Seafood: shellfish, crustaceans and squid

Research carried out in October and November 2019, with revisions in October/November 2020 and May 2021.

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.

Many kinds of seafood are at high risk of having slave labour in their supply chains. Imported shellfish is commonly either harvested or farmed with slave labour. Farmed prawns are fed on fishmeal that is often caught by fishing vessels using slave labour. Many kinds of crustaceans are commonly peeled with slave labour. Squid is often caught in highly abusive working conditions where pay is commonly withheld and workers are often given drugs to keep them working 23 hours a day. Who would want to support things like that?!

We have good news! You can enjoy shellfish and crustaceans in confidence that basic labour standards have been met by:

• buying shellfish either farmed or harvested in New Zealand (the one exception to this is farmed paua: we haven’t found any we are confident is fed on slave-free feed. However, most paua you will see is wild-harvested and farmed paua is always clearly marked as such);
• only buying imported scallops if they are marked as being from Peru, Australia or the US;
• buying prawns from Ocean Pearl or Kingfisher OR unpeeled Argentinian red shrimp OR unpeeled wild-caught Australian prawns;
• buying crayfish only unpeeled and only from New Zealand (which they almost all are anyway); lobster only unpeeled and only from Australia; and crabs only unpeeled and from New Zealand or Australia (which is fairly rare).

Of these we particularly recommend Kingfisher prawns (available from PakNSave and New World), Peruvian scallops and Argentinian red shrimp as purchasing any of these provides decent work in countries much poorer than New Zealand.

Unfortunately we have no recommendations for squid, prawn dumplings or scampi.

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

Read on to learn why we came to these conclusions.

Shellfish

Issues

Most shellfish sold in New Zealand is from New Zealand; the main exception is scallops, most of which are imported. Most New Zealand shellfish species are wild harvested, but mussels are always farmed and oysters and paua can be either. Wild-caught oysters are generally clearly identified as such, as are farmed paua: in the absence of such identification, assume the oysters are farmed and the paua wild-caught.

The slavery risks are different in wild harvested and farmed shellfish, and different in New Zealand and various overseas markets. Shellfish is usually clearly identified as being either imported or from New Zealand, although the exact country of origin for foreign shellfish isn’t always named.

The only overseas shellfish widely available are scallops, so we haven’t investigated any other species. If you are interested in buying other imported species, our discussion on overseas scallops should give you an idea of the questions to ask first.

Shellfish farmed in New Zealand

The main shellfish species farmed in New Zealand are oysters and mussels; there is some farming of paua, although that is mostly for pearls or the export market. Mussels for commercial sale are all farmed, paua for eating is mostly wild-caught (although we have seen some farmed paua for sale in New Zealand) and oysters can be either.

New Zealand farmed shellfish are all farmed either close to land or in tanks on land, meaning that labour rights violations are very unlikely on the farms themselves. We are not aware of either child labour or forced labour ever even being alleged on New Zealand shellfish farms.

Unlike farmed salmon, farmed oysters and mussels aren’t given feed as such. The farms are in the ocean and the shellfish simply eat the algae and plankton naturally occurring there. Coupled with the location of the farms, this means that all New Zealand farmed oysters and mussels can be considered slave free.

Paua, on the other hand, naturally eats seaweed, which is often in insufficient supply at paua farms. This means the paua are often given artificial pellets as supplemental feed. These pellets typically include fish products.

All paua farmed for meat in New Zealand currently appear to come from Moana, in Bream Bay. The New Zealand Abalone Company in Southland has produced paua in the past but is currently rebuilding; they hope to have paua available for sale by 2023. We have asked both of them about their feed, as the fish typically used in aquaculture feeds is at extremely high risk of having slavery in its supply chain. So long as the paua are fed on either a fish free feed, a feed with some kind of reliable slave-free certification, or a fish feed made from fish from a low-risk market such as Peru they will be fine. To date we have not heard back from either so are unable to recommend any farmed paua.

New Zealand farmed shellfish all seem to be exclusively processed in New Zealand; we have not found evidence of forced labour or child labour ever occurring in the shucking, mincing, cooking etc. of these shellfish.

At this stage, Just Kai recommends all New Zealand farmed oysters and mussels. We cannot recommend farmed paua until we have heard back from the two companies mentioned above. However, do note that most paua for sale is wild-harvested and can be considered slave-free.

Shellfish wild harvested in New Zealand

A wide variety of wild-harvested shellfish is sold in New Zealand, including paua, oysters, cockles, kina, geoduck, scallops, tua tua, pipis and various clams. Note that scallops sold in New Zealand are most commonly sourced from overseas; with the exception of certain clams, all the other varieties listed above will always be New Zealand sourced.

These shellfish are all harvested coastally, which makes the use of slave labour unlikely due to New Zealand’s strong labour laws. All known cases of slave labour in the New Zealand fishing industry have occurred on fishing vessels operating well out to sea (e.g. on the Sajo Oyang), where policing is difficult. Thomas Harré of Slave Free Seas has assured us that New Zealand wild harvested shellfish are a “fairly safe bet” from a slavery point of view.

New Zealand farmed shellfish all seem to be exclusively processed in New Zealand; we have no concerns about forced labour in the shucking, mincing, cooking etc. of these shellfish.

Just Kai considers all New Zealand wild harvested shellfish to be slave free.

Scallops from overseas

Most overseas scallops labelled with country of origin are wild-caught Peruvian scallops. We have also seen wild-caught scallops from both Tasmania and the US, as well as scallops simply labelled as being imported.

We are consider Peruvian scallops of low risk for both slavery and child labour and are happy to recommend them. See our discussion of the Peruvian fishing industry here.

Similarly, we have found no evidence of forced labour or child labour in the Australian wild-caught shellfish industry: wild-caught Tasmanian scallops will be fine.

We have found no evidence of forced labour in the US wild-caught fishing industry in general; however, conditions that border on forced labour have been reported in the processing of crabs and some other crustaceans. As scallops need much less processing than these species, we consider the risk here to be low and are happy to recommend US wild-caught scallops.

The scallops simply labelled as being ‘imported’ are more complicated. Likely some of them are farmed. The global scallop aquaculture industry is dominated by China, with Japan making up the bulk of the remainder. These countries are both considered to have a high risk of slavery in their fishing industries, so scallops from either Chinese or Japanese farms shouldn’t be purchased unless the farms were subject to third party human welfare audits of some kind.

Another possibility that would be concerning would be those scallops being wild-harvested from the UK. British scallops are at very high risk of slavery: there have been multiple reports of forced labour on UK scallop boats. Any scallops that are found to be sourced from the UK should not be purchased unless the brand can assure you they were fished by vessels belonging to the Responsible Fishing Scheme.

At this stage, Just Kai recommends wild-caught scallops from Peru, Australia or the US.

We have contacted the companies we found selling overseas scallops from elsewhere or from unspecified locations (Foodstuffs and Sea Treasure with regard to their ‘imported’ scallops and Takitimu with regards to their Chinese scallops). Thus far, only Foodstuffs has replied. Their ‘imported’ scallops will be either wild-caught Tasmanian scallops (which are fine) or Chinese farmed scallops (which are not, as Foodstuffs don’t check their supplier for human welfare issues). The people at the fish counter in your local PakNSave or New World will be able to tell you which they are on any given day.

Recommendations

All New Zealand-sourced shellfish, with the sole exception of farmed paua, is considered free of child and slave labour. This includes, mussels, oysters, cockles, kina, geoduck, scallops, tua tua, pipis and most clams. Wild-caught paua (which forms the bulk of paua available for commercial sale) is also fine.

Scallops wild-harvested from Peru, Australia or the US are free of child and slave labour. Suitable brands include:

• Shore Mariner Peruvian scallops (available from both New World and Countdown)
• Peruvian scallops from the fish counter in Countdown
• US or Peruvian scallops from Takitimu Seafoods online (note that Takitimu also sell Chinese scallops. We have asked them about human welfare considerations in the supply chain of their Chinese scallops and do not recommend buying these until Takitimu gets back to us).
• Kiwi, Peruvian or Tasmanian scallops from Gourmet Seafoods online
• wild-caught Tasmanian scallops from the fish counter of your local New World or PakNSave. Be aware that scallops here will sometimes be wild-caught Tasmanian and sometimes Chinese farmed. Always ask the people on the counter, and only buy the Tasmanian ones.

Crustaceans

Issues

Prawns and shrimp

Note that there aren’t really clear distinctions between what is a prawn and what is a shrimp, so they are discussed together below. The term ‘prawn’ seems to be currently used more commonly in New Zealand so that is what I’ll generally be using.

Feed

Almost all farmed prawns are fed on fish meal of some kind; fish meal from certain markets is at high risk of slave labour. The largest supplier of fish meal globally is Peru. 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 recommend prawns 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: I have no concerns there.

However, there are significant slavery concerns with one of the other major suppliers, Thailand. This is of particular concern when it comes to prawn production, as Thailand is one of the major suppliers of prawns to New Zealand and Thai prawns are likely fed on Thai fish meal. The ILO has found that 17 to 26% of workers on Thai vessels fishing for fish feed were subject to forced labor; forced labour and child labour are also common in the ‘feed mills’ where the fish are processed into meal and oil.

There is less data for Viet Nam and China (the next largest suppliers, and also major shrimp farming countries), but they are also countries where worker abuses are reasonably common.

Before buying any farmed prawns it is important to check where the fish meal they were fed on was caught. If it’s from Peru or the EU you don’t need to ask further questions; if it’s from Thailand, Viet Nam or China, you’ll need to ask if anyone’s auditing the boats and feed mills for human rights abuses before you can be confident to buy it.

Certifications that can help include:

GlobalG.A.P.: 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. However, the Global G.A.P. compound feed manufacture standard only requires feed manufacturers to use fish caught ‘responsibly’ (section 15) in terms of fishing regulations (which prevent things like overfishing). There is no requirement that any particular labour regulations are adhered to at the fishing stage, although labour conditions in mills are audited.

BAP: feed mills are subject to unannounced third party audits checking for many things, including forced labour and child labour. However, suppliers (i.e. the boats) are only subject to sustainability criteria, not social accountability ones.

Friends of the Sea: similar to BAP, feed mills are subject to rigorous human welfare audits. In some cases, so are fishing vessels, but there are significant exceptions: see here for more information.

IFFO-RS: again, similar to BAP, feed mills are subject to rigorous human welfare audits but fishing vessels need only meet sustainability criteria. See here for more information.

As you can see, any of these certifications can give you confidence that the feed mills were free of forced labour and child labour; however, none of them tells you anything about what happened on the fishing vessels. The only way we know of to be confident the fishing vessels were slave free is for the fish to have been caught in either Peru or the EU.

Note that a minority of prawns are fed a fish-free diet. Ridley in Australia, in conjunction with the CSIRO has developed Novacq, a fish meal alternative made from microbes. It’s grown on ponds in Queensland, using fertiliser and agricultural waste. That’s an excellent slave-free option! AlgaPrime, an algae based fish oil substitute, also reduces the fish content required in shrimp feed used on some Thai prawn farms.

Some prawn farms will be certified through the Aquaculture Stewardship Council. Their shrimp farming standard only has sustainability requirements for feed, not human welfare ones, so isn’t useful here.

Farming

Most of the farmed prawns sold in New Zealand come from Viet Nam, China and Thailand. If the prawns are vannamei prawns or white tiger prawns, or if the origin isn’t clearly labelled, chances are the prawns are from one of these countries. Despite the widespread occurence of labour abuses in all three countries, forced labour and child labour seems rare on the prawn farms themselves, although Matt Friedmann of The Mekong Club assures us it does sometimes occur in Thailand, at least. Farms are typically small, family-run operations and it can be hard for companies to know what is going on on all the farms that supply them. Aquaculture Stewardship Council certification, Global G.A.P. or Best Aquaculture Practise Certification assures you someone has been checking basic minimum labour standards have been adhered to on the farms; however, this isn’t something Just Kai insists on as forced labour on farms doesn’t seem widespread.

You can also buy prawns farmed in Australia: these are easier to identify as they are generally prominently labelled as such. Australian prawn farms are located on the east coast of Australia, between Yamba in northern New South Wales and Cairns in Queensland. The prawns are grown in ponds on land and Australia is a country with strong labour law. This makes forced and child labour unlikely on the prawn farms themselves. We have not found any evidence of either practise on Australian prawn farms, and do not expect to. Australia currently exclusively farms banana and black tiger prawns.

Wild-caught prawns

New Zealand waters are too cold for prawns, but you do see imported wild-caught prawns: many are from Australia (e.g. Australian king prawns) but others are also from various Asian countries. We have not found any evidence of worker abuse in the Australian wild-caught prawn industry. It has been hard to tell if there is worker abuse in the Asian wild-caught prawn industry as searches have been swamped by information about worker abuse in Asian prawn farming and processing. If you wish to buy wild-caught Asian prawns, ask the retailer whether anyone has been auditing working conditions on the fishing vessels. If they have not, Just Kai doesn’t advise buying them: forced and child labour on fishing vessels in that region is just too common.

Some retailers sell carabineros prawns, which are wild-caught off the coast of Spain. Spain is considered at high risk for forced labour in its fishing industry, so these shouldn’t be purchased unless the supplier has been audited for human wellfare standards.

Argentinian red prawns (also called Argentinian red shrimp) are wild caught off the coast of Argentina. We have found no evidence of forced labour or child labour in the Argentinian seafood industry.

Processing

Prawns are sold processed to widely varying degrees. Some are sold simply frozen without further processing, others are whole but cooked, or shelled and either cooked or left raw while still others are processed into dumplings, breaded etc.

Wild-caught Australian prawns are generally snap-frozen on the vessel that catches them. Farmed Australian prawns are cooked (if they are to be) and frozen on farm. We have found no evidence of labour abuse on Australian prawn vessels or farms and are very happy to recommend any prawns cooked or frozen there. However all Australian prawns, be they farmed or wild-caught, that undergo further processing (e.g. shelling, marinating, processing into dumplings) are likely to have been processed in a low-wage Asian country such as Thailand.

The Australian government has a special arrangement with a large Thai seafood processor, Thai Union, to handle much of the Australian prawns that are sent overseas for processsing. Thai Union previously had a dreadful human rights record with extensive use of slave labour by subcontractors. However, they have been working to eliminate these practises since 2015, and now have a robust anti-slavery policy in their factories. Activist Andy Hall has previously told Just Kai that Thai Union has particularly good labour practises in its factories and is most unlikely to use forced or child labour. We would be very confident to recommend any prawns processed by Thai Union.

We are much less confident of prawns processed elsewhere in Thailand. Prawns are typically peeled and have their heads removed in highly unregulated ‘peeling sheds’ before being passed onto larger factories for further processing. Especially in peeling sheds (but also in actual factories) both forced labour and child labour remain common. We do not recommend buying prawns processed in Thailand (other than those processed by Thai Union) unless there have been independent inspections of labour conditions at all facilities concerned. Ask the company if their prawns have been exclusively processed facilities with either TLS8001 certification (discussed here) or SA8000 certification (discussed here).

Prawns processed in China, Viet Nam and other low-wage Asian countries are all at risk of having used forced and/or child labour. Always ask if the factory was independently audited, ideally with SA8000 certification. And be aware that processed prawns, regardless of their country of origin, are very likely to have been processed in such countries. Prawn peeling is labour intensive and prawns travel great distances around the globe: Argentinian red prawns marketed in the US is generally processed in China, for example, whilst Ecuadorian farmed shrimp may be processed in Viet Nam.

Summary

• Argentinian red prawns/shrimps and Australian wild-caught prawns are both always OK from a human welfare point of view, so long as they haven’t been processed beyond simply cooking and/or freezing.

• All other shrimps and prawns have multiple risk points:

  • if they are farmed, the prawns/shrimp need to have been fed either on fish-free feed (such as Ridley’s Prawn Plus No Catch) or on feed that is either low risk or has been audited for human welfare conditions. No feed certification we know of involves auditing boats, although Global G.A.P., IFFO-RS and BAP certification audit feed mills. Fish caught in the EU or Peru doesn’t need to be audited.
  • if the prawns/shrimp are farmed in Thailand, the farms will also have been audited for human welfare conditions. Certifications that cover this include ASC, BAP and Global G.A.P. All prawns other than black tiger prawns and banana prawns are likely to have been farmed in Thailand.
  • if the prawns/shrimp are processed beyond simple cooking and/or freezing (e.g. if they are shelled, have had their heads removed etc.) then this needs to have been done in a factory with suitable human welfare audits. This includes factories with SA8000 or TLS8001 certification, and needs to cover both the main factory and any pre-processing facilities used. The only exceptions to this is if they were processed by Thai Union. Many Australian farmed prawns are processed by Thai Union.

Other crustaceans

Prawns and shrimp are by far the crustaceans most commonly consumed in New Zealand so we have covered them in considerable detail. Below is much briefer information about crayfish, lobsters, scampi and crabs. In general, we consider unpeeled crustaceans caught or farmed in low-risk countries to be slave free. Peeled crustaceans are more complicated: crustaceans are labour-intensive to peel and there is a strong market pressure for this work to be carried out as cheaply as possible. In some cases, crustaceans caught in countries where wages are high are sent to low-wage countries for processing. They aren’t necessarily processed with slave labour in those circumstances, but it always a risk. In addition, in the US there have been many cases documented of migrant workers incurring significant debt to obtain crustacean-processing jobs and then having little choice but to stay in those jobs to service their debt. We are unsure if that situation quite meets the formal ILO definition of slave labour but it certainly comes close.

Crayfish

In most of the world the term crayfish refers to small, fresh-water creatures but in New Zealand it is used for a kind of lobster also known as the rock lobster. New Zealand crayfish are a coastal species occurring off both mainland New Zealand and various offshore islands. Crayfish for sale could be either wild-caught or farmed. New Zealand does also have freshwater crayfish, the two species of kōura, but we have never seen them for commercial sale.

All unpeeled New Zealand crayfish can be assumed to be slave-free. Wild-caught crayfish, like wild harvested New Zealand shellfish, are gathered near land in a country with strong labour laws. Farmed crayfish are also farmed near land and, like farmed mussels or oysters, simply feed on seaweeds etc. naturally present in the environment. This means that, unlike with many aquaculture species, there is no concern about slavery in the supply chain of their feed.

Lobsters

Occasionally New Zealand-sourced crayfish are referred to as lobsters, but the word is usually used to refer to a variety of imported species. These can be from any of a wide range of countries, and often neither the country of origin or species is named.

The only direct reports we have seen of any form of Modern Slavery in the lobster industry is the use of child labour in lobster fishing in Honduras. However, many of the lobsters for sale here come from countries with a high risk of slavery in their fishing industries in general, such as Viet Nam or Brazil. Many also come from the US. We know of no reports of forced labour in the fishing industry in the US in general, but highly exploitative labour that borders on slavery is common in US crustacean processing. This all makes us cautious to recommend any imported lobster, with one exception: unprocessed lobsters from Australia, which we would expect to have the same very low slavery-risk as New Zealand crayfish.

Note that crawfish from the US are sometimes sold in the lobster section, at least at online retailers. US crawfish is processed under the same exploitative conditions as US crabs and we do not consider it ever to be slave free.

Scampi

True scampi are only found in New Zealand, although we have found one company marketing an imported species as scampi. They are a midwater fish and so are caught by fishing vessels that are out at sea for some time. In general, midwater and deepwater fish are at high risk of having been caught by forced labour, as it is easier to keep people confined on a fishing vessel when it is out to sea for a long time. There have been reports of slavery on foreign-flagged vessels carrying out mid- and deep-water fishing in New Zealand in the past. Since 2014 foreign vessels commercially fishing in New Zealand waters have had to be reflagged as New Zealand vessels. One consequence of this is that they are now audited by observers who are required to report any breaches of New Zealand labour laws on the vessel. In theory this should make New Zealand scampi at low risk of slavery in its supply chain; however, there has been no research carried out to date to assess how the system is working and, anecdotally, it seems there has been little improvement. We do not recommend any scampi.

Crabs

As with lobsters, we have seen crabs for sale from a very wide range of countries: country of origin is frequently unstated. New Zealand does have a small commercial crab industry, but the vast majority of crabs for sale are imported.

Crabs are commonly sold significantly processed, and this processing is labour-intensive work. There have been many reports of debt bondage and payment below the legal minimum wage in crab processing in the US. Many of the countries from which crabs are imported (Madagascar, Indonesia, Viet Nam etc.) are countries where slavery is common in the fishing industry.

For the same reason we recommend wild-harvested New Zealand shellfish, we also recommend crabs from either New Zealand or Australia, and then only unpeeled. Spanner crabs are likely to be from Australia; paddle crabs are likely to be from New Zealand. Mud crabs are also likely to be from Australia, although don’t buy them without a clearly labelled country of origin - they are found throughout South-East Asia. Similarly blue swimmer crabs may be from Australia, but don’t buy them if you aren’t sure - there have been many reports of illegal fishing in the Chinese blue swimmer crab industry, so they are at high risk of slavery. You may also find other species for sale that were caught and processed in those countries, but these seem to be the most common ones.

There is currently much active research into farming crabs in Australia, particularly mud crabs. Australian farmed crabs do not appear to currently be commercially available. However, should you see Australian crabs in the future that are labelled as farmed, they should be approached with caution. Experiments in crab farming in Australia seem to be using fish oil in the feed of the very young crabs then the same pellets that are fed to prawns for the older animals. As discussed earlier, the fish that goes into prawn feed and into fish oil are very often caught and processed using slave labour. If you ever do come across Australian farmed crabs, check with the brand concerned about the source of their feed before you buy.

Note that crawfish from the US are sometimes sold in the crab section, at least at online retailers. US crawfish is processed under the same exploitative conditions as US crabs and we do not consider it ever to be slave free.

Prominent brands

Prawns and shrimp

Just Kai contacted the following brands of prawns and shrimp:

United Fisheries (parent company of United Food Co and Sea Cusine)

Leanne’s Kitchen

Sea Treasures

Countdown (for their own brand and fish counter products)

Markwell (parent company of Shore Mariner and Sea Breeze)

Pacific West

Kingfisher

Foodstuffs (for Pams, Pams Finest and Value)

and online retailers Takitimu and Gourmet (the latter owned by Solander)

We also investigated Raptis (who sell prawns under the brand Ocean Pearl) but didn’t need to contact them as they had sufficient information on their website to recommend them.

Raptis

Raptis exclusively sell wild-caught Australian prawns that are simply frozen on the fishing vessel. There is no risk of slavery or child labour in their products. Note that there is a different company marketing ‘Ocean Pearl’ prawns in the UK: we have no knowledge of whether their products are slave free.

Kingfisher

Kingfisher is one of the largest seafood companies in Thailand. They farm vannamei and black tiger shrimps as well as selling wild-caught shrimp. They sell under their own brand in PakNSave and New World supermarkets.

Kingfisher was one of the companies named in a notorious 2015 AP report into slavery in the Thai seafood industry. At that time they appeared to have no interest in mitigating such practises in their supply chain. However, things appear to have since changed significantly with Kingfisher. In terms of the key risk points, they:

• they themselves produce IFFO-RS certified fish meal: this certification means the fishmeal factory is audited for slave and child labour, but it doesn’t indicate that the fishing vessels catching the fish were so audited. However, their fish meal appears to all be from tuna scraps, and Kingfisher has been working since 2017 with UK charity Ocean Mind to monitor working conditions on all Thai-flagged vessels in their tuna supply chain. They also make some efforts in their international supply chain; these don’t seem to be all that thorough, but this is an area of lower risk so that isn’t a major concern. It seems that not all the fishmeal they use is produced inhouse, however, but (from correspondence) we have learned that they only buy from suppliers who are audited to check for slave and child labour. In addition, they impose strong working condition requirements on suppliers in general, and conduct their own audits to ensure these are being adhered to. They have been supported in this process by the well-regarded NGO Issara.
• many of their shrimp farms are subject to external audits by organisations that check for human welfare. Their Trat farm is audited by ASC, others by BAP.
• from correspondence we have learned that all their shrimp processing (including initial peeling stages) is done in-house, and has been for several years.
• in their factories they adhere to the UN’s Good Labour Practises for the Thai seafood industry. They do not charge recruitment fees (a major source of debt bondage). They also have a thorough workforce practises policy that includes no tolerance for forced or child labour. Since 2017 they have worked with the NGO “Worker’s Voices” to assess working conditions in all their facilities and have seen improvements in all working conditions metrics measured since then.

Just Kai would like to see more evidence of independent audits of human welfare throughout Kingfisher’s supply chain. However, we do believe they have strong human welfare policies and are encouraged by their collaborations with respected NGOs at a number of points in their process. Just Kai recommends prawns and shrimps from Kingfisher.

Foodstuffs

Foodstuffs sells wild-caught Argentinian red prawns and wild-caught Australian King prawns, both of which are always clearly labelled as such. As discussed above, these are always fine from a human welfare point of view.

In addition, they sell farmed prawn from “a number of countries including China, Vietnam, Thailand”. These countries are all at high risk of slavery in their prawn industries. Foodstuffs told us they “ask that any supplier to us be able to show that factories are audited by independent companies to ensure that there are no breaches of that countries labour rights or human rights,” and they cited Sedex as an example of one such auditor. That is encouraging, but not sufficient, as it is unclear whether these audits go right through the supply chain or if they just cover the final factory.

When we requested clarification, they told us their main Thai prawn supplier is Kingfisher (discussed above). We are reasonably confident Kingfisher prawns are slave free; however, it is not clear whether all their Thai prawns come from them, and the Chinese and Vietnamese ones certainly don’t.

In terms of their other prawn suppliers, Foodstuffs told us “we have asked that they can produce statements of a similar nature to Kingfisher (SMETA, BRC, FDA approval) around the ethical procurement of their products from these countries. This is much less encouraging. Neither BRC certification nor FDA approval concern themselves with worker treatment in any way: they are both only interested in whether a product is safe to consume. SMETA (discussed previously here) does, at least, concern itself with worker treatment, but it’s not a certification: it’s a tool companies can use to analyse their supply chain. It’s up to the company concerned both how deeply they look into the supply chain and how they respond to what they find. For an industry such as the prawn industry, where slavery can occur right throughout the supply chain, a SMETA audit would need to be applied at many levels. There is no evidence Foodstuffs are doing this (and the fact that they cited two certifications that have no relevance doesn’t instill confidence).

Just Kai cannot be confident Foodstuffs’ prawns (either those at the fish counter of PakNSave and New World supermarkets or those under the Pams and Value brands) are slave free. The only exception is prawns clearly labelled as being either Argentinian red prawns or wild-caught Australian King prawns.

Markwell

Markwell (which owns the brands Shore Mariner and Sea Breeze) tell us they use a variety of prawn suppliers, and the prawns can come from different countries at different times. However, they believe that “all staff in these respective supplier factories are adults and working of their own free will. This is audited by independent bodies, which hopefully should allay your concern with regards to human welfare conditions. ASC, MSC (fish), BAP, Global GAP are further certification bodies which can be stipulated, if requested by our customer base.” They also told us that they are Assured Food Safety certified, but that isn’t hugely relevant as AFS only deal with product safety issues, not worker rights.

This suggests that the factories in which the prawns are processed are likely to be staffed by adults working of their own free will; however, there is little reason to be confident this is the case deeper into the supply chain.

Of the certifications mentioned, none check for human rights issues right back to the boats that catch the fish fed to the prawns. None of the other certifications mentioned do this. Global G.A.P. and BAP certification kick in from the feed mill onwards, ASC certification only from the farm onwards, and MSC doesn’t certify prawns (just fish, which Markwell also sells).

We cannot recommend Markwell prawns.

Leanne’s Kitchen

From correspondence, Leanne’s kitchen dumplings use farmed vannamei prawns supplied by Shore Mariner (a Markwell brand, discussed above). They are supplied peeled and deveined. We do not recommend Markwell prawns, so cannot recommend Leanne’s kitchen dumplings.

United Fisheries

United Fisheries haven’t answered our enquiries and have no information about their prawn sourcing on their website. We do not recommend their products.

Gourmet

Gourmet have told us that they source all but their carabineros prawns through United Fisheries. As stated above, we do not recommend prawns from United Fisheries. Carabineros prawns are at high risk of slavery due to their country of origin (Spain). Gourmet doesn’t check for such practises when choosing suppliers for their carabineros prawns.

Countdown

The majority of Countdown’s own brand prawns are farmed prawns from either Vietnam, China or India. They deliberately do not source any own brand prawns from Thailand. All suppliers of farmed prawns are ASC or BAP certified. They also sell own brand wild-caught MSC certified Australian banana prawns.

As neither ASC nor BAP certification covers conditions of the fishing vessels that catch the fish used to feed the prawns, we are not willing to recommend any own-brand farmed prawns from Countdown.

However, wild-caught Australian banana prawns with their shells on are very low risk for slavery: we are happy to recommend their own brand banana prawns.

Note that Countdown was intending to revise their seafood sourcing policy in 2020 to cover human rights risks further up their supply chain. We have enquired as to whether this has now happend (October 2020) and will update our advice if we hear back from them.

Pacific West

Pacific West didn’t respond to our enquiries and doesn’t have any information about the sourcing of their prawns on their website. We do not recommend prawns from Pacific West.

Sea Treasure

Sea Treasure didn’t respond to our enquiries and doesn’t have any information about the sourcing of their prawns on their website. We do not recommend prawns from Sea Treasure.

Takitimu

Takitimu didn’t respond to our enquiries and doesn’t have any information about the sourcing of their prawns on their website. We do not, in general, recommend prawns from Takitimu. However, they do sell some wild-caught whole raw Australian prawns. These are a low-risk product and we are happy to recommend them.

Other crustaceans

We didn’t really find any ‘branded’ crayfish, lobster, scampi or crabs so our recommendations (below) are based solely on species and country of origin.

Recommendations

Whole raw wild-caught prawns (excluding carabineros)

Ocean Pearl: banana prawns, tiger prawns, king prawns, endeavour prawns. Ocean Pearl banana prawns are stocked by Countdown.

Takitimu sells wild-caught Australian King prawns online.

Own brand banana prawns from Countdown’s fish counter.

Argentinian red prawns from the fish counter of PakNSave or New World.

Peeled raw farmed prawns

Kingfisher: prawn cutlets and stir-fry prawns. Available in PakNSave and New World.

Crumbed prawns

Kingfisher: crumbed garlic prawns and crumbed prawn cutlets. Available in PakNSave and New World.

Peeled and cooked prawn meat

Kingfisher: cooked prawn cutlets, cooked prawn meat and cooked and peeled shrimp. Available in PakNSave and New World.

Other prawn and shrimp products

We do not know of any slave free options for other prawn and shrimp products - sadly, this includes dumplings.

Crayfish

All unpeeled crayfish sold in New Zealand.

Lobster

Whole lobster from Australia, or whole New Zealand crayfish that are being marketed as lobster.

Scampi

We know of no slave-free options for scampi.

Crabs

Unpeeled crabs from New Zealand or Australia. You’re most likely to see Australian spanner crabs and New Zealand paddle crabs; you may also see blue swimmer crabs, but make sure they’re marked as being from Australia. Unpeeled mud crabs are widely sold at fish shops - so long as they’re from Australia they are also slave-free.

Crawfish

We know of no slave-free options for crawfish.

Squid

Issues

Fishing

The term ’squid’ refers to about 300 different species, 30-40 of which are fished commercially. They are mostly caught in the Pacific and Atlantic oceans. Like scampi, squid is a deepwater fish, so fishing grounds occur far from land. Squid boats fishing in New Zealand waters typically stay out for 6 months without a break, for example. This makes squid a fish with a high risk of slavery in its supply chain as fishers have little recourse to help if their captain wishes to hold them against their will.

There have been many reports of slavery on squid boats. The only conviction for slavery in New Zealand waters occurred on a squid boat; Aung Ye Tung tells his story of slavery on an Indonesian squid boat here; and in 2019 the crew of a North Korean squid boat systematically killed all the officers on board in an attempt to escape harsh treatment.

Since 2014 foreign vessels commercially fishing in New Zealand waters have had to be reflagged as New Zealand vessels. One consequence of this is that they are now audited by observers who are required to report any breaches of New Zealand labour laws on the vessel. In theory this should make New Zealand squid at low risk of slavery in its supply chain; however, there has been no research carried out to date to assess how the system is working and, anecdotally, it seems there has been little improvement. We cannot assume that squid caught in New Zealand waters is slave-free, although it probably has a somewhat reduced slavery risk due to this observer system.

We would not recommend any squid unless the company could assure us that some form of auditing was taking place to check conditions on the boats. Observers on the boats would be ideal, but interviews with fisheries workers in port (away from their boat) would also provide some indication of whether slavery was occurring on a given vessel.

Processing

Because squid vessels are out at sea for a long time, some minimal processing (gutting, sometimes deheading, and freezing) is carried out on the vessel, after which it is referred to as ’dressed squid’. Squid can be sold as dressed squid, or further processed before sale into tubes, rings (which are often sold crumbed) or strips (sometimes also called fillets).

This processing isn’t as labour-intensive as crustacean peeling, but it is still work that is often carried out done offshore. For example, squid caught in Californian waters is generally processed in China before being returned to California for sale as a ‘local’ product. Both forced labour and child labour are common in seafood factories in many low-wage countries, especially in Asia. Before buying processed squid - even if it has been caught in New Zealand - it is important to check whether the factory it was processed in was slave free. You can be confident this is the case if it was processed in a country with strong labour laws (like New Zealand), but if it has been sent to a low-wage country for processing you can’t be confident it’s slave free unless that’s been independently verified. The two most common certifications that can assure you of this are SA 8000 or TLS 8001 (both discussed here). These are factory certifications that you will never see displayed on product packaging, but you can still ask a company if the factory they source from has such certification.

In summary, Just Kai would only recommend squid caught on a vessel where labour conditions have been independently verified to be slave free. When it comes to squid rings, tubes etc., they not only need to have been caught under those conditions but also processed either in a country like New Zealand with strong labour laws, or in a factory with SA 8000 or TLS 8001 certification or similar.

Prominent brands

Just Kai contacted the following squid brands whose products were available in supermarkets: United Fisheries (which has the brands United Fish Co and Sea Cuisine), Pacific West, Shore Mariner (a brand of Markwell Foods) and Sea Treasure. We also looked at online fish retailers Gourmet and Takitimu, both to look at their specific products and to get an idea of what might be for sale in fish shops.

United Fisheries

United Fisheries exclusively sell Arrow Squid caught in New Zealand waters. It is not clear where their squid are processed. We haven’t yet asked them about fishing conditions, but have asked about their squid processing. At this stage we cannot recommend their products, but we will update our recommendations if/when we hear back from them.

Pacific West

Pacific West haven’t responded to several queries about other products, so it didn’t feel worthwhile to contact them again to ask about squid specifically. There is no information on their website about how they source their squid. Some of their squid products are of Chinese origin, a country at high risk of slavery in its processing factories. We cannot recommend Pacific West’s squid.

Markwell Food

Markwell (which owns the brand Shore Mariner) have simply told us they believe that “all staff in these respective supplier factories are adults and working of their own free will. This is audited by independent bodies, which hopefully should allay your concern with regards to human welfare conditions.” They also told us that they are Assured Food Safety certified, but that isn’t hugely relevant as AFS only deal with product safety issues, not worker rights.

It sounds like the factories from which Markwell sources are likely to be slave free as they are audited, although we have no further details of this auditing. However, they didn’t comment on conditions on boats, which is the area of greatest slavery risk, so we cannot recommend Markwell/Shore mariner squid.

Sea Treasure

Sea Treasure haven’t responded to several queries about other products, so it didn’t feel worthwhile to contact them again to ask about squid specifically. They don’t have any information about the sourcing of their squid on their website.

Gourmet

Gourmet source all their squid from New Zealand, which we initially thought would make their dressed squid ‘slave-free’ (an opinion we’ve since revised after learning more about the observer system). It is not clear where their squid are processed. We have enquired about the processing and will ask about labour conditions on vessels if/when we hear back from them. At this stage we cannot recommend any of their squid, but we may update that if we hear back from them.

Takitimu

Takitimu haven’t responded to several queries about other products, so it didn’t feel worthwhile to contact them again to ask about squid specifically. They don’t have any information about the sourcing of their squid on their website. We do not recommend squid from Takitimu.

Recommendations

At this stage we know of no squid products we can recommend, although we do feel that dressed (i.e. very minimally processed) squid sourced from New Zealand (e.g. this) is your lowest-risk option.