Correspondence
Email sent to the contact address for Imaex Trading Co. Ltd.
The email said: "I’m writing to you in light of our latest investigation, which concerns abuses in the Chinese squid fishing industry, and a link we’ve discovered between companies engaged in abuses and your supply chain.
Imaex Trading’s supplier Rongcheng Runtong Aquatic Products Co. Ltd. is Chishan Group company. Fishing vessels owned by the group have been observed fishing in North Korean waters in contravention of UN sanctions and fishing illegally in Indonesian waters. The group also owns at least two reefer vessels which have transshipped with dozens of fishing ships tied to illegal, unreported and unregulated fishing as well as human rights abuses.
At least two seafood processors under the Chishan Group (Shandong Haidu and Rongcheng Haibo) have received persons from the Xinjiang Uyghur Autonomous Region of the People’s Republic of China under the state-imposed labor transfer program. 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 leave employment.
Another of Imaex Trading’s suppliers, Shantou Haimao, sources squid caught by Chinese vessels in waters claimed by Taiwan, an act described as illegal by U.S. authorities.
Imaex Trading has imported squid products from the Chinese seafood processor Rongcheng Guangrun Aquatic Food, a company owned by Shandong Bodelong Group. Bodelong Group vessels have fished illegally in the South Atlantic and the South Pacific Oceans, and have disembarked at least two dead deckhands in the Port of Montevideo, in 2016 and 2019. One vessel also disembarked an ill deckhand in Montevideo in 2020 who had symptoms of beriberi, a sign of severe neglect.
Does Imaex Trading have any comment to make in light of the above? Please let me know by close of business July 18, 2023."
The Outlaw Ocean Project emailed the contact address for Imaex Trading: "We previously contacted Imaex Trading on July 13, 2023, regarding our investigation into China’s seafood processing industry and squid fishing fleet. We have additional findings to bring to your attention, as they relate to Imaex Trading’s supply chain.
We have uncovered evidence that Dandong Hailong Foodstuff used North Korean labor after the December 2019 deadline for the repatriation of overseas North Korean workers required under United Nations Security Council sanctions. This evidence shows North Korean labor at Dandong Hailong Foodstuff’s factory in Liaoning, China, as recently as 2023. Under the Countering America's Adversaries Through Sanctions Act (CAATSA), passed in 2017, the U.S. prohibits the import of any goods produced by North Korean nationals unless clear and convincing evidence is provided that indicates the materials were not made with forced labor.
Trade data seen by The Outlaw Ocean Project shows that Imaex Trading was the consignee for dozens of shipments of seafood from Dandong Hailong since 2019. While we understand that you may not be aware of the above issues, does Imaex Trading have any comment to make in response to this email? Can you confirm if any product sourced from Dandong Hailong has been supplied by Imaex Trading to Siam Store, Chicago Oriental Wholesale Market, or Gainsville Seafood Market & Eatery since June 2019?"