Original research carried out in July and October 2018; information verified and sections on feed certifications, Sanford, Mt. Cook Alpine Salmon, and Huon updated July-October 2020.
At Just Kai our bottom line is that fish, cocoa and sugar should be free of child and slave labour right back to the original boat or farm.
Within this, where possible we also:
The reasons behind these principles are explained in more detail here.
At the time that was written we were uncertain which (if any!) fish or seafood we could buy that would accord with those principles. We had become aware that slavery was rife in the fishing industry. People were being forced to work without pay both on the boats and in processing factories, child labour was being used, and there were plenty of disturbing stories of rape and murder, too. It was all pretty sobering.
A year later, we have good news! There are companies taking this stuff seriously, and there are brands you can buy in confidence :-) We have been in discussions with a number of companies over recent months and am keen to share what we’ve found with you.
In summary, here’s what we’ve found:
Download as a pdf to take with you as you shop :-)
Read on to learn why we came to these conclusions.
Salmon in New Zealand comes from three sources:
The ethical issues in wild-caught and farmed salmon are quite different, so I will treat them separately. In terms of farmed salmon, I will mostly deal with that farmed in New Zealand as that dominates the market here.
Wild-caught salmon essentially all comes from the Pacific Ocean - well over 2 million tonnes are harvested annually from the Pacific vs. only 2500 tonnes from the Atlantic (source). Pacific salmon is caught in five distinct locations:
Any tinned salmon is likely to be wild-caught; some packaged fillets and ready-meals are also wild-caught.
Alaskan salmon is caught in Bristol Bay. Salmon-fishing boats are restricted by law to no more than 32 feet in length. Working on them is clearly tough, but it seems to be work that people are freely choosing and, indeed, work that people encourage their friends and relatives into as the pay can be very good. I found no evidence of forced labour and also think forced labour would be hard to manage in this context: the fishing season is short and afterwards you’d need to find something else for the people you had coerced into working to do.
The fish is then generally processed locally. There have been some allegations of unsafe working conditions in factories - and the hours people work are phenomenal - but many people also speak of enjoying the stunning location and the impressive money you can make. Even the minimum wage really adds up when you’re working 16 hour days and getting time and half for overtime! Many people choose to come back year after year and encourage others to join them. I found no evidence of forced labour. Much of the workforce is migrants, with Puerto Ricans dominating.
British Columbian salmon is caught in the Skeena watershed. As with Alaskan salmon, it is caught from small boats. There are some safety concerns, but no forced or child labour concerns: these seem to be desirable jobs. And again, the factory processing jobs seem to be hard yakka but freely chosen.
Conditions for the US Pacific North-West seem similar.
I believe you can buy wild-caught North American salmon in complete confidence - so long as it was also processed locally. It won’t be supporting development in low income countries much (although it will help Puerto Rico), but you won’t be supporting child or forced labour either.
You do need to check that it is processed locally, however. Sometimes it is frozen then shipped to Asia for processing, and those factories sometimes use child and/or forced labour. If it’s not on my list and it doesn’t specify on the packaging that it was both caught and processed in Alaska then I’d advise you to contact the company for more information.
I have not come across any wild-caught salmon from either the Russian Far East or Japan being sold in New Zealand. However, I will cover these briefly in case someone else finds some (in which case, please tell me!) or in case it is of use to international readers.
There have been a significant number of cases of human trafficking and forced labour in the fishing industry in the Russian Far East, both on boats and in processing factories. I would not buy salmon from Russia unless the company was able to assure me that independent third parties had found these abuses were not occurring in their supply chain.
I wasn’t able to find any information about the Japanese salmon industry, so have no idea whether or not it is OK. I expect it is likely to be fine, so long as it employs local workers or foreigners on regular work visas. If any staff are members of the foreign “trainee” worker scheme there could be concerns: many such workers seem to have been somewhat deceived into their jobs and work for well below the minimum wage. I do not know if any of them work in the fishing industry but it would be worth asking about this (and about whether the processing is done locally or elsewhere in Asia) before buying.
We contacted John West, Sealord, Pams and Select (Countdown’s own brand) to enquire about the origins and processing of their salmon products, as they all seemed to include at least a portion that were wild-caught. All replied.
All John West’s salmon products - both those that say ‘wild caught Alaskan salmon’ and those that don’t - are wild caught in North America and canned locally there. They sell tinned pink salmon in a wide variety of flavours, tinned red salmon, salmon slices and salmon-based ready-to-eat meals. Note that there is a ‘John West’ brand in Europe that is owned by a different company from that which owns the ‘John West’ brand in Australia and New Zealand: we have no idea of the provenance of their salmon.
Again, all Sealord’s salmon products - both those that say ‘wild caught Alaskan salmon’ and those that don’t - are wild caught in North America and canned locally there. They also regularly visit the canneries, which are also independently audited for good labour practices. Sealord sells tinned pink salmon in a wide variety of flavours, tinned red salmon and plastic ‘pockets’ of flavoured salmon.
Sealord deserves a special mention as their Public Affairs and Communications Manager has been extremely helpful to us in this project. She has been very generous with her time, answering a large number of questions. It has been clear from the information she has provided that Sealord has a deep commitment to ensuring human rights are protected throughout the supply chain.
We don’t know where any Pams salmon is canned and we don’t know where the salmon that isn’t explicitly marked as ‘Alaskan’ is caught. All they were willing to say to us is: “All of our suppliers are expected to adhere to robust food safety standards and the relevant legislation, including labour laws, in place in either New Zealand or their country of business.” We do not recommend Pams salmon.
Most of Countdown Select’s tinned salmon is caught and processed in Alaska and hence is slave and child labour free. However, their 95g tins contain salmon caught in Alaska but processed in Thailand. Thai factories not infrequently use child and/or slave labour, however Countdown’s 2020 strategy states:
“We have an ethical sourcing policy which we expect all our suppliers to adhere to. Alongside Woolworths in Australia, we audit own brand factories based on considerations such as human rights and labour practices. We will build on our audit and compliance practice to ensure our supply chain accords with global best practice.”
As we can be confident of good labour conditions in the catching of this salmon, we think the above statement is good enough. The factory itself is the primary area of concern (not the upstream supply chain), and it is apparently audited for human rights and labour practices. In addition, by processing this portion of their salmon range in Thailand, Countdown is providing employment in a low income country, which is great.
Countdown Select does plain tinned salmon, as well as salmon in ‘smoke’, ‘lemon and pepper’ and ‘tomato and onion’ flavours.
Fresh, frozen and smoked salmon is likely to be farmed in New Zealand, as is any salmon marketed as ‘King’ or ‘Chinook’ or pushing New Zealand identity in the packaging.
New Zealand is a country with strong worker rights, and salmon farms are situated either on land or close in-shore so are easily accessed by labour inspectors. I do not expect to find cases of forced labour or child labour in salmon farms themselves. However, all salmon farmed in New Zealand is fed on feed containing fish meal and oil. This is generally made from quite low-value fish, meaning that margins are tight and slave labour is not uncommonly used on the fishing vessels used to catch the fish. Secondly, the mills used to turn the fish into meal and oil are often in countries with poor labour rights records and both child and slave labour are sometimes used in these facilities. So, the key question here is: does the farm know the feed they’re using is free of child and slave labour at these early stages of prodution?
Globally, the largest supplier of fish meal is Peru; they also seem to supply the bulk of the New Zealand salmon market. The fishers there are highly collectivised and the fish meal factories are very automated and require highly skilled labour. We have not found any reports of slavery there and it seems unlikely there would be any in such conditions. The US Department of Labour does, however, report that children are involved in ‘the worst forms of child labour’ in the industrial fishing sector in Peru. We think this is slightly misleading. The ILO definition of the ‘worst forms of child labour’ includes anyone under the age of 18 being involved in hazardous work. Peruvian law allows people to work on industrial fishing vessels from the age of 17. This is undoubtedly hazardous work and 17 year olds are still technically children so it does meet the ILO definition of child labour; however, we think it is very much at the ‘mild’ end of that spectrum. we are happy to buy fish fed on Peruvian fish meal: it’s slave labour free and close to child labour free and it provides employment to poor people :-)
The next largest supplier globally is the EU, which is also highly regulated: we have no concerns there. However, there are significant slavery concerns with one of the other major suppliers, Thailand. We would want to carefully check any fish meal or oil from Thailand, as well as probably any from Viet Nam or China, before having confidence in them.
If salmon farms wish to be confident their feed is free of both child and slave labour, they need to buy feed that is made from fish meal and oil that were both fished and processed in either Peru or the EU. Some farms have also cited that they use certified feed (certified by either Global G.A.P. or Best Aquaculture Practises (BAP)). Unfortunately, at this stage we do not feel either of these standards are robust enough to justify that confidence.
Global G.A.P. is a certification that covers many agricultural products including from aquaculture; to obtain it, not only must the farm producing the goods be certified, but so must all of their suppliers (and hence all of their suppliers, etc.). The standard requires regular audits and is, itself, governed by the standard ISO17065, which certifies standards are robust and impartial.
The aquaculture ‘compound feed manufacture’ standard mostly covers food safety issues but does also state (clause 15.2 of the standard):
When sourcing fishmeal and fish oil, the fishery and the production of fishmeal and oil shall be in compliance with the laws and regulations of the country of production and the country of destination related to fisheries.
We initially read that to mean the fish had to be caught and processed in ways that adhered to all the laws of both the production and destination countries. However, reading the documentation more carefully, it’s clear this only refers to fisheries laws - which cover things like catch quotas - rather than employment law. Just Kai doesn’t believe Global G.A.P. certification isn’t sufficient to guarantee basic human welfare in the highest risk stages of feed production.
The facility shall not source raw material from IUU fisheries. It shall have documented procedures of corrective actions in the event of usage of any raw material sourced from IUU fisheries and shall prevent recurrence.
IUU fishing is any fishing that is illegal, unreported or unregulated. However, ‘illegal’ here only means ‘breaking fishing regulations’ rather than ‘breaking any law’. So BAP certification has nothing to say about whether human rights abuses occurred at the fishing stage.
However, BAP certification applies directly to feed mills (not just to feed compounders), and does prohibit such mills (clauses 3.15-3.23) from using child or forced labour directly. They also need to have procedures in place for rehabilitating the people involved if these things are found to have occurred, and the standards are subject to unannounced third-party audits at least annually.
This is better than Global G.A.P., but still not good enough: there is still no checking for slave labour at the fishing stage.
We have asked all the salmon farms that belong to the Salmon Farmers Association of New Zealand about the source of their fish feed. This includes New Zealand’s two largest salmon farms (New Zealand King Salmon and Sanford Bluff Salmon), as well as three small ones (Aoraki/Mt. Cook, Akaroa and High Country). From this we have learned the following.
New Zealand King Salmon (which produces the brands Regal, Southern Ocean and Ora King) sources the bulk of their feed from Peru, with the balance being from the EU. This makes their feed supply very low risk for both child and slave labour. They seem well aware of the issue of human rights abuses in their supply chain and expect to choose feed suppliers who purchase from low-risk countries into the future. Their major feed supplier is Skretting Australia.
New Zealand King Salmon is also BAP 4-star certified,* so we can be confident they are buying feed from a mill that is regularly audited for child and slave labour.
* BAP certification comes in different versions, which are expressed in the number of accompanying stars. A 4-star certification indicates the feed mill, hatchery, actual farm and processing facility are all certified; with a 3-star certification the farm and processing facility are certified but only on of the feed mill and hatchery, not both. NZ King Salmon’s 4-star certification means they buy feed from a BAP-certified feed mill.
Just Kai is happy to recommend NZ King Salmon’s products.
Sanford, like New Zealand King salmon, buy their feed from Skretting Australia, and hence are also buying feed where the original fish was caught in the EU or Peru. They are BAP 3-star certified (where the third star is for the feed mill, not the hatchery), so they have an ongoing commitment to buy feed from certified mills. We are slightly less confident to recommend them than New Zealand King Salmon as they don’t seem to have an ongoing commitment to buy fish sourced from low-risk countries, but we are happy to recommend them at this stage.
Mt. Cook Alpine Salmon (who are also responsible for the smoked salmon brand Aoraki) purchase their feed from Skretting Australia. This means the fish used in their feed were caught in either the EU or Peru and so are at low risk of human rights abuses. Also, like New Zealand King Salmon, Mt. Cook Alpine Salmon has BAP 4-star certification, meaning they have an ongoing commitment to buying feed from mills where human rights checks are carried out.
Just Kai is unaware of Mt. Cook Alpine Salmon having made any ongoing commitment to exclusively buy fishmeal sourced from low-risk countries into the future, but we are confident their products are currently at low risk of slavery and child labour in their supply chain. Just Kai recommends the Mt. Cook Alpine Salmon and Aoraki salmon brands.
Akaroa uses feed supplied by Ridley. Ridley is at least somewhat aware of the issues, and have a policy of ”not sourcing raw materials from suppliers which have been linked to the use of slave or child labour (or any contravention of human right laws). Wherever possible this is confirmed by third-party audit of the suppliers operations.” From this, it seems unlikely that regular audits are carried out, which is less than ideal (they didn’t reply to clarification questions on this). However, they did also assure us that they don’t use any Thai-sourced fish due to the human rights issues there. This suggests Ridley’s feed (and hence Akaroa’s salmon) is at reduced risk of slavery or child labour in its supply chain, but we can’t be confident those practises didn’t occur as Thailand isn’t the only risky country.
Akaroa has also made no ongoing commitments to source feed from suppliers that check for human rights abuses and didn’t seem particularly aware of these issues. We do not recommend Akaroa salmon.
High Country didn’t reply to our enquiries and has no information on their website about where they source their feed. We do not recommend their products.
If you purchase salmon from the fish counter in PakNSave or New World supermarkets, that salmon will either come from New Zealand King Salmon or Sanford Bluff Salmon. It is child and slave labour free and has been fed on feed that has likely provided employment to poor people in Peru: you can buy it in confidence :-)
If you purchase salmon from the fish counter in Countdown supermarkets, that salmon will have either come from New Zealand King Salmon or from Huon (discussed below) in Tasmania. Any of these products are likely to be child and slave labour free, and to be giving jobs to people in low income countries - they are all fine to buy.
If you are purchasing salmon from the fish counter of one on the major supermarkets and have a choice of which one to buy from, I recommend you choose Countdown. Currently, salmon from any of them are child and slave labour free; however, Countdown have made a commitment to try to eliminate labour abuses from their supply chain and told me they chose Huon and NZ King Salmon because they have made similar commitments. Salmon from them is thus likely to continue to be child and slave labour free into the future. Foodstuffs (i.e. PakNSave and New World) has made no such commitment so may well change to other suppliers with worse practices in the future.
Salmon farmed overseas is usually labelled ‘Atlantic salmon’; if it’s packaged, it may also state on the ingredients list that it is farmed (and where).
The vast majority of salmon farmed globally comes from two countries: Norway and Chile. I have not come across any worker abuse associated directly with Norwegian salmon farming (and don’t really expect to, as the Norwegian industry is highly regulated and collectivised). The situation is different in Chile, where worker abuse of various kinds (including in Norwegian companies operating in Chile) has been reported, although not actual forced or child labour.
As with New Zealand farmed salmon, abuse can also occur in the fishing and processing of feed for the salmon. If you want to buy salmon farmed overseas and it comes from Chile, you’ll need to ask about worker treatment in feed production (i.e. on the boats and in the feed mills) as well as on the farm; for Norwegian salmon only the first two of these are likely to be relevant.
Ocean Blue has not replied to my queries so I don’t know whether or not their products are slave and child labour free. It is fairly likely that they are, as the EU does attempt to ban the import of products where forced labour has occurred, but I can’t be sure without Ocean Blue publishing information or replying to my queries.
Huon sources their feed through two suppliers: Skretting Australia and BioMar Australia. They have a clear and ongoing commitment to human welfare throughout the supply chain, and have chosen their suppliers on this basis.
As discussed earlier, Skretting obtains most of their fish from Peru, with the balance coming from the EU: we are not concerned about slavery in Skretting’s supply chain.
Biomar mostly uses fish from Peru, Chile, the North East Atlantic and the North Sea, with small quanitites of fish from other sources. They publish detailed information on which species are used and where they are caught, suggesting they have good visibility of their supply chain. Most their fish are caught in low-risk regions, but Chile is of some concern. However, Biomar has told us that suppliers must adhere to the following:
1) Freely Chosen
Forced, bonded or indentured Labour or involuntary prison Labour is not to be used. All work will be voluntary. Workers shall not be required to hand over government issued identification, passports or work permits as a condition of employment.
2) Child Labour
Child Labour is not to be used in any stage of the value chain. The term “child” refers to any person employed under the age of 15 or higher if required in the respective country. Seasonal employment of workers (other than occasional experience by students on school holidays according to local custom) is included under this policy. Workers under the age of 18 shall not perform hazardous work and may be restricted from night work with consideration given to educational needs.
Suppliers are assesed to determine their Modern Slavery risk and audits are regularly conducted by Supplier Approval, Audit and Traceability team. Whilst we would prefer third party audits (and a bit more information on how often given suppliers are audited), this feels more than sufficient for a company operating exclusively in low and medium risk environments.
Huon itself is Global G.A.P. certified, so its own facilities are regularly audited for human welfare conditions, as are the factories in which their fish feed is produced.
We recommend Huon’s products, which are available in Countdown and possibly elsewhere. They are also one of the suppliers for salmon from the fish counters in Countdown supermarkets.
Note that I have since published a separate guide on pet food with fish in it.
A lot of cat food turns out to include salmon, as do a couple of brands of dog food.
It is quite difficult for pet food brands to be confident of the provenance of their fish supplies as they generally use waste left over from human food production. It often arrives as scraps or even meal and it can be hard to know all the stages it has been through before arrival. It could be argued that it is good, from an environmental standpoint, that these products are used rather than wasted, so it doesn’t really matter where it came from as at least it’s being used. I have some sympathy for this argument, but still would prefer products to be made from the waste of more ethically caught fish if at all possible, as that increases the size of the ethical fish market.
The majority of the brands I contacted to ask about the provenance of their salmon did not get back to me. I contacted Nestle (owner of the brands Purina, Fancy Feast and Friskies), Kraft Heinz Watties (owner of the brand Chef), Temptations, Dine, Applaws, Gourmet and Whiskas. Of these, only Nestle, Applaws and Kraft Heinz have replied so far.
Nestle (i.e. Purina, Fancy Feast and Friskies), were fantastic. They are well aware of the labour abuses occurring in the fishing industry and have taken substantial steps to avoid supporting them. They:
Yay for commitment, transparency and concrete action!
In addition, activist Andy Hall tells me that Thai Union, the company that processes all fish used by Nestle in their pet food, has the best human rights practices of any Thai fish processing company.
All that makes the Nestle brands my preferred choice: not only do they not (as far as can be ascertained) use child or slave labour in their pet food supply chain, but they are giving jobs to vulnerable poor people (mostly migrants from Cambodia, Myanmar, Laos and Viet Nam), and those jobs come with better working conditions than those in other fish factories. Go Nestle!
I also heard back from Applaws, who make It’s all good ocean fish and salmon cat food and Applaws dog food with salmon and kelp, both of which contain salmon meal. Applaws have an ethical policy that includes good “workforce rights” policies which are backed up by onsite visits either by their suppliers or by their parent company, MPM Products Ltd. It was not clear to me whether their workforce rights policies cover workers on boats, or whether they are just relevant to workers at processing facilities. However, for wild-caught salmon the dominant human rights issues occur in factories, rather than on boats, so I am happy to recommend Applaws’ salmon-containing products.
Kraft Heinz Watties (i.e. Chef), on the other hand, was most unsatisfactory. They told me that they source salmon “from various suppliers throughout New Zealand” and that “Kraft Heinz is an ethical company and adheres to all the employment regulations.” That doesn’t tell me anything about labour abuses occurring before the fish even arrives in New Zealand, which is where the bulk of the problems occur. I have asked them whether they do anything to check on conditions throughout their supply chain, and will update this if they come back with anything more. For the meantime I wouldn’t buy Chef salmon-containing products (or any of their fish-containing products, for that matter, as I had asked about all of them in my email).
New Zealand King Salmon (discussed above) also have a pet food brand, Omega Plus, made using the same highly ethical salmon they use for their human food :-) The Omega Plus range includes dog as well as cat food.
There are a lot of multi-ingredient products that contain salmon (salmon-flavoured cream cheese, ready-made meals containing salmon, salmon sandwich spreads, fish cakes etc.). In general, these were the only salmon-containing product a particular brand made; I didn’t email these brands as it would have been a lot of effort for not much gain.
However, I did notice that Bird’s Eye makes salmon-containing fish cakes. These are likely to be fine as Simplot (the owner of the Bird’s Eye brand in Australasia) is a signatory to the Australian Retailer and Supplier Pledge against Forced Labour. As part of this they have joined Sedex (a system that helps businesses trace goods through their supply chain) - so it’s not just empty words.
Phew! That’s a lot to take in. But I’ve summarised the key information in this pdf that you can download and take with you when you shop.