Original research completed July 2019; latest update August 2022.

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:

  1. identify goods produced in low income countries (as buying those increases employment opportunities there);
  2. identify which goods are produced in the best labour conditions available (supporting those brands will increase the pool of good jobs people have to choose from).

The reasons behind these principles are explained in more detail here.

When buying marine oils this can be challenging: these are highly processed products and it can be quite hard to know where they come from. However, if you want to support your health with fish oil, codliver oil or other omega 3 supplements but also want to treat your global neighbours well, we have good news!

If you want to buy marine oils that are free of child and slave labour, restrict your buying to:

If you want to support job-creation in low-income countries at the same time, buy products from Blackmores or Ethical Nutrients: they carry out more of their operation in low-income countries than others.

Our findings are summarised in the graphic below:

graphic that says all fish oil and omega 3 supplements from Ethical Nutrients, Blackmores, Swisse are slave free; as is cod liver oil from Blackmores or Nordic Naturals and Alaskan salmon oil from Solgar; also says that all brands of vegan/algae omega 3 oil and New Zealand green-lipped mussel oil are fine.

Download as a pdf to take with you when you shop.

Read on to learn why we came to these conclusions.

Fish oils and omega 3 supplements are often made from fish scraps: tuna carcasses, sardine heads, cod livers etc. This can make it hard even for the fish oil companies to know the conditions under which the original fish was caught. However, it is very important that working conditions are monitored, difficult though this is. Fish require a lot of oil in their bodies when they live in cold conditions: this means that fish oil fish are often deep-water species living far from land. The fishing vessels that catch such fish tend to stay out to sea for months or even years on end: conditions that make slavery much more likely. If you want to buy fish oil and omega 3 supplements that are free of slavery it is very important that you either choose oil from low-risk species or from companies that monitor conditions both at sea and in processing facilities.

Table of Contents

Issues

Fishing and farming

Most come from various kinds of fin-fish, but there are also mussel, krill, algae and even plant-based options. These are each discussed separately below as the issues in their fishing and farming are quite different.

Finfish

With the exception of cod liver oil, fish oil supplements are generally not labelled with the name of the fish the oil came from. The most common fish used are anchovies and sardines, although mackerel, tuna and even salmon are also sometimes used.

Cod

Cod refers to one of two fish species: Pacific Cod or Atlantic Cod. Both are used to make cod liver oil. They are bottom dwellers and live in huge schools. Pacific cod grow up to 49cm and Atlantic cod to 2m. Cod are caught using a wide range of fishing methods including hook and line gear, pots, bottom trawls and gillnets.

Atlantic cod caught in Scandanavia are at low risk for child and forced labour; however Atlantic cod caught in Russia are considered to be at high risk. There haven’t been any specific cases of forced labour reported from the Atlantic cod industry as such, but such reports are widespread throughout the Russian fishing industry so no fishery can really be considered safe.

Pacific cod are caught on the North American west coast, around Japan and in the Russian Far East. As previously discussed, no Russian-caught fish can be considered slave free. Japanese-caught fish is also at high risk of forced labour (especially when the fish is caught well out to sea, as is the case with Pacific cod). Pacific cod from the US or Canada, on the other hand, should be fine: we have found no specific evidence of forced or child labour in the cod industry in either country, and their fishing industries are generally considered to be low risk.

In summary, with cod it is important to ask where it is caught. If it came from Scandanavia or the US west coast it should be fine. If it came from Japan or Russia you will need to ask further questions before you can be confident it is slave free.

Anchovies

Anchovies are small oily fish of the family Engraulidae. They are commercially fished in the Atlantic and Pacific oceans as well as in the Mediterranean and Black Seas. There are six commercially fished species, of which Peruvian anchovies (also called anchoveta) are dominant. Anchovies are mostly caught within 80km of the coast, although they can be found much further out. They are mostly caught by purse seine nets although mid-water trawling is also used.

As anchovies occur reasonably close to the coast, their fishing is at reasonably low risk of slavery: fishing vessels that fish so close tend to come to shore reasonably often, making it harder to keep people trapped on them.

In addition, anchovies from Peru (by far the dominant source globally) are at extremely low risk of forced labour as the fishers there are highly collectivised. We have not found any reports of slavery there. In terms of child labour, 17-year-olds are allowed to work on Peruvian industrial fishing boats, which violates ILO regulations against child labour as this is considered hazardous work. However, we do not consider this a major violation as the age limit in Peru is only one year younger than what the ILO considers acceptable. We thus consider Peruvian anchovies slave-free.

Chilean anchovies (the other main South American source country) are also at low risk for both child and forced labour, as are European anchovies. However, anchovies from Asia are at much higher risk. Both child and forced labour is common in both the Indonesian and Thai anchovy fishing industries.

As with cod, it is important to ask where your anchovies were caught if you want to know they’re slave free. If they were caught in South America or Europe they should be fine; if they came from Asia you will need to ask further questions.

Just Kai has already covered human welfare issues of salmon, sardines, mackerel and tuna fishing in previous guides. Read those for more detail but, in brief:

Sardines

Sardines generally occur within around 15 km of the coast so sardine fisheries are only at moderate risk for worker abuse: labour rights risks always increase the further you are out to sea. However, child labour is used in some regions to spread purse seine nets to catch sardines, and sardines in Indonesia are caught by blast fishing, where child labour is extensively used.

Sardine oil is often made from sardine heads.

Mackerel

Mackerel are found throughout the world in deep water well out to sea. As with any deep-water fish, mackerel fishing is at high risk for forced labour as the fishing boats tend to be out at sea for long periods of time.

Tuna

Tuna is, similarly, found in deep water well out to sea. Transshipping, where fish are transferred from the fishing vessel to a cargo vessel that carries them back to land, is common, meaning that tuna boats often stay out at sea for 1-2 years at a time. This makes them at extremely high risk for forced labour. In addition there have been many cases of very serious abuse occurring on tuna fishing vessels: starvation, severe beatings, rape and even murder are well documented. Children frequently work on tuna vessels as cooks and women are sometimes also forced into sex slavery there.

Tuna oil is also commonly made from tuna waste, making it hard to always trace the source of the original fish.

Salmon

Wild-caught salmon from North America is at extremely low risk of forced and slave labour - oil from that source will be fine. Wild caught salmon from the Russian far East, however, could well have been caught with forced labour. Farmed salmon is fed on fish meal made from wild-caught fish, so farmed salmon is only slave and child-labour free if that fish meal has been audited for working conditions in its supply chain.

Salmon oil is generally made from salmon heads, not whole fish.

New Zealand green-lipped mussels

Several companies are selling capsules of green-lipped mussel oil. These all use farmed mussels and all are at very low risk of child and forced labour. New Zealand is a country with strong worker rights, and mussel farms are all situated close in-shore, so are easily accessed by labour inspectors. I have not found any cases of forced labour or child labour in mussel farms and do not expect to in the future.

In addition, mussels are not fed on commercial feed: instead, they subsist on algae that they filter from the water in which they are growing. This means that, unlike farmed salmon, there are no worker welfare concerns in the supply chain of their feed.

Krill

Krill oil supplements are made from Antarctic krill, Euphausia superba. These are small, swimming crustaceans (about 6cm long) found around Antarctica. They must be processed within a few hours of being caught, so are typically caught by trawlers with onboard factories or by trawlers working in conjunction with factory ships. Vessels typically stay at sea for months at a time (longer if they are transferring their catch to other vessels for processing and transport) and work far from any inhabited land, making this a very high-risk fishery from a forced labour point of view.

By far the majority of Antarctic krill is currently caught by Norwegian vessels (60% in 2019), with being caught by vessels from China, South Korea, India and Ukraine. Of these, South Korean vessels have a particularly bad history with forced labour and Chinese vessels are also of concern. If your krill oil is of Norwegian origin it is likely to be fine (and, handily, the majority is), but if it comes from elsewhere you’ll need to ask further questions.

Algae

Fish don’t actually produce omega-3 fatty acids: they get them from eating algae. This same algae is now grown in vats on land, with the oil ready for extraction after a few days. Much of this oil is grown in the US, but some also comes from China and other countries. As this is grown on land it is at low risk for forced and child labour; however, it is still a good idea to ask where it comes from before buying. Forced labour is still legal in some contexts in China, in particular. We haven’t found forced labour in the supply chains of algal oils in particular, but we have found it sometimes used in similar industrial products.

That said, Just Kai recommends algal oil as it is a fish-free product.

Plants

You will also find omega 3 supplements made from seeds: sunflower seeds, canola seeds, flax seeds, chia seeds etc. These haven’t been considered in this research as, unlike algal omega 3 supplements, plant-based omega 3 supplements aren’t really equivalent to fish oil-based supplements. Plant-based oils contain an omega-3 fatty acid called ALA; fish oils contain ones called EPA and DHA. This difference is important, your body processes the different oils quite differently. We’re only considering fish oils and identical equivalents here.

Processing and manufacture

Fish oils spoil rapidly: they need to be extracted from the fish promptly and then stored away from oxygen and certain metals. The extraction generally involves cooking the fish, pressing to remove the oil and then purification of the oil. This leaves a by-product of fish meal that can then be sold either to aquaculture companies, pet food manufacturers or as fertiliser.

For fish caught far out to sea (e.g. tuna, mackerel and krill in all cases, as well as sometimes sardines and cod) this processing occurs either on the fishing vessel itself or on a nearby dedicated factory ship. For coastal fish such as anchovies and some sardines (or Scandanavian cod, where the fish occur in deep water that is, nevertheless, near to land) this processing occurs on land.

We are confident working conditions will be fine on any Norwegian factory ship: they are usually out to sea for five weeks or less and are from a country with reasonably good labour standards. We have come across reports of Norwegian labour laws being circumvented to some extent by various fishing companies, but none of actual forced or child labour. However, this only applies to fish that is caught on Norway. Norway is also a significant hub for the reprocessing of fish oils. Oils reprocessed in Norway, regardless of where or how the fish was caught, are typically marketed as Norwegian. Just Kai is confident any fish caught and processed from the beginning in Norway will be slave free - the same doesn’t apply to oil simply reprocessed there. Make sure the company selling your oil describes it as having been caught in Norway, not simply as being ‘from’ Norway.

Land-based fish oil factories are not generally at high risk of forced or child labour; however such practices occur widely in Thai fish processing factories. Fish oil factories at sea, on the other hand, carry the same high worker welfare risks as any other fishing vessel that is out at sea for months at a time.

If your fish oil brand doesn’t use a certification which checks labour conditions in factories, see if you can find out which species are used and where they were processed. Krill, tuna and mackerel-based oils are all always at high risk for forced labour: don’t buy these unless abuses have been checked for. Scandanvian cod is at very low risk (due to the strong labour laws in that part of the world and the fact that such cod is generally processed either on land or on well-regulated ships) and can be bought uncertified. Anchovies, sardines and salmon are at much lower risk at the processing stage, but you shouldn’t buy uncertified oil from these species if it was processed in Thailand.

Tools that can help companies

Fish oils are often aggregated: oils from different fish and different fleets can end up in the same barrel. This can make it difficult for companies (especially smaller ones) to know whether their supply chain is slave and child labour free. However, there are some tools that can help with this.

Friend of the Sea (FoS)

Friend of the Sea is an organisation primarily focused on certifying the environmental sustainability of a wide range of marine products. Their fish oil standard (and many others) do, however, include the provision that all workers must be paid the legal minimum wage and that there must be no child labour. These standards are audited by bodies approved of by Accredia before certification is granted and again within 12 months; certification lasts for three years.

However, there are two significant limitations with FoS certification:

  1. From their certification procedure document: “Friend of the Sea social accountability criteria is only included in accreditation procedures for countries adhering to the agreements of the International Labour Organization (ILO).” (section 2, p.6) In other words, if a fishing vessel is flying the flag of a non-ILO country, they have no obligation to pay a minimum wage (or anything at all) or to have a minimum age for workers. They will get FoS certification regardless. There are, admittedly, very few non-ILO member countries (I believe the full list is Andorra, Bhutan, Liechtenstein, Micronesia, Monaco, Nauru, and North Korea); however that list includes both Nauru and Micronesia - countries with significant fishing industries. Friend of the Sea has assured Just Kai that they are currently not certifying any oils derived from fish caught by non-ILO countries (September 2019), but until this clause is removed there remains a risk that Friend of the Sea certified oils could have been made from fish caught with child or forced labour
  2. Whole fish used for fishmeal must come from FoS certified fleets (so will have social accountability criteria if ILO members) but certified fish oil can also be made from “Fish by-products from fish processing and or/aquaculture and/or discards” - none of which needs to come from certified fleets (see clause 5.1 here). This is not reassuring. With the exception of krill and anchovy oil, fish oil is generally made from some kind of discard: tuna waste, salmon heads, sardine heads, cod livers etc. So FoS certification presumably is very commonly granted to fish oil where the fishing vessel wasn’t certified.

FoS certification is a good solution for companies who have other reasons to believe their fish oil comes from whole fish fished by vessels flagged to an ILO member country. However, it is not so useful for consumers. Consumers generally don’t have access to information about how the fish was caught, and most fish oil isn’t made from whole fish and so is exempt from FoS social accountability criteria. Consumers can trust FoS certification for krill oil, as krill oil is always labelled with the species, all the major krill-fishing nations are ILO-signatories, and krill oil is always produced from whole animals rather than discards. In all other cases FoS certification is insufficient to indicate to consumers that the oil is slave free.

MarinTrust Standard for Responsible Supply (formerly IFFO-RS)

The largest fish oil industry body, IFFO, was concerned about the prevalance of modern slavery in their industry and responded with a responsible sourcing standard (formely IFFO-RS) that is now administered by MarinTrust. Section 5 of the standard guarantees that all workers are paid a legal minimum wage, that no one below 15 is hired at all and that no one 15-18 is hired full time or “engaged in work that is dangerous to their health and safety that jeopardises their development or prevents them from finishing their compulsory school education.” There are also conditions related to health and safety and allowing workers to unionise. To remain certified, a facility needs to pass three-yearly full audits; there are also annual surveillance audits.

This is thus a stronger standard from a worker welfare point of view that FoS, with one very large caveat: it only applies to factories. Fish processed at those factories must be both legally and sustainably caught, but there are no audits of what happens on boats.

IFFO-RS certification provides companies with strong guarantees of welfare conditions in the fish oil factories, but should only be relied upon where companies have other reasons to believe conditions of fishing vessels also meet basic minimum labour standards.

Sedex Members Ethical Trade Audit (SMETA)

Members of SEDEX (the Supplier Ethical Data Exchange) have access to a further tool: the Sedex Members Ethical Trade Audit. This isn’t a certification as such: it’s a carefully thought-through audit process members can apply on their own behalf in order to verify what is going on in their supply chain. Results of the audit will then be made available to other SEDEX members through their database.

The SMETA audit comes in two versions: the four-pillar audit covers Labour, Health and Safety, Environment, and Business Ethics; the two pillar audit only covers Labour, and Health and Safety. Both audits look for child and forced labour as well as freedom of association, health and safety, a living wage (or legal minimum if that is higher), reasonable working hours (48 hour week, 60 with overtime), non-discrimination etc.

Audits may be announced (although unannounced audits are encouraged); their frequency should be determined based on the risk level of the operation - annual for high-risk, less frequently for lower risk.

It is up to the company how deep into their supply chain they apply the audit: however, SMETA audits are an excellent tool for companies that wish to really understand what is happening in their supply chains.

Prominent New Zealand fish oil and omega 3 supplement brands

Just Kai has contacted the following fish oil and omega 3 supplement brands: Nutra-Life, Swisse, Blackmores, Good Health, Nordic Naturals, Solgar, Clinicians, Healtheries, Ethical Nutrients, Nature’s Way, Cenovis, Red Seal, GO Healthy and Bioglan. Of these all but Nature’s Way, GO Healthy and Bioglan replied to us.

Of these companies we are reasonably confident all products produced by Blackmores, Ethical Nutrients and Swisse are slave free.

We are also confident of the cod liver oil produced by Nordic Naturals and the Wild Alaskan salmon oil produced by Solgar. As discussed earlier, Just Kai also considers vegan/algae omega 3 oil and New Zealand green-lipped mussel oil to always be slave free, regardless of the manufacturer.

Continue reading for a discussion of individual brands or jump to our recommendations in individual product categories.

Blackmores

Blackmores logo

Blackmores has no information about worker welafre on their New Zealand website; however, there is a 2020 Modern Slavery Act statment on the website of their parent company, Blackmores Australia. Our assessment is based on this statement.

From the Modern Slavery Act statement we learn that:

  • Blackmores is assessing the risks of Modern Slavery in all direct suppliers (p.14); those suppliers deemed to have a high risk of slavery in their operations are audited using the SMETA 4-pillar process (discussed here). They note (p. 15) that fishing is a high-risk industry when it comes to slavery.

    • At the time of their 2020 report, a risk assessment had only been done on 25% percent of Tier 1 suppliers, and only one had had a SMETA audit (p. 17). We would hope to see considerable improvement in that over time, but that seems like a good start for what is a new process - especially as access to many facilities is currently limited because of Covid-19 protocols.

  • In high-risk areas, they assess slavery risk in those who supply their suppliers, as well as companies that supply them directly. In 2019/2020 one such supplier was audited using the SMETA process. It is important that they are looking beyond their immediate suppliers like this, as we see on p. 10 that they purchase marine oils, rather than fish. As the company that has caught the fish is not necessarily the same as the company that refines the oil it is good they are looking deeper than the first step of the chain.

  • All new suppliers have to commit to being slave-free; 97% of existing suppliers have also agreed to this, and they are working on ammending their contracts with the remainder (p.17).

  • They have an anonymous whistle-blowing system, Speak Up, to facilitate reporting on inappropriate and illegal behaviour in their own facilities and their supply chain (p.13).

We also learned from Blackmores in 2018 that they contract the British Standards Institute to do SMETA 4 pillar audits on fishing vessels when in port. The audits are ‘announced’ (i.e. the vessel staff know when auditors are coming), which is not ideal but is still more than most companies are doing. Audits check not only for child and forced labour but also freedom of association, health and safety, living wage (or legal minimum if that is higher), reasonable working hours (48 hour week, 60 with overtime), non-discrimination etc.

This is all very encouraging. Blackmores is clearly aware of the high-risk nature of their marine supply chain and, whilst we would prefer them to do unannounced audits, they are still doing fare more than most. We also appreciate that they are monitoring risks of slavery throughout their supply chain and are moving to audit all risk points. We are happy to recommend their products.

We also appreciate the collaborative approach that Blackmores is taking to addressing Modern Slavery. They have convened and chair the Complementary Medicines Australia Modern Slavery Working Group: they run webinars for their suppliers to teach them how to identify and prevent Modern Slavery (p. 17).

Just Kai recommends all Blackmores products containing fish oils. They produce several different fish oil formulations, fish oil containing products to meet a range of needs (kids’ health, pregnancy, joint health etc.) and cod liver oil capsules.

Ethical Nutrients

ethical nutrients logo

Ethical Nutrients doesn’t have anything on their website about working conditions in their fish oil supply chain. From correspondence, Just Kai initially learned that they only use Friend of the Sea certified oils. They didn’t answer our question as to whether they only use oil from whole fish so we presume they do not: using whole fish - except for krill and anchovies - is unusual.

We also learned that the majority of their oil comes from Peru, but that the balance comes from Chile, Morocco and the Black Sea; they also stated that they only use fishing vessels flagged to the country in whose waters they are fishing.

As discussed in a previous guide, Just Kai is reasonably confident any fish from Peru will be slave free. There is a chance it will not technically be child labour free (as 17-year-olds are permitted on fishing vessels under Peruvian law), but we are generally OK with that - it’s not a particularly severe form of child labour.

In addition whilst child labour has been identified in the Chilean fishing industry, it is unclear whether this happens on boats or on land, and Chile is generally considered at low risk for forced labour in fishing. As child labour is generally more common on land than at sea, and Friend of the Sea certification means that what is happening on land is being actively assessed, we are also OK with Chilean-sourced oil in this context.

We have found reference to child labour in the fishing industry in Morocco, but not to forced labour - and Morocco is, in general, making good progress on forced labour at the moment. Again, as child labour isn’t so commonly an issue on fishing vessels, the Moroccan oil is reasonably likely to be OK.

We have found no references to forced or child labour in Black Sea fishing at this stage.

This seemed encouraging, but not great: they looked like a low risk supplier, but some audits would be good. However, they made mention of having chosen a supplier that was strict on a number of ethical issues, including both child and forced labour, so we asked for more information on that.

They replied that their supplier uses a third party to audit their supply chain for both child and forced labour. Some audits are on a formal cycle and some are random. Their business has been awarded EcoVadis CSR Gold status for their efforts, which reflects their strong stance on labour and human rights (as well as many other factors).

That is excellent news! An external auditor is more likely to find issues than an in-house one, as are random audits (as opposed to planned ones).

Just Kai is very confident Ethical Nutrients fish oils will be slave free and is happy to recommend them. Ethical Nutrients sells omega 3 fish oil capsules and flavoured oils.

Swisse

Swisse logo

Swisse have no information on their website about working conditions in the supply chain of their fish oils.

From correspondence with them we have learned that all Swisse fish oils are Friend of the Sea certified. They also told us that they source their fish oil from “South and Central America, Africa and the Mediterranean” and that is made from whole sardines, anchovies, mackerel and tuna. That was excellent news. As noted above, Friend of the Sea certification for fish oil only covers working conditions on fishing boats if two conditions are met: that the boats are flagged to ILO member countries and that whole fish are used. It seems Swisse meets these conditions :-) Swisse is using whole fish, and Friend of the Sea has informed us (July 2019) that they are not currently certifying any fish caught by vessels flagged to non-ILO countries. This could change in the future, but that seems unlikely in this case as Swisse is clearly a company that favours long-term relationships with suppliers.

Just Kai recommends all Swisse products. Swisse produces odourless fish oil in two strengths.

Clinicians

Clinicians logo

Clinicians sell two marine-derived supplments: omega-3 capsules, and ReJuvenate (which contains marine collagen). At this stage we are only assessing omega 3 oils, so we have no position on whether or not ReJuvenate is slave-free.

There is no information on their website about the sourcing of their products, however we have learned from correspondence (August 2022), that they do require direct suppliers to sign a code of conduct that requires them not to use forced labour or child labour. However, as the most severe abuses in the fish oil industry occur on fishing vessels and in the first processing step (where crude oil is produced), and fish oil companies tend to buy refined oil, this is unlikely to be sufficient to prevent the use of forced labour or child labour in their supply chain.

They did tell us that their omega-3 supplements are made from fish oil that is IFFO and FoS certified. As discussed above, IFFO does not involve audits of fishing vessels, so is not recommended. FoS only covers fishing vessels where the fish oil is made from whole fish (not discards). They informed us that their fish oil is made from tuna, which means it will be made from discards. This means we cannot recommend their fish oil at this stage.

They also sell an algal oil product. As with all algal oils, Just Kai considers Clinicians’ algal oils to be slave free.

Just Kai currently recommends Clinicians’ algal omega 3 only.

Nordic Naturals

Nordic naturals supplies a variety of marine oil products, including algal oils, cod liver oil and fish oils. Their fish oils (including the cod liver oil) are all Friend of the Sea certified. This means they come from audited factories and that the fishing vessels will have been audited so long as they are flagged to an ILO-signatory country and supply factories with whole fish.

As with all algal oils, Just Kai considers Nordic Naturals’ algal oils to be slave free.

From their website, we learn that their cod liver oil is caught in Norwegian waters and is Friend of the Sea certified (which means the processing was slave free). Just Kai considers this to be slave free.

There is no other information on their website about the sourcing of their other fish oils. This means we cannot be confident that Nordic Naturals fish oils (other than their cod liver oil) are slave free. Everything is Friend of the Sea certified, but fish oil is often made from discards and Friend of the Sea don’t audit fishing vessels if they are only providing discards to fish oil manufacturers. In addition, several Pacific states aren’t signed up to the ILO. Vessels flying flags of non-ILO member countries don’t need to meet Friend of the Sea human rights criteria in order to be certified by them. Currently (July 2019), none of the suppliers Friend of the Sea certifies fly non-ILO flags, meaning that any oils Nordic Naturals sell that are made from whole fish caught in the Pacific are currently fine. However, that could change in the future if Nordic Naturals continues to source Friend of the Sea certified oils but changes to a supplier that flies the flag of a non-ILO member state.

We have contacted Nordic Naturals and asked for further information: we will update our recommendations if/when we hear from them. However, at this stage Just Kai recommends Nordic Naturals’ algae omega 3 oils and their cod liver oil range, but not their general ‘fish oil’.

Nutra-Life

Nutra-Life produces fish oils from mackerel, sardines and anchovies. From their website we learn that these oils are IFFO-RS certified and are processed in Norway; all fish are processed within 24 hours of being caught, and are caught under strict EU fishing regulations.

However, the fish are clearly not caught in EU waters: they are caught in both the Eastern Atlantic and Eastern Pacific. The ‘Eastern Atlantic’ may mean Scandanavia, but more likely means West Africa; the Eastern Pacific is the east coast of the Americas so is definitely not European.

The strict EU fishing regulations referred to (EU hygiene regulation EC 852/2004) exclusively relates to food safety, so doesn’t tell us anything about the working conditions on these fishing vessels.

Similarly, IFFO-RS certification tells us practically nothing about working conditions on the fishing vessels.

Just Kai cannot be confident Nutra-Life fish oils are slave and child labour free and does not recommend them.

However, Nutra-Life also sells oil from New Zealand green-lipped mussels under the trademark Biolane. As with all green-lipped mussel oil, Just Kai is confident this is slave and child labour free. The farming of mussels occurs in New Zealand and is extremely likely to be slave free; due to the perishability of the product, the mussels will also be processed in New Zealand, which has strong labour laws.

Good Health

Good Health have no information about worker welfare on their website. When we enquired, they said they would contact their suppliers and get back to us, but there has been no further contact.

Good Health do sell New Zealand green-lipped mussel oil (which, like all NZ green-lipped mussel oil, will be slave free); however Just Kai doesn’t recommend any other of their products.

Solgar

Solgar produce fish oil (from anchovies and sardines), Wild Alaskan oil (from salmon) and cod liver oil. There is no information on their website about worker welfare considerations in the sourcing of this oil. When we contacted them, they told us at length about the quality control mechanisms they employ to keep their customers safe, but made no mention of worker welfare.

Because their salmon oil is produced from fish wild-caught in Alaska (a very low risk fishery), and because fish oil factories are generally at low risk for forced labour, Just Kai is confident Solgar’s Wild Alaskan oil is slave and child labour free. We do not, however, recommend their fish oil or cod liver oil as these are much more risky fisheries and we have been provided with no assurances with regards to working conditions.

Healtheries

Healtheries has statements about sustainability on their website, but nothing about labour conditions. From correspondence we have learned that all their oils have either IFFO-RS or FoS certification and some have both. That means we can be confident minimum labour standards are met in the processing factories, but doesn’t provide much information about what happens on fishing vessels.

Healtheries manufacture fish oil (including as ’smart bursts’ for kids) as well as krill oil and cod liver oil. Their krill oil may well be slave and child labour free (it will be if it is FoS certified, but we cannot be confident of that). Their other oils are less likely to be as IFFO-RS certification only checks factories and FoS certification social accountability criteria do not apply to all fishing vessels and only apply to oils made from whole fish.

Nature’s Way

Nature’s Way state on their website that their fish oils are derived from anchovies, sardines, mackerel, herring; and that “These fish are sustainably harvested and 100% traceable, which helps support delicate ocean ecosystems.” They also do krill oil. Being 100% traceable is a good start in terms of understanding welfare standards in their supply chain, but it wasn’t clear from their website that they were looking for that. They didn’t respond to our enquiries so we do not know anything about worker welfare in their supply chain: Just Kai doesn’t, in general, recommend Nature’s Way at this stage. However, they do have one vitamin product for kids that uses algal omega 3 oil. This is the sole Nature’s Way product we are confident is slave free.

Cenovis

Cenovis have no information on their website about working conditions in the supply chain of their fish oils. When we contacted them they wished to discuss Just Kai’s concerns by phone. We were unable to do this due to health reasons, and again requested written information. There has been no further contact with Cenovis since. Just Kai doesn’t recommend Cenovis oils at this stage.

Red Seal

Red Seal have no information on their website about working conditions in the supply chain of their fish oils. However, they told Just Kai that they source their fish oils from South America. They didn’t know anything about the working conditions on the boats or in the factories catching and extracting the oil and were going to contact their supplier to find out more. We have yet to hear back from them.

The fishing industry in parts of South America have been described as a hot-spot for modern slavery. Just Kai doesn’t recommend Red Seal oils at this stage.

GO Healthy

GO Healthy has no information on their website about working conditions in the supply chain of their fish oils and did not respond to our inquiries. Just Kai doesn’t recommend GO Healthy at this stage.

Bioglan

Bioglan has no information on their website about working conditions in the supply chain of their fish oils and did not respond to our inquiries. Just Kai doesn’t recommend Biolglan at this stage.

Recommendations

Fish oil and omega 3 supplements from different species have slightly different properties. If you aren’t fussy about which species your oil comes from, we simply recommend you restrict your buying to products produced by Blackmores, Ethical Nutrients or Swisse. We are confident all their products are slave free.

However, if you are after a particular oil (cod liver oil, for example, or krill oil) read on to see which manufacturers are producing that oil slave-free.

Red krill oil

  • none

Codliver oil

Salmon oil

  • Solgar Wild Alaskan oil (but only their Wild Alaskan oil - not any of their other products).

Fish oil (also simply labelled omega 3 oil)

Vegan/algae omega 3

Any brand of vegan/algae omega 3 oil will be slave and child labour free. As well as the brands listed below, note that there are usually a range of options on TradeMe or US sites like iHerb. Brands likely to be available in pharmacies or supermarkets include:

Green-lipped mussel oil

Any brand of green-lipped mussel oil will be fine from a human welfare perspective. The farming of mussels occurs in New Zealand and is extremely likely to be slave free; due to the perishability of the product, the mussels will also be processed in New Zealand, which has strong labour laws.

Brands that are available include: