Correspondence
Email sent to Schwarz Gruppe’s press office, which handles Lidl media inquiries.
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 Lidl's supply chain.
Our investigation has found that Lidl’s own brand of squid, under the Eridanous range, is processed at a seafood plant in China called Zhoushan Xifeng Aquatic Co. Ltd. It is supplied by at least three companies whose vessels have a history of fishing offenses, including lengthy transmission gaps, illegal fishing and shark finning. For example, one of these vessels had a 42-day transmission gap while operating in the northwestern Pacific Ocean, while another of the vessels fished illegally in Peru’s exclusive economic zone.
Lidl’s commitments under ‘A Better Tomorrow’ state: “We are certain that successful business can only be maintained with respect for human rights and environmental standards. Consequently, we take our corporate responsibility for respecting human rights and environmental standards seriously. Through a risk-based management approach, human rights and environmental risks can be identified and addressed through appropriate preventive measures and, if a risk occurs, rectified through corrective measures.”
Given those commitments and the information here, does Lidl have any comment to make on the record? Please reply to this email by end of day March 8, 2023."
Lidl’s Corporate Communications International team replied: "Thank you for contacting us. In order to be able to deal with your inquiry appropriately and to consult with the responsible departments and stakeholders, we kindly ask you for an extension of the deadline. We will be able to get back to you by the middle of next week. Please let us know if this is compatible with your timing."
Lidl replied: "Thank you for your inquiry. The practices you described are not acceptable to Lidl. In our business activities, we take responsibility, respect and protect the fundamental rights of all stakeholders in the different stages of our supply chains. Our commitment to implementing social and environmental standards in the supply chain is enshrined in our Code of Conduct, which is part of our legally binding agreement and applies to the entire supply chain. Our Code of Conduct applies to all companies of Schwarz Group, as well as all Lidl country units. We have also published a comprehensive corporate due diligence declaration on our website. As part of our corporate responsibility, we continuously and systematically examine potential risks in the supply chains. If we have specific facts about violations of our regulations, we will investigate the matter and initiate appropriate measures.
Therefore, we have already requested a statement from Zhoushan Xifeng Aquatic Co. Ltd. via our direct supplier for squid, Vassiliou Trofinko SA. Zhoushan Xifeng Aquatic Co. Ltd. has confirmed to us in writing that they are not involved in fishing offenses, including the practices you described. Please see their statement attached to this e-mail.
Having a complete understanding of where our fish and seafood originates from is important to our business and our customers. Lidl is opposed to Illegal, Unreported and Unregulated Fishing (IUU), which is the term used to describe any unauthorized fishing activities conducted in breach of regional, national or international rules or obligations. Through our focus on traceability and transparency we are taking steps to mitigate the risks associated with IUU fishing and labor rights abuses.
Please note that the product you addressed is purchased by Lidl Greece and only sold in Greece and Cyprus.
Further information can be found here - for language reasons, these links lead to the website of Lidl Great Britain: • [Code of Conduct](https://corporate.lidl.co.uk/content/download/38865/fileupload/Code%20of% 20Conduct%20Lidl%20GB.pdf)
• [Corporate due diligence](https://corporate.lidl.co.uk/content/download/38847/ fileupload/Human%20Rights%20and%20Environmental%20Due% 20Diligence%20Policy%202020%20December.pdf) "
The email included an attachment with a declaration from Zhoushan Xifeng Aquatic dated March 10, 2023: "We Zhoushan Xifeng Aquatic Co. Ltd. herewith declare that our company is not involved in any fishing offenses, including lengthy transmission gaps, illegal fishing and shark finning. Vassiliou Trofinko has always instructed us to buy raw materials only from legal sources and from vessels that are duly registered and approved by EU. Vassiliou Trofinko has clearly declared that all raw materials should come from vessels following sustainable practices. Vassiliou Trofinko SA has clearly stated that all human rights should be respect at all stages of fishing, production and final packaging of products. Vassiliou Trofinko SA has clearly stated that child labour is condemned. All the raw materials purchased by our company are approved by the government and issued by the legal fishing certificate.”
The Outlaw Ocean Project replied: "Thank you very much for your response to our email, we really appreciate your engagement on this issue and your transparency with us in sharing your supplier statement.
Industry analysts and experts have, however, told us that traceability from China is highly unreliable, despite various certification programs depended on by buyers and importers. This is largely due to gaps in record-keeping as product passes from point of catch to point of export, with documentation often filled in retrospectively to meet buyer requirements without effective oversight to verify compliance. We have visual evidence of bags of squid from the companies we cited previously in the Xifeng plant, and we have extensive evidence of those companies' ties to IUU activity. For example, we have video and images of bags from Zhoushan Han Yi arriving in September 2021. The Han Yi 3, 7, 21, 22 each have a history of lengthy transmission gaps, while crew from the Han Yi 21 said shark finning and walrus hunting was carried out while they were on board.
Zhejiang Zhou Pu Ocean Fisheries, meanwhile, also owns multiple squid vessels with regular transmission gaps, and its vessel Pu Yuan 825 was fined for illegal fishing inside Peruvian waters in 2020. Another of its vessels, the Zhou Pu 818, fished without authorization in the SPRFMO in 2021.
We have also recently identified packaging from another company, Zhoushan Run Da Ocean Fishing, a company which owns at least six jiggers that have had multiple long transmission gaps in squid fisheries in the South Pacific and South Atlantic since 2019.
In light of these details, do you feel that the supplier statement you have been given provides adequate assurances that Lidl's supply chain is free from IUU? Regarding your assertion that the Eridanous squid rings product is only available in Greece/Cyprus: our reporting team has visual evidence of the product on sale in Ireland in January 2023. Searches on Google also indicate that Eridanous Tintenfischringe have been on sale in Germany and Austria recently. Can you please clarify what markets it is available in, or has been available in in the past?"
Lidl replied: "Thank you for getting back to us with further information. We take our corporate responsibility as well as these allegations very seriously. As we mentioned before, the practices you described are not acceptable to us. We also expect honesty and compliance with our regulations and guidelines from our suppliers throughout our business relationships as well as proof that these guidelines have been complied with. We are therefore also examining the situation from a compliance perspective. Since your inquiry, we have been in contact with our supplier and are currently evaluating the best possible options to address the matter in the most effective way.
In order to be able to press ahead with our investigations, sound evidence is also of great importance to us. To support our investigations, we would appreciate it if you could share with us some of the evidence you mentioned regarding IUU activities, as this would enable us to thoroughly and specifically trace possible violations of our guidelines together with our supplier. This includes the following information:
- Could you please provide more specific details on the transmission gaps (time and location), e.g. for Zhoushan Han Yi 3, Zhoushan Han Yi 7, Zhoushan Han Yi 22, Zhoushan Han Yi 21, Zhejiang Zhou Pu Ocean Fisheries’ vessels, Zhoushan Run Da Ocean Fisheries’ vessels and on the vessel with a 42-day transmission gap?
- Could you please provide us further materials on the information, that Zhoushan Han Yi 21 engaged in shark finning and walrus hunting?
- Would you mind sharing more information with us, that Zhejiang Zhou Pu Ocean Fisheries’ vessel Pu Yuan 825 engaged in illegal fishing in Peruvian Waters in 2020?
- Would you please share further information with us about Zhejiang Zhou Pu Ocean Fisheries’ vessel Zhou Pu 818 presumably engaging in illegal fishing without authorization of SPRFMO in 2021?
In case you’d like to share any documents (e.g., visual evidence - videos, photos, ...) on this topic with us, we can provide an upload link via a file-sharing platform. We will, of course, keep any shared information confidential and are careful to protect whistleblowers.
Please note that such investigations must be carried out with neutrality and hence require some time since pinpointing the violations is necessary to implement effective measures. For a thorough investigation and a final conclusion, this process can take several weeks. We highly appreciate your patience. More information on compliance at Lidl can be found here: https://info.lidl/en/compliance, including our procedural guidelines for compliance cases.
Regarding your question about the availability of squid in other Lidl countries we would like to clarify, that the Eridanous brand squid is only available in the fixed assortment in Greece and Cyprus. In other Lidl countries, it was available as promotional goods for a limited time.
In our business activities, we strive to minimize any negative impact on society and the environment. We are seriously interested in the comprehensive processing of cases in which our compliance guidelines are violated. To this end, we exchange ideas with relevant contact persons in order to take their expertise and experience into account in our business activities. For this reason, we would like to invite you to an off-the-record dialog with our specialist departments. Please let us know if you are interested. We look forward to an exchange."
The Outlaw Ocean Project replied: "Thanks for your email, we really appreciate your interest in the issues and incidents highlighted in our recent correspondence and that you are conducting your own inquiry into these matters. Given the nature of our reporting and our obligations of confidentiality to sources, we are unable to give you some of the source materials requested, but are happy to give you more specifics where we can:
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Could you please provide more specific details on the transmission gaps (time and location), e.g. for Zhoushan Han Yi 3, Zhoushan Han Yi 7, Zhoushan Han Yi 22, Zhoushan Han Yi 21, Zhejiang Zhou Pu Ocean Fisheries’ vessels, Zhoushan Run Da Ocean Fisheries’ vessels and on the vessel with a 42-day transmission gap? Vessel tracking information for these ships was gathered via Global Fishing Watch and analyzed for the period 2017 to 2022.
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Could you please provide us further materials on the information that Zhoushan Han Yi 21 engaged in shark finning and walrus hunting? The behavior in question occurred between 2019 and 2021, but we are unable to share the specific sourcing on this due to confidentiality obligations.
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Would you mind sharing more information with us, that Zhejiang Zhou Pu Ocean Fisheries’ vessel Pu Yuan 825 engaged in illegal fishing in Peruvian Waters in 2020? Details on this matter hail from Peruvian Ministry of Production records.
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Would you please share further information with us about Zhejiang Zhou Pu Ocean Fisheries’ vessel Zhou Pu 818 presumably engaging in illegal fishing without authorization of SPRFMO in 2021? Further details on the Zhou Pu 818 fishing without authorization inside the SPRFMO area can be found in this Global Fishing Watch July 2021 report, ‘Analysis of the Southeast Pacific Distant Water Squid Fleet’
We also appreciate your offer to speak with Lidl’s specialists to discuss how compliance issues are managed by the company. I’m unavailable next week, but am CC’ing my colleague who can help with the scheduling on this."
The Outlaw Ocean Project emailed: "I hope you are all keeping well. We are approaching publication for our squid investigation and wanted to come back to you to see if Lidl has any comment or statement you wish to add to the previous on-record statement?"
Lidl replied: "Thank you for contacting us again and please excuse that we haven’t come back to you yet. Right now, we do not want to make any additions to our previously submitted on-the-record statement. Thank you very much and all the best."
The Outlaw Ocean Project's publishing partner in Germany, Die Zeit, contacted Lidl for comment on the investigation.
Lidl replied with a statement, saying: "We take such allegations very seriously and the practices described below are not acceptable to Lidl. We were also in direct exchange with 'The Outlaw Ocean Project' on this to discuss the allegations and our handling of such cases. Lidl is committed to its corporate duty of care. We are therefore working hard to minimize negative impacts in our supply chains, to effectively remedy rights violations, and to use our influence for positive change." The statement added that Lidl had examined the concerns raised by The Outlaw Ocean Project: "We immediately contacted our direct suppliers to investigate these allegations. For the specific case of illegal fishing highlighted by Outlaw Ocean, the business relationship with the affected supply chain actor was suspended by our direct supplier due to limited cooperation. With respect to the information we received regarding human rights violations, we remain in the process of investigating the allegations, including working with national industry initiatives such as The Seafood Ethics Action (SEA)."
The Outlaw Ocean Project's publishing partner in Germany, Die Zeit, asked Lidl for an update on its internal review into the findings of The Outlaw Ocean Project’s investigation.
Lidl International’s Corporate Communications team replied. A summary in English of this email: Lidl takes the allegations raised in The Outlaw Ocean Project’s investigation seriously and the practices described are not acceptable to Lidl. Therefore, the company has immediately contacted its direct suppliers to investigate the allegations and is currently checking its entire fish and seafood supply chain for such links. Lidl asks for your understanding that these investigations are thorough and take a long time due to the complexity of international supply chains. The company plans to have further discussions with The Outlaw Ocean Project once the comprehensive review of supply chains is complete. For the specific case of illegal fishing highlighted by Outlaw Ocean, the business relationship with the affected supply chain actor was suspended by our direct supplier due to limited cooperation. Lidl is till investigating the allegations with regard to the information we received on human rights violations. One of the production facilities concerned has now also been blocked by Lidl’s direct supplier.
The email in its original language said: “Vielen Dank für Ihre Anfrage und die Möglichkeit, unser Statement vom 09. Oktober (siehe unten) noch einmal zu ergänzen. Wir möchten noch einmal darauf hinweisen, dass wir im direkten Austausch mit „The Outlaw Ocean Project“ waren, um über die Vorwürfe und unseren Umgang mit solchen Fällen zu sprechen. Die Vorwürfe nehmen wir sehr ernst und die von Outlaw Ocean beschriebenen Praktiken sind für Lidl nicht akzeptabel.
Wir haben daher umgehend Kontakt mit unseren direkten Lieferanten aufgenommen, um diesen Vorwürfen nachzugehen. Derzeit prüfen wir unsere gesamte Lieferkette für Fisch und Meeresfrüchte auf entsprechende Verbindungen. Wir bitten um Verständnis, dass diese Untersuchungen gründlich durchgeführt werden und aufgrund der Komplexität von internationalen Lieferketten viel Zeit in Anspruch nehmen. Wir planen mit „The Outlaw Ocean Project“ weitere Gespräche zu führen, sobald die umfassende Prüfung unserer Lieferketten abgeschlossen ist.
Für den spezifischen von Outlaw Ocean aufgezeigten Fall von illegaler Fischerei wurde die Geschäftsbeziehung mit dem betroffenen Lieferkettenakteur durch unseren direkten Lieferanten aufgrund von eingeschränkter Kooperation ausgesetzt. Bezüglich der uns zugespielten Informationen zu Menschenrechtsverletzungen befinden wir uns weiterhin in der Untersuchung der Vorwürfe. Eine der betroffenen Produktionsstätten wurde inzwischen ebenfalls von unserem direkten Lieferanten gesperrt.
Statement vom 09.10.: Wir nehmen solche Vorwürfe sehr ernst und die unten beschriebenen Praktiken sind für Lidl nicht akzeptabel. Wir waren hierzu auch im direkten Austausch mit „The Outlaw Ocean Project“, um über die Vorwürfe und unseren Umgang mit solchen Fällen zu sprechen. Lidl bekennt sich zu seiner unternehmerischen Sorgfaltspflicht. Wir arbeiten daher intensiv daran, negative Auswirkungen in unseren Lieferketten zu minimieren, bei Rechteverletzungen effektiv abzuhelfen und unseren Einfluss für positive Veränderung zu nutzen.
Mit unserer Grundsatzerklärung bekennen wir uns unmissverständlich zur Achtung der Menschenrechte und umweltbezogenen Pflichten. Über unseren Code of Conduct für Geschäftspartner legen wir soziale und ökologische Mindeststandards für die Zusammenarbeit fest und bringen dies in Verhandlungen mit unseren Geschäftspartnern ein. Sollten uns konkrete Sachverhalte bezüglich Verstößen gegen diese Bestimmungen vorliegen, gehen wir dem nach und leiten entsprechende Schritte ein. Wir prüfen kontinuierlich und systematisch potenzielle menschenrechtliche, soziale und umweltbezogene Risiken in unseren Lieferketten. Ziel ist es, diese Risiken zu erfassen und zu minimieren.
Die von „The Outlaw Ocean Project“ gegenüber uns vorgebrachten Fälle haben wir daher auch aus Compliance-Sicht geprüft. Wir haben umgehend Kontakt mit unseren direkten Lieferanten aufgenommen, um diesen Vorwürfen nachzugehen. Für den spezifischen von Outlaw Ocean aufgezeigten Fall von illegaler Fischerei wurde die Geschäftsbeziehung mit dem betroffenen Lieferkettenakteur durch unseren direkten Lieferanten aufgrund von eingeschränkter Kooperation ausgesetzt. Bezüglich der uns zugespielten Informationen zu Menschenrechtsverletzungen befinden wir uns weiterhin in der Untersuchung der Vorwürfe, unter anderem auch in Zusammenarbeit mit nationalen Brancheninitiativen wie der The Seafood Ethics Action (SEA). Weitere Informationen zum Thema Compliance bei Lidl finden Sie unter https://info.lidl/de/compliance inklusive unserer Verfahrensrichtlinie für Compliance-Fälle.
Ein Verständnis darüber, woher unsere Fische und Meeresfrüchte stammen, ist sowohl für uns als auch für unsere Kunden wichtig. Wir sprechen uns daher deutlich gegen illegale, nicht gemeldete oder nicht regulierte Fischerei (IUU Fishing = Illegal, Unreported and Unregulated Fishing) sowie gegen illegale Fischereimethoden aus. Wir verlangen auch von unseren Lieferanten, dass sie auf risikoorientierte Verfahren setzen und auf die Verwendung von Rohware aus IUU-Fischfang verzichten. Wir unterstützen Initiativen wie die „Initiative des Handels gegen illegalen Fisch“ des WWF, die sich dafür einsetzt, dass auch politisch geeignete Maßnahmen ergriffen werden, um die Umsetzung des Anladegebots sicherzustellen. Weitere Informationen zu unseren Maßnahmen finden Sie auch in unserem Positionspapier für den nachhaltigen Einkauf von Fisch, Schalentieren und deren Erzeugnissen: 49182.
Viele Grüße Unternehmenskommunikation International”
The Outlaw Ocean Project's publishing partner in the UK, Sky News, contacted Lidl for comment on the investigation.
Lidl International’s Corporate Communications team replied: “We take such allegations very seriously and the practices described by Outlaw Ocean are not acceptable to Lidl. We were also in direct contact with The Outlaw Ocean Project to discuss the allegations and our handling of such cases. Lidl is committed to its corporate due diligence. We are therefore working intensively on minimizing negative effects in our supply chains, effectively remedying rights violations and using our influence for positive change.
With our Policy Statement, we are unequivocally committed to respecting human rights and environmental obligations. Through our Code of Conduct for business partners, we set minimum social and ecological standards for cooperation and incorporate this into negotiations with our business partners. If we have specific facts regarding violations of these provisions, we will investigate and take appropriate steps. We continuously and systematically review potential human rights, social and environmental risks in our supply chains. The aim is to record and minimize these risks.
We have therefore also examined the cases presented to us by The Outlaw Ocean Project from a compliance perspective. We immediately contacted our direct suppliers to investigate these allegations. We are currently reviewing our entire fish and seafood supply chain for relevant links. We ask for your understanding that these investigations are carried out thoroughly and take a long time due to the complexity of international supply chains. We plan to have further discussions with The Outlaw Ocean Project once the comprehensive review of our supply chains is completed. For the specific case of illegal fishing highlighted by Outlaw Ocean, the business relationship with the affected supply chain actor was suspended by our direct supplier due to limited cooperation. With regard to the information presented to us on human rights violations, we are still investigating the allegations, including in cooperation with national industry initiatives such as The Seafood Ethics Action (SEA). One of the affected production sites has also been blocked by our direct supplier.
Further information on the topic of compliance at Lidl can be found at https://info.lidl/en/compliance, including our procedural guidelines for compliance cases. Understanding where our fish and seafood comes from is important for both us and our customers. We therefore speak out against illegal, unreported or unregulated fishing (IUU fishing) as well as against illegal fishing methods. We also require our suppliers to use risk-oriented procedures and refrain from using raw materials from IUU fishing. We support initiatives such as the WWF's “Initiative of Trade Against Illegal Fish”, which is committed to ensuring that appropriate political measures are taken to ensure the implementation of the loading requirement. Further information on our measures can also be found in our position paper for the sustainable purchase of fish, shellfish and their products: https://unternehmen.lidl.de/pdf/show/49182.”
The Outlaw Ocean Project emailed Lidl: "We were in contact with Lidl in 2023 regarding our investigation into China’s squid fishing and seafood processing industries. Our ongoing investigation into the use of forced labor in Chinese seafood plants has uncovered additional evidence which we wanted to bring to your attention.
We have investigators on the ground in China who have been engaging with labor brokers directly involved with the transfer of North Korean workers to factories in China. Through this and other investigative means, including collecting online footage from the plants and interviews with workers recently returned to North Korea from China, we’ve found large numbers of North Korean workers at a range of seafood processing plants in Liaoning province, on China’s border with North Korea. These include plants belonging to companies called Dalian Haiqing Food, Donggang Haimeng Foodstuff and Dandong Hailong Foodstuff.
According to trade records seen by The Outlaw Ocean Project, the Polish company Abramczyk Sp. Z O.O. was the consignee for shipments of seafood from Dalian Haiqing, Donggang Haimeng and Dandong Hailong in 2021. Trade records also show that the Portuguese company Riberalves was the consignee for shipments from Donggang Haimeng in 2021.
The use of overseas North Korean workers was prohibited by the United Nations Security Council in 2017, with Resolution 2397 setting a deadline of December 2019 for the repatriation of all such workers to North Korea. Under the Countering America's Adversaries Through Sanctions Act (CAATSA), passed in 2017, the United States 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.
Lidl store brochure details show that Abramczyk Sp. Z O.O. has supplied seafood to Lidl Poland, and that Riberalves has supplied fish to Lidl in Portugal.
In light of the above, we have some questions for Lidl:
- While we understand that you may not be aware of the above issues, we want to ask if Lidl has any comment to make in response to this email?
- Has Lidl been supplied with fish from Donggang Haimeng, Dalian Haiqing or Dandong Hailong since December 2019?"
Lidl International's corporate communications team replied: ""Thank you for your inquiry. Lidl is committed to its corporate due diligence. We are therefore working intensively on minimizing negative effects in our supply chains, effectively remedying rights violations if necessary and using our influence for positive change. In addition, our Code of Conduct for suppliers describes the fundamental principles for cooperation with business partners and is based on the ILO labor standards. If we become aware of specific instances of violations of these provisions, we investigate them and take appropriate action. We continuously and systematically review potential human rights, social and environmental risks in our supply chains. The aim is to identify and minimize these risks. We also expect honesty and compliance with our regulations and guidelines from our suppliers throughout our business relationships as well as proof that these guidelines have been complied with. We take information of this kind very seriously, which is why we will investigate whether fish is being sourced from the companies you mentioned. We ask for your understanding that such investigations must be carried out with neutrality and might take some time due to the complexity of the seafood supply chain. We therefore thank you for your patience."
A coalition of eighteen NGOs wrote to thirteen major seafood distributors and retailers, including Lidl, asking a series of questions connected to the Outlaw Ocean's reporting. Their email to Lidl said: "Dear Lidl,
We are writing to you on behalf of a consortium of human rights NGOs requesting an update on the steps Lidl 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 Lidl,
The undersigned organizations, experts on human rights, labor rights, Uyghur rights, North Korean rights, and trade law, are requesting an update on the steps Lidl 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, Lidl 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"
Lidl responded to the NGO coalition letter, saying: "Dear Mr. Hee-Seok Shin, thank you again for your inquiry.
Lidl is committed to its corporate due diligence. We are therefore working intensively on minimizing negative effects in our supply chains, effectively remedying rights violations if necessary and using our influence for positive change. With the policy statement of our human rights strategy we are unequivocally committed to respecting human rights and environmental obligations. Our Code of Conduct for Business Partners sets out minimum social and environmental standards for cooperation and we incorporate these into negotiations with our business partners. If we become aware of specific instances of violations of these provisions, we investigate them and take appropriate action. We continuously and systematically review potential human rights, social and environmental risks in our supply chains. The aim is to identify and minimize these risks.
We take information of this kind very seriously and therefore began an investigation immediately after we became aware of the concerns raised by The Outlaw Ocean Project regarding forced labor. International supply chains such as these are highly complex, so such investigations take some time and require a high degree of sensitivity. Since the allegations became known, we have been in close contact with our colleagues in the Lidl countries, our suppliers, and organizations that can support us in the process, such as NGOs, pre-competitive retail platforms and auditing companies. We are also planning further discussions with relevant stakeholders (NGOs, certifiers, partners, suppliers etc.) to ensure that we can find a viable solution in the interests of all parties. We ask for your understanding that such investigations must be carried out with neutrality and that these processes continue to take some time due to their complexity. We cannot provide you with more detailed information at the moment due to the ongoing compliance process. We thank you for your patience.
Best regards, Corporate Communications International"