur in developed countries. The complexity of supply chains therefore creates a need for strong environmental and social management and justice systems.
The UK’s Modern Slavery Act has been ahead of European legislation. But the upcoming EU Directive 2014/95/EU requires the disclosure of human rights and corruption data. Under the directive, large EU-listed companies will have to publish a non-financial statement containing information on human rights and bribery and corruption matters as part of their annual reports. The European Commission intends to prepare non-binding guidelines on the methodology for the reporting of non-financial information and plans to consult stakeholders on these.
The International Labour Organization (ILO) has also decided to focus on the global fight against forced labour and human trafficking by developing The Protocol to the Forced Labour Convention, a new tool that gives countries more power to tackle slavery and supplements the Forced Labour Convention from 1930. The protocol requires countries not only to criminalise slavery and punish perpetrators, but to prevent it and offer protection and remedy to victims. It needs two national ratifications before it can come into force and the ILO has just launched a campaign to persuade at least 50 countries to ratify it by 2018.
Engaging on human rights
At Hermes EOS, we have developed an active dialogue with multiple stakeholders on human and labour rights. We engage with a range of food and beverage companies that were implicated in the 2014 seafood controversy to address these ESG issues and to develop dedicated human rights frameworks. To establish transparency, disclosure, traceability and transformational change in the industry, we have also started to work with human rights partners such as SHIFT, the Global Business Initiative on Human Rights and the Corporate Human Rights Benchmark, as well as sustainable seafood experts such as the Marine Stewardship Council, the Sustainable Seafood Coalition, the Sustainable Fisheries Partnership and the Ocean Disclosure Project
In September 2015, we also signed an investor letter in support of the Business Supply Chain Transparency on Trafficking and Slavery Act of 2015 in the US, drafted by the Interfaith Center on Corporate Responsibility. Please contact me if you would like to find out more. You can also listen to my contribution to the Innovation Forum webinar on human rights issues in the seafood supply chain.
 See for example the California Transparency in Supply Chains Act 2012 (US), The Business Supply Chain Transparency on Trafficking and Human Slavery Act 2014 (US) or the ILO Convention 29 on Forced Labour, 1930 and the New Protocol adopted in 2014
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