Correspondence
Email to Aldi South's press office and marked FAO Linda van Rennings, Aldi South's spokesperson for sustainability communication.
The email said: "I’m contacting you in light of our latest investigation which concerns the use of forced labor in China’s seafood processing industry, and a link we’ve discovered between a company engaged in such practices and your supply chain.
Aldi’s supplier, Dalian Rich Enterprise Group, signed a distribution agreement in 2022 with a Chinese conglomerate (Xinjiang Tianyun Organic Agriculture) known to have participated in a Chinese government program described by the U.S. government as an indicator of forced labor.
The United Nations, human rights organizations and academic experts agree that since 2018, the Chinese government has systematically subjected Xinjiang’s predominantly Muslim ethnic minorities to forced labor within Xinjiang and across the country via state-sanctioned employment schemes which use coercive methods in worker enrollment. The U.S. has prohibited the importation of goods produced in the Xinjiang Uyghur Autonomous Region, under the Uyghur Forced Labor Prevention Act.
Further to this, we have uncovered clear evidence that the processor Rongcheng Puchen – which supplies squid products under Aldi’s own-brand labels Tasty Catch and Fishmongers – has received catch from a Chinese squid fishing vessel found engaging in unregulated fishing activity. The company that owns the vessel has a history of illegal fishing and human rights abuses, with our investigation identifying 14 of its vessels as engaged in activities including forced labor, AIS spoofing, shark finning, and unauthorized transhipment.
Does Aldi have any comment or statement to make in light of the above information?
Please respond to this email by close of business June 23, 2023."
Cathleen Völkel of the communications company Rosam.Grünberger.Jarosch & Partner replied for Aldi, saying: "Thank you very much for your enquiry. The ALDI SOUTH Group has not approved any contracts with Dalian Rich Enterprise Group since 2020. However, we can confirm that we receive one product for the UK market from Rongcheng Puchen.
ALDI is committed to fulfilling its duty to respect human rights, and we take any reports of human rights abuses committed in our supply chains very seriously. ALDI maintains a rigorous due diligence process, which we regularly review and revise according to the principle of continuous improvement. Any reported instances of Forced Labour or Illegal, Unreported and Unregulated (IUU) fishing are covered by ALDI’s Severe Risk Process, and will be followed up on at the earliest opportunity, with appropriate business consequences being imposed if necessary.
As such, we would welcome any information that shows the processer has sourced an ALDI product from this vessel so that we are able to carry out a thorough investigation."
The Outlaw Ocean Project replied: "Thank you very much for engaging with our query and for providing that statement from ALDI SOUTH Group.
The fishing company referred to in my previous email is Zhoushan Ningtai Ocean Fisheries Co. Ltd. (舟山宁泰远洋渔业有限公司). We have evidence of squid catch from a Zhoushan Ningtai Ocean Fisheries vessel (Ning Tai 58) which engaged in unregulated fishing activity, at Rongcheng Puchen’s processing plant. As noted in my previous email, 14 other vessels owned by Zhoushan Ningtai are linked to a range of environmental and human rights issues including forced labor, AIS spoofing, shark finning, and unauthorized transhipment. Unauthorized transhipment can undermine supply chain traceability by obfuscating the movement of catch from vessel to processor.
Does ALDI SOUTH Group have any concerns that the processor which supplies their products is receiving catch from a fishing company which has a history of illegal fishing and human rights abuses?
Please respond to this email by close of business June 29, 2023."
Paulina Burghardt of communications company Rosam.Grünberger.Jarosch & Partner replied to say: "Unfortunately, after internal consultation, I have to inform you that Aldi South cannot answer your question."
The Outlaw Ocean Project emailed Aldi South: "I’m contacting you in light of our latest investigation which concerns the use of forced labor in China’s food processing industry, and a link we’ve discovered between companies engaged in such practices and one of your suppliers - Nomad Foods.
Aldi Süd sells Iglo brand white fish products. Our research shows that Northseafood Holland and Unibond Seafood International are white fish suppliers to Nomad Foods brands, which include the Iglo, Birds Eye and Findus range retailing across Europe.
Northseafood Holland has imported shipments of white fish, including pollock, from the processor, Yantai Sanko Fisheries Co. Ltd., based in China. Yantai Sanko Fisheries Co. Ltd. has received persons from the Xinjiang region of China under a government labor transfer program since 2019 and until at least April 2023.
Northseafood Holland B.V. has also been supplied white fish by Yantai Longwin Foods Co. Ltd., a company linked to Yantai Sanko Fisheries through corporate ownership. Our investigation has found Uyghurs working at Yantai Longwin Foods Co. Ltd. since at least 2020 and until at least July 2023.
Unibond Seafood has imported shipments of white fish, including cod and pollock, from Qingdao Tianyuan Aquatic Foodstuff Co. Ltd. since the Chinese plant is known to have first started using Xinjiang labor in 2018. Our evidence demonstrates the presence of Uyghur workers at Qingdao Tianyuan as recently as May 2023.
The United Nations, human rights organizations and academic experts agree that since 2018, the Chinese government has systematically subjected Xinjiang’s predominantly Muslim ethnic minorities to forced labor across the country via state-sanctioned employment programs which use coercive methods in worker enrollment and obstruct freedom to terminate employment.
The United Nations, human rights organizations and academic experts agree that since 2018, the Chinese government has systematically subjected Xinjiang’s predominantly Muslim ethnic minorities to forced labor across the country via state-sanctioned employment programs which use coercive methods in worker enrollment and obstruct freedom to terminate employment.
Could you confirm whether white fish sourced from Yantai Sanko, Yantai Longwin and Qingdao Tianyuan has been used in any of the Iglo branded products sold by Aldi Süd since 2018?
Does Aldi Süd have any comment or clarification to make regarding the above information?
Please respond by close of business September 8, 2023, and note that all interactions are fully on record."
Paulina Burghardt at Rosam.Grünberger.Jarosch & Partner, replied: "Unfortunately, we cannot meet the current deadline. Is it possible to extend it for another one to two weeks?"
Paulina Burghardt at Rosam.Grünberger.Jarosch & Partner, replied with a statement from Aldi: "Aldi South is committed to fulfilling its duty to respect human rights, and we take any reports of human rights abuses committed in our supply chains very seriously. Aldi South maintains a rigorous due diligence process. Any reported instances of forced labour are covered by Aldi South’s Severe Risk Process which includes thorough investigation, remediation and appropriate business consequences if necessary. The exploitation of workers has no place in our business or supply chain and breaches to our strict policies will be investigated. As such, we would welcome any further information so that we are able to carry out a thorough investigation."
The Outlaw Ocean Project's publishing partner in Germany, Die Zeit, contacted Aldi South for comment on the origin of fish products from China.
Cathleen Völkel from the PR agency Rosam.Grünberger.Jarosch & Partner replied: "As an international trading company with global supply chains, ALDI is aware of its responsibility to uphold human rights and environmental standards. We take reports of human rights violations and environmental problems in our supply chains very seriously.
We have established a comprehensive due diligence process that we regularly review and develop. All cases of forced labor or illegal, unregulated and unreported (IUU) fishing are considered serious risks under our due diligence process and are followed up immediately. If necessary, appropriate consequences are taken, which can range from the joint development of action plans to the termination of cooperation.
Responsible sourcing of fish and seafood is part of our sustainability strategy. ALDI SÜD's goal is to continuously increase the share of responsibly sourced private label products in our fish and seafood range.
A prerequisite for responsible procurement is transparency along the supply chain. Together with our business partners, we are working to further increase the transparency of our supply chains to ensure control over the origin of products and raw materials.
We rely on independent certification systems for the responsible procurement of fish and seafood. Over 87 percent of the fish and seafood sold at ALDI SÜD in Germany is certified. Those products that are not yet certified come from fishery improvement projects (FIP) or have undergone a risk assessment in cooperation with Sustainable Fisheries Partnership (SFP).
If production takes place in countries that pose a high risk with regard to human rights, we require social audits of all production sites that supply our direct business partners. These audits must be conducted by independent third parties.
In addition, we are currently establishing our own annual assessment of the human rights and environmental performance of our seafood suppliers, the so-called Corporate Responsibility Supplier Evaluation. For this purpose, we carry out comprehensive on-site assessments to identify and minimize risks with regard to human rights compliance or traceability.
Our business partners are required to report regularly on compliance with our procurement guidelines. These reports - as well as the results of our own human rights and environmental assessments - are a fixed component of our purchasing decisions."
The Outlaw Ocean Project's publishing partner in Germany, Die Zeit, asked Aldi South for an update on its internal investigation into the findings of The Outlaw Ocean Project’s investigation.
Paulina Burghardt at Rosam.Grünberger.Jarosch & Partner, replied for Aldi South. A summary in English of this response: Since the first inquiry from The Outlaw Ocean Project, we can confirm that we have contacted all relevant suppliers and that audits have been carried out. Any negative results will be followed up as quickly as possible and, if necessary, we will take appropriate commercial action.
The response in its original language said: “Vielen Dank für Ihre Anfrage. Anbei darf ich Ihnen in Vertretung von Frau Völkel die Antwort des Unternehmens übermitteln: Seit der ersten Anfrage des Outlaw Ocean Project können wir bestätigen, dass wir mit allen relevanten Lieferanten Kontakt aufgenommen haben und dass Audits durchgeführt worden sind. Etwaige negative Ergebnisse werden so schnell wie möglich weiterverfolgt, gegebenenfalls ziehen wir angemessene geschäftliche Konsequenzen. Freundliche Grüße”
Cathleen Völkel of Rosam.Grünberger.Jarosch & Partner sent an additional email for Aldi South. A summary in English of this response: Since The Outlaw Ocean Project's initial request, we can confirm that we have contacted all relevant suppliers and that audits have been carried out. Any negative results will be followed up as quickly as possible and appropriate business consequences will be taken if necessary. Please understand that we will not comment publicly on the results of the audits. However, as a precautionary measure, we are temporarily not sourcing products from the production facilities named by The Outlaw Ocean Project.
The response in its original language said: “Wir haben noch einen kleinen Nachtrag – hier gelb hinterlegt. Seit der ersten Anfrage des Outlaw Ocean Project können wir bestätigen, dass wir mit allen relevanten Lieferanten Kontakt aufgenommen haben und dass Audits durchgeführt worden sind. Etwaige negative Ergebnisse werden so schnell wie möglich weiterverfolgt, gegebenenfalls ziehen wir angemessene geschäftliche Konsequenzen. Wir bitten um Verständnis, dass wir uns zu den Ergebnissen der Prüfungen nicht öffentlich äußern. Als Vorsichtsmaßnahme beziehen wir jedoch vorübergehend keine Produkte aus den von The Outlaw Ocean Project genannten Produktionsstätten. Liebe Grüße”
Paulina Burghardt of Rosam.Grünberger.Jarosch & Partner replied for Aldi South. A summary in English of this response: Since The Outlaw Ocean Project's initial inquiry, we can confirm that we have contacted all relevant suppliers and that audits have been carried out. Any negative results will be followed up as quickly as possible and, if necessary, we will take appropriate business action. We ask for your understanding that we will not comment publicly on the results of the audits.
The response in its original language said: “Anbei finden Sie das finale Statement. Wir wären Ihnen sehr dankbar, wenn Sie dieses in Ihrem Bericht berücksichtigen würden – vielen Dank! Seit der ersten Anfrage des Outlaw Ocean Project können wir bestätigen, dass wir mit allen relevanten Lieferanten Kontakt aufgenommen haben und dass Audits durchgeführt worden sind. Etwaige negative Ergebnisse werden so schnell wie möglich weiterverfolgt, gegebenenfalls ziehen wir angemessene geschäftliche Konsequenzen. Wir bitten um Verständnis, dass wir uns zu den Ergebnissen der Prüfungen nicht öffentlich äußern.”
The Outlaw Ocean Project’s publishing partner in Germany, Die Zeit, contacted Aldi South with additional questions. A summary in English of this email: What is the basis for your decision not to comment publicly on the results of the audits? What evidence do you offer regarding internal reviews, and that negative results are followed up and that appropriate business consequences are drawn if necessary? Under what system and with what consistency does this happen/has this already happened? Thank you for your efforts in answering these questions.
The query in its original language said: “Vielen Dank für Ihre Antwort. Worauf beruht es denn, dass Sie sich zu den Ergebnissen der Prüfungen nicht öffentlich äußern? In Ihrer Erklärung steht die Formulierung, dass das Unternehmen dafür „um Verständnis“ bitte, aber ohne weitere Begründung kann man ein solches Verständnis ja nicht haben. Welche Belege bieten Sie dafür an, dass interne Prüfungen in Ihrem Haus stattfinden, dass negative Ergebnisse weiterverfolgt werden, und dass gegebenenfalls angemessene geschäftliche Konsequenzen gezogen werden? Nach welchem System und in welcher Konsequenz geschieht dies/ist dies dies schon geschehen? Danke für Ihre Mühe mit den Antworten. Ihre Antworten, die Sie uns in den vergangenen Mails geschickt haben sind mehrere Tage nach unserer ursprünglichen Deadline eingegangen. Wir können sie glücklicherweise dennoch berücksichtigen, weil wir die Veröffentlichung verschoben haben, und tun das auch gern. Wir veröffentlichen nun in der aktuellen Woche. Der Redaktionsschluss mit einer Möglichkeit zur Berücksichtigung eventueller zusätzlicher Antworten ist morgen (Dienstag), 7.11., um 12:00. Mit freundlichen Grüßen”
Paulina Burghardt of Rosam.Grünberger.Jarosch & Partner replied for Aldi South. A summary in English of this email: ALDI SOUTH does not comment on internal processes for fundamental reasons. This also applies to internal audits of all business units. Of course, ALDI SOUTH has also committed itself to a clear due diligence procedure. Further information can be found here: ALDI SOUTH Group Due Diligence process.
The query in its original language said: “Anbei finden Sie das Statement zu Ihrer Anfrage. Wir hoffen, Sie können dieses noch berücksichtigen: Vielen Dank für Ihre Rückfragen. ALDI SÜD äußert sich aus grundsätzlichen Erwägungen nicht zu internen Prozessen. Dies trifft auch auf interne Audits aller eschäftsbereiche zu. Selbstverständlich hat sich ALDI SÜD darüber hinaus zu einem eindeutigen Due Dilligance Verfahren verpflichtet. Weitere Informationen dazu finden Sie hier: ALDI SOUTH Group Due Diligence process. Freundliche Grüße”
A coalition of eighteen NGOs wrote to thirteen major seafood distributors and retailers, including Aldi South Group, asking a series of questions connected to the Outlaw Ocean's reporting. Their email to Aldi South said: "Dear Aldi South,
We are writing to you on behalf of a consortium of human rights NGOs requesting an update on the steps Aldi South has taken following the investigation published by The Outlaw Ocean Project. The investigation highlighted concerns about state-imposed Uyghur and North Korean forced labor across the Chinese seafood processing facilities, including within your company’s supply chain.
Given the seriousness of these findings, we are keen to learn about the progress of your internal investigations that your company stated it would conduct. Please refer to the attached letter for detailed inquiries. We look forward to your prompt response by August 2, 2024.
Sincerely, Ethan Hee-Seok Shin, Transitional Justice Working Group Krysta Bisnauth, Freedom United"
The attached letter read:
"Dear Aldi South,
The undersigned organizations, experts on human rights, labor rights, Uyghur rights, North Korean rights, and trade law, are requesting an update on the steps Aldi South committed to take following the publication of a series of investigations published by The Outlaw Ocean Project. The findings on the investigations, which shed light on the use of state-imposed forced labor in your company’s seafood supply chain, are deeply concerning and demand immediate attention from all stakeholders in the industry.
In 2023, Aldi South stated it would investigate exposure to state-imposed forced labor in its downstream supply chains. Given the severity of the harms reported and the gravity of the situation and the potential impact on human rights and environmental sustainability, we are keen to learn about the progress of these investigations into your company's seafood supply chain.
We ask that you provide us with an update on the following points:
- The due diligence conducted to identify whether direct Chinese suppliers or sub-suppliers are using, or at risk of using, Uyghur or North Korean forced labor;
- Any preliminary findings or outcomes from these investigations, e.g., has your company identified Chinese suppliers or sub-suppliers using or at risk of using Uyghur or North Korean forced labor;
- Steps your company has taken or leverage used to cease supplier’s or sub-supplier’s participation in state-imposed forced labor programs, including poverty alleviation programs;
- Where suppliers or sub-suppliers did not cease their participation, or agree to a time bound plan to do so, whether your company disengaged, or has plans to disengage, from that business relationship;
- Steps your company has taken or plans to take to report this information to shareholders (if applicable), companies within your supply chain, consumers, or other stakeholders or otherwise make these findings publicly available.
We believe that maintaining a supply chain free from forced labor is not only a legal and ethical imperative, but also crucial for the sustainability of the seafood industry. Your prompt response and continued diligence in this matter are essential for upholding these standards. Please respond to these questions within three weeks of receipt. Information provided will inform ongoing investigations into forced labor in seafood supply chains.
Sincerely, Transitional Justice Working Group (TJWG) Hubert Younghwan Lee, Executive Director
Human Trafficking Legal Center Martina Vandenberg, Founder and President
The Committee for Human Rights in North Korea (HRNK) Greg Scarlatoiu, Executive Director
Advocates for Public Interest Law (APIL) Shin Young Chung, Attorney
HanVoice Sean Chung, Chief Executive Officer
The Citizens' Alliance for North Korean Human Rights (NKHR) Joanna Hosaniak, Deputy Director General
Corporate Accountability Lab Charity Ryerson, Executive Director and Founder
International Corporate Accountability Roundtable David McKean Deputy Director
Humanity United Action Emily Risko, Associate Program Manager - Forced Labor & Human Trafficking
International Federation for Human Rights (FIDH) Gaelle Dusepulchre, Deputy Director - Business, Human Rights and Environment
Uyghur American Association Elfidar Iltebir, President
Anti-Slavery International Chloe Cranston, Head of Thematic Advocacy Programmes
Uyghur Human Rights Project Omer Kanat, Executive Director
Freedom United Krysta Bisnauth, Advocacy Manager
Global Labor Justice Allison Gill, Legal Director
Investor Alliance for Human Rights Anita Dorett, Director
Campaign For Uyghurs Rushan Abbas, Founder And Executive Director
Worker Rights Consortium Jewher Ilham, Forced Labor Project Coordinator"
Aldi South responded, saying: "Dear Ethan, Krysta,
Please accept this email as an acknowledgement of receipt for your enquiry. We are processing your enquiry and will share our response in due course.
Best regards."
Aldi South responded to the letter from the NGO coalition: "Dear Ethan,
As an international retailer with global supply chains, the ALDI SOUTH Group is aware of its responsibility to respect human and environmental rights. We take any reports of human and environmental rights abuses committed in our supply chains very seriously.
The ALDI SOUTH Group is highly committed to its due diligence processes, which are regularly reviewed and revised to ensure their effectiveness. The Group collaborates closely with its business partners in the fish and seafood supply chains to clearly communicate its stringent expectations and address any non-compliance issues found.
The ALDI SOUTH Group has performed multiple ad-hoc risk assessments, including supply chain mappings and unannounced on-site visits and audits to verify any connections in light of the related allegations. At the time of these assessments, none of the allegations against the ALDI SOUTH Group could be confirmed. In cases when the ALDI SOUTH Group’s business partners failed to provide the required access or did not meet the Group’s transparency standards, and demonstrated an unwillingness to collaborate, business relationships were ceased.
The ALDI SOUTH Group’s due diligence framework was created to facilitate the systematic monitoring and assessment of human rights and environmental risks in our supply chains. This enables us to comply with due diligence legislation and meet our broad human rights and environmental commitments. The ALDI Business Partner Sustainability Standards outline our minimum requirements for ALDI’s business partners. They cover such topics as non-tolerance for forced labor, child labor and discrimination, as well as requirements around environmental stewardship, freedom of association and occupational health and safety.
In collaboration with internal and external supply chain experts, the ALDI SOUTH Group has also developed a Corporate Responsibility Supplier Evaluation (CRSE) program. This approach goes beyond certification or conducting audits and focuses on the Group’s business partners’ social and environmental compliance management systems as well as their facilities’ sustainability performance. The CRSE is being implemented in relevant high-priority supply chains, including fish and seafood.
The ALDI SOUTH Group will continue to monitor the situation, and we will ensure the continuation of our close cooperation with our business partners and key stakeholders to reduce risks.
Sincerely, International Sustainability – ALDI SOUTH Group"