The threats posed by human trafficking, child labor, forced labor and Illegal, Unreported, and Unregulated (IUU) fishing that contribute to overfishing our oceans are gaining attention from law enforcement and human rights organizations. While the seafood industry has sustainable fishing programs in place (e.g. Marine Stewardship Council, Aquaculture Stewardship Council), they do not adequately address IUU fishing or human rights abuses on a global scale. The time to develop a global solution is now.
Organization for Economic Co-Operation and Development’s (OECD’s) Five-Step Risk-Based Due Diligence Framework (Five-Step Framework), which is quickly becoming the norm for due diligence best practices. The framework includes the following steps:
1. Establish management systems
2. Identify and assess risk
3. Respond to identified risks
4. Audit of supply chain due diligence
5. Report on supply chain due diligence
These requirements place the onus on the supply chain actors—particularly initial processors—who have more direct relationships with raw material suppliers and are often the last point where the origin of material can be validated. This proximity forces them to be accountable for all material that they purchase or process and to have robust policies, procedures, material management systems, and evidence for each transaction.
As I shared in my October 2016 blog, the Conflict Free Smelter Initiative (CFSI) has been very successful among several industries using the new model of empowering, enabling and implementing risk-based due diligence.
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