Human Rights / Slavery

Don’t Jump Ship

The Seafood Slavery Risk Tool helps inform businesses about abuses of labour and human rights in their seafood supply chains

This article is by the Seafood Slavery Risk Tool Analyst Team (

Myint Naing, held captive for 22 years after being trafficked onto Thai fishing boats, never thought he would see his family in Myanmar again. Joshua, and three other Filipinos, escaped from a United Kingdom scallop dredger after enduring violence and death threats to keep them working up to 22 hours a day. But another Filipino, Eril Andrade, did not survive his enslavement on a Taiwanese tuna longliner. Neither did Supriyanto, an Indonesian trafficking and forced-labour victim, who also died on a Taiwanese longline vessel. These men’s stories, and those of others, including the thousands we will never hear, are why the Seafood Slavery Risk Tool exists.

Until a few years ago, the labour- and human-rights abuses in the notoriously opaque global fishing industry had remained largely invisible to the outside world. But a series of high-profile investigations reported by the Associated Press (AP), The Guardian and The New York Times in 2015 and 2016 created a heightened awareness, leading the business partners of the California-based Monterey Bay Aquarium Seafood Watch programme (Seafood Watch) and the environmental non-governmental organization (NGO), Sustainable Fisheries Partnership (SFP), in Hawaii, to seek out information on how to identify affected fisheries and help drive positive change.

It soon became clear that it would be no easy task to gauge the risk of forced labour, human trafficking, or hazardous child labour in seafood supply chains. Reliable, publicly available resources for this purpose simply did not exist. The available studies and tools tend to focus on whole sectors or countries, instead of individual fisheries. A new risk assessment tool was needed – one based on credible, public information and a clear and robust methodology – that informs due diligence and spurs remedial and transformative action.

After two years of hard work and extensive consultation with business and human-rights experts, a coalition comprising Seafood Watch, SFP and Liberty Global/Liberty Asia, a Hong Kong-based NGO working to prevent human trafficking through legal advocacy and technological interventions, launched the Seafood Slavery Risk Tool in February 2018.

Following a rigorous decision-tree-based methodology, the Risk Tool assesses if there’s a Critical, High, Moderate, or Low Risk of forced labour, human trafficking, or hazardous child labour in the wild-capture stage of a fishery. To do so, first, analysts document any publicly available evidence in the profile fishery. If evidence is found and deemed credible – gathered from reports and publications by authoritative institutions, including media, governments, academia and civil society – the fishery is assessed as Critical Risk, period.


If there is no evidence in the fishery, the Risk Tool team then looks for any evidence in the country’s other fisheries. Where evidence is found, it is categorized as either related or unrelated to the profile fishery (that is, similar species, gear type, and/or location) or as unspecified, if the nature of the fishery is not reported. The absence of evidence does not automatically equate to Low Risk. The Risk Tool’s decision tree also treats evidence in unspecified fisheries the same as related fisheries because the former’s relation to the profile fishery is unknown.

Next, Risk Tool analysts evaluate the relevant legislative framework and enforcement effectiveness of the country responsible for regulating the fishery or where the product is landed, whichever is most appropriate. This portion of the assessment – called the country criteria – does not result in a country rating. Rather, the findings inform the assessment by providing greater context about the risk environment within which the fishery operates. This precautionary approach is needed because labour conditions in the fishing industry are often not well documented. Indeed, Risk Tool analysts have thus far found a glaring lack of information published by the fishing industry on labour issues, though evidence from governmental, media and civil society organizations is mounting.

In certain circumstances, evidence of forced labour, human trafficking and hazardous child labour in a country’s related or similar renewable resource industries – seafood processing, forestry, agriculture and aquaculture – may be examined as indicators of high or moderate risk in the profile fishery. For example, in situations where there is no evidence in fisheries and country criteria have not been met, evidence in one or more of the above industries indicates a high risk for the profile fishery.

Finally, all assessments are carefully reviewed by external experts who are asked, among other things, to judge the credibility and validity of the sources.

Due diligence

The Risk Tool is intended to inform due diligence by companies, by highlighting where risks may be most significant. It is important to note that the Tool provides contextual information for particular fisheries, but cannot replace robust supply-chain management by businesses.

As illustrated by the Risk Tool’s conceptual model (see diagram), there are multiple paths to High, Moderate and Low Risk. The path a profile fishery follows depends on the evidence in fisheries, the country criteria evaluation and, if relevant, evidence in related or similar renewable resource industries.

If a fishery is assessed as Critical or High Risk, it does not necessarily mean that forced labour, human trafficking or hazardous child labour is pervasive in the fishery. Also, if a risk exists in one fishery, it does not necessarily mean a country’s other fisheries are likely to have the same risk.

The Risk Tool coalition does not advocate for a “Do Not Buy approach when a fishery is assessed as Critical or High Risk. Indeed, quite the opposite reaction should happen. The Risk Tool recommends engaging and supporting improvement efforts because there is a real danger that jumping ship could drive the problem further underground, placing affected fishermen or children at even greater risk of abuse.

In addition, disengaging from fisheries with human and labour rights issues will ultimately lead to a landscape where ethically minded and law-abiding firms compete in an increasingly uneven playing field with unscrupulous businesses that are willing to purchase seafood caught by slaves or children. The industry’s lack of transparency about its risks and challenges also encourages this kind of competitive business environment.

The coalition thus advocates the identification of source fisheries and their assessment for social and environmental risks, using the Seafood Slavery Risk Tool and other resources. In tandem with environmental sourcing policies, companies should create a Human Rights Policy that all suppliers must follow.

If forced labour, human trafficking or hazardous child labour is discovered in the supply chain, the Risk Tool coalition advises creating and implementing a Corrective Action Plan with the help of on-the-ground organizations and other key stakeholders, including those whose livelihoods depend on the fishery.

Lastly, businesses should document their efforts, evaluate their impacts, and share lessons learned so that others can avoid similar mistakes, and good practices can be replicated. To fully address these human-rights issues, the seafood industry also needs to become more transparent. There are many organizations and resources available for assessing, preventing or correcting human- and labour-rights abuse, some of which are listed on the Risk Tool website for informational purposes.

Myint Naing was freed and went home to Myanmar, thanks to the dogged AP reporters who tracked him and more than 2,000 other victims to an island in Indonesia. Joshua and his Filipino crew mates were able to go home too, but Joshua later learned that his family never received a penny for his work on the scallop dredger. The road to sustainable, socially responsible fisheries that provide safe and secure livelihoods is long. It will take multiple stakeholders, working together, to change the global fishing industry’s labour practices. When the risks remain unknown, the lives, health and safety of thousands of men, women and children around the world are also at risk.

“It soon became clear that it would be no easy task to gauge the risk of forced labour, human trafficking, or hazardous child labour in seafood supply chains.

“The Risk Tool recommends engaging and supporting improvement efforts…

For more

Seafood Slavery Risk Tool

Seafood Watch

Sustainable Fisheries Partnership

Report of the Proceedings Enhancing Capacities of Fishing Communities: ICSF-BOBLME Sub-regional Dialogue on Labour, Migration and Fisheries Management, 11 to 13 December 2013, Thailand

Forced into Slavery

Better Fishing, Better Living