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.
The following tables contain the same info as above but in a larger font that 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 (initially included Seafish and Fishwise but they went their own way)||Board is comprised of compliance executives|
|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:
|Labor Safe Screen
|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 Tool
|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 2
High 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 Template
|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.|