Correspondence
Email sent to Stove Boat Communications which handles press for Lund’s Fisheries.
The email said: "I understand you handle media queries for Lund’s Fisheries and so 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 Lund's supply chain.
This link concerns a Chinese squid jigger owned by the Chinese fishery company, Rongcheng Wangdao Ocean Aquatic Products. In a seven-month period, one crew member died and a second was disembarked for emergency medical treatment after suffering serious mistreatment and abuse while on board the vessel. Our reporting documents multiple indicators of forced labor among crew onboard the vessel: recruitment linked to debt, deceptive recruitment, enforced isolation, degrading living conditions, physical violence, wage withholding, the retention of personal identity documents and strong financial penalties for leaving employment.
We have traced squid caught by that vessel and transshipped to two large refrigerated vessels called the Hai Feng 678 and the Hai Feng 698, both belonging to the state-owned China National Fisheries Corporation. Import records show that the China National Fisheries Corporation’s biggest customer, Shandong Zhonglu Ocean (Yantai) Food, exported over 930 US tons of frozen squid to Lund’s over the 2018-2022 period.
Separately, the vessel has also transshipped with a refrigerated ship owned by the Chishan Group, whose processing plant Rongcheng Haibo exports squid to Lund’s. In turn, Lund’s Fisheries supplies squid to Performance Food Service, among other buyers.
Does Lund’s Fisheries have any comment or statement to make on the record in response to this information?"
Bob Vanasse of Stove Boat Communications responded by phone and email to convey Lund’s interest in discussing the findings of The Outlaw Ocean Project’s investigation, and the company’s multifaceted efforts to ensure their supply chain is free of illegal, unreported, or unregulated fishing and human rights violations.
Bob Vanasse at Stoveboat Communications emailed: "I've been working with Lunds on looking into the information you sent last week. We need another day or two, but I anticipate they will want to respond. Thank you for reaching out on this matter."
Eight members of staff from Lund’s and three from The Outlaw Ocean Project had a group video call. The Outlaw Ocean Project discussed the findings of the investigation into China’s distant-water squid fishing fleet. Lund’s said that the squid they received from Chishan was only sourced from Spanish- or Agentinian-flagged vessels, while the squid that is processed for them at Zhonglu is squid that Lund’s caught in U.S. waters, freezes at their facility, and then sends over to China for processing and to be exported back to Lund's. The company also said they have two people working full-time for them in China, one of whom goes back and forth between the different processors to inspect conditions for them on-site. Lund’s also discussed the difficulties for them and similar companies as regards having full visibility on what happens on Chinese ships, given the lack of oversight bodies on that specific issue. Lund staff said they were interested in engaging with The Outlaw Ocean Project in working on the wording of their submission regarding the potential expansion of the U.S. Seafood Import Monitoring Program to include squid.
The Outlaw Ocean Project emailed Lund’s: "Thank you again for taking the time to meet with us on Monday to discuss our squid investigation findings and to talk through the concerns it has raised.
As we said during the call, we do have some follow-up questions and points on which we’re very interested to hear your input. To reiterate, we are very aware that Lund’s has a positive track record in holding its supply chain to a very high standard and in pushing for greater sustainability in the seafood industry. That’s a big part of why we want to be as open as possible with you about the kinds of things our investigation has found.
- Traceability: During Monday’s call you made a broader point about the traceability of your squid sourcing, saying: “We have catch certificates. We have certificates of the product arriving in China, certificates of the product exporting out of China, and then obviously everything from there.” You also said that your Chinese processors “all have a MSC chain of custody in place”. However, MSC standards are really not transferable from one species to another: squid coming from a non-MSC fishery cannot have a MSC chain of custody. Our understanding from the call is that the Argentinian- and Spanish-flagged squid that is sourced for you and processed by the Chinese processors is not MSC fishery squid.
In sourcing squid that does not come from MSC fisheries, buyers often rely on documentation provided by the Chinese processors, in particular catch certificates, to understand the origin of purchased squid. We are hearing from other seafood companies and industry analysts that the problem with this approach is that the credibility of these certificates is limited because when squid reaches the storage or processing plants in China from one fishing ship, it is frequently mixed with that from other ships as bulk sellers trade between each other to top up their amounts.
Analysis of satellite tracking also reveals a high number of unreported transshipments at sea in the Chinese squid industry.
The added reason that there are concerns about the possibility of comingling is that much of the squid from the Chinese-processed supply chain is being off-loaded from Chinese and non-Chinese flagged vessels to transshipment vessels that then bring it back to processing plants in China, and the owner of the transshipment vessel and the processing plant is the same company, which increases the likelihood of topping-off. These factors undermine any ability for downstream customers to claim confidence that they know where or from which ships their squid is actually caught.
Beyond your catch certificates, do you have any other way of knowing that comingling isn’t happening at the reefer level? What specific steps has Lund's taken to identify and mitigate human rights risks connected to your suppliers?
Regarding the Chishan group of companies, which include your supplying processors Rongcheng Haibo and Rongcheng Jiamei Seafood Co. Ltd.: At least three of Chishan’s squid jiggers have been observed fishing in North Korean waters, despite UN sanctions, between 2017 and 2019, while a fourth vessel was reported for illegal fishing in Indonesian waters in 2020. What specific steps has Lund's taken to identify and mitigate human rights risks connected to your suppliers?
Chinese vessel ownership beyond Chinese-flagged jiggers: You mentioned that your squid comes off of Spanish- or Argentinian-flagged vessels. We’re wondering if any of your squid comes off of any of the ships on the list we have attached to this email?" The email included a list of 28 squid jiggers.
Wayne Reichle, President of Lund’s, replied: "In response to your email late last week please see our comments below:
"1. Correct there is no MSC certification within the Argentine fishery, but the Argentine EEZ fishery is a limited access fishery supported by catch and export documents managed by their government. In addition, each of the factories we work with are BRC certified as well. Like MSC, BRC and SQF audits contain Trace and Mass Balance exercise of unidentified items which is limited to 4 hours to complete and satisfy the audit.
Most countries require each block of squid (or seafood item) to be labelled with associated catch data of the plant or vessel. In January 2021, China customs required exporters to not only label exterior cartons but also label the plastic bag or block within the carton. While this created financial costs for many processors, it provides traceability to the individual block level. Regulation attached.
In my experience with reefer vessels upon possession, the captain and chief mate are responsible for the cargo onboard the vessel. Product is received onboard and a hatch plan is created to accurately keep track of the number of frozen blocks received from each fishing vessel. After a fishing vessel is finished discharging to a tramper vessel, the crew normally uses a separation net to mark a change in different vessels cargo. When a vessel reaches port(s), the vessel is discharged using the chief mates hatch plan. An accounting at destination between the receiver(s) and chief mate is expected to match or the reefer vessel would be liable for the shortage.
Topping off is not a term or practice we are familiar with.
New labeling regulations cited above requires product to be labeled prior to being received on the reefer vessel.
- Rongcheng Jiamei Seafood was officially cancelled or delisted in 2021.
Lund’s Fisheries is not carrying cleaned todarodes in its supply chain. However, after further investigations, Rongcheng Haibo Seafood confirmed it operates independently and has no beneficial association with Rongcheng Ocean Fishery. Rongcheng Haibo Seafood also confirmed they have not purchased any frozen todarodes from Rongcheng Ocean Fishery fishing vessels.
Lund’s Fisheries requires our suppliers to comply with an ethical audit standard scheme focused on working conditions and human rights in processing facilities in the following way: o Adhere to Lund’s Ethical Policy o Comply with an Ethical Audit standard scheme, specifically SMETA o Promote the development of policies addressing: § Social Responsibility including fundamental labor rights. § Confidential reporting of complaints and assurance systems at vessels and processing facilities that allow workers to report abuses and unfair treatment.
- There are two vessels that carry the name Xin Shi Ji 18. One is owned by a group in Zhoushan and another is owned by a Spanish Company Fandicosta. We can confirm that Rongcheng Haibo did purchase a parcel produced by the Xin Shi Ji 18 owned by Fandicosta and have been provided a full set of documents for reference.
None of the vessels appear on the combined IUU list (www.tm-tracking.org), which is the list we have used as reference.
If you have any additional questions, please feel free to reach out."
The Outlaw Ocean Project replied: "Thank you again for your continued engagement on this, we really appreciate the time and care you are taking to go through the issues raised in our research. In continuing our conversation on this, we have some follow-up questions:
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Our understanding of the BRCGS Global Food Safety Standard and Safe Quality Food (SQF) Edition 9 certifications is that they are primarily a site- and product-specific standards. Please could you clarify whether Rongcheng Haibo Seafood’s SQF certification is multi- site, whether all fishing vessels supplying raw material to Rongcheng Haibo are within scope of SQF and BRCGS audits and whether the squid imported by Lund’s from Rongcheng Haibo – specifically the Todarodes pacificus – falls under the SQF and BRCGS certifications?
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The Lund’s Supplier Declaration that Wayne sent us says: “The above-named company hereby agrees that it will do everything, within reason, to avoid doing business with any company, vendor, fishing vessel, or other entity, that engages in, supports, or otherwise condones any of the below, illegal activities” including forced labor and human trafficking. Given the limitations we’ve raised about MSC oversight of labor issues, what internal mechanisms does Lund’s have in place to check that each of its suppliers is in compliance with this declaration? And how does Lund’s handle reported breaches?
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We know Lund’s wants to avoid being associated with labor abuses, however most supply chain traceability measures help indicate where fish is caught but they do not indicate anything about conditions on the ships. Surely, Lund’s can only use what tools exist to prevent such concerns; does the lack of effective tools for tracking and countering labor issues on these vessels frustrate Lunds?
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Our investigation has documented hundreds of suspected transshipments at sea involving Chishan reefers. 84 of these suspected transshipments occurred just outside of the Argentine Exclusive Economic Zone (EEZ) during transmission gaps in vessel Automatic Identification Systems (AIS). Fishing vessels suspected to have transshipped with Chishan reefers during AIS transmission gaps include squid jiggers implicated in IUU fishing and the disembarkation of a dead crew member. This pattern of regular transshipments during AIS transmission gaps just outside of the Argentine EEZ is indicative of systematic efforts by Chishan to evade proper monitoring, control and surveillance. Does Lund’s have any response to these findings?
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Having squid processed at any plant (especially in China where insights into the plants is less available than in other countries) runs a real risk of it being commingled with catch from other vessels with great IUU or labor concerns. Even with catch certificates which are largely self reported and fairly thin on details when it comes to gear type, GPS coordinates of fishing location, and vessel conditions hardly ensures that a supply chain is free from these types of problems. Can you offer comment on these challenges?
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Wayne, you noted in your email that Lund’s Fisheries is not carrying cleaned Todarodes in its supply chain. The product descriptions for shipments from Rongcheng Haibo to Lund’s include frozen squid whole round (todarodes pacificus), some – but not all – of which is specified as being for bait. Is all of this squid for use as bait?
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To clarify re. Rongcheng Ocean Fishery: our research indicates that Rongcheng Ocean Fishery Company [荣成市海洋渔业有限公司] is a different company from Rongcheng Chishan Ocean Fishery Co., Ltd. [荣成市赤山远洋渔业有限公司], this latter being our company of primary interest. Can you confirm which of these two Haibo was referencing when it said it had no beneficial association or todarodes purchasing connections with Rongcheng Ocean Fishery?
Regarding Rongcheng Jiamei being officially canceled or delisted in 2021: Our investigation spans a five-year period including when Jiamei was operating, and Lund's importing."
Wayne Reichle of Lund’s replied: "Please see our follow up to your questions below. We would appreciate a response back to question 4 at your earliest convenience.
In light of our ongoing cooperation, we have received similar copies of your letter from others outside the US. The letters specifically call out Lund’s Fisheries, Town Dock, and Ruggerio seafood but leaves out other major importers of Todarodes? Does your research and reporting cover additional known importers of Todarodes and Argentine Illex?
Thanks
- Rongcheng Haibo is not a BRCG multi-site certificated site. The GFSI certification covers squid products, the company has met Lund’s Fisheries Approval Supplier Program requirements and analysis of their Hazard Analysis Critical Control Plan details, "All raw material should provide supplying proof"; " Fishing time, location, type, quantity, name and reg. # on supplying proof" "All material should come from the area approved by the state." This is a requirement that the raw material needs to be met to be used/processed in the plant and enables a traceback to the origin.
Lund’s Fisheries Supplier Approval Program utilizes currently accepted international practices and regulations and continues to implement improvements based on industry best practices and requirements.
- Our compliance team includes a Society of Human Resources Management Certified Professional. This certification includes international labor laws and regulations, as well as best practices for handling and responding to any violations of those regulations. We require SEDEX third party audits from all plants. Reported breaches will be investigated and the appropriate action taken, ranging from requiring changes in practices to stopping business relations;
An excerpt from the Sedex Members Ethical Trade Audit report of Roncheng Haibo: Current systems: i. The factory had/s a policy, endorsed at the highest level, covering human rights impacts and issues, and ensure it is communicated to all appropriate parties, including its own suppliers.
- Yes, it is frustrating. However, it is impossible to retroactively fix a problem. You take the information that is available, and you work towards a solution. Lund’s is actively participating is several initiatives and round-tables that are solely focused on addressing labor/human rights issues at sea. As previously discussed, Lund’s is the only squid processor/producer actively engaged in the NOAA CALM-CS initiative. Our compliance and government relations teams are members of working groups dedicated to standards and due diligence, as well as worker’s voice. Lund’s is utilizing currently accepted international methods and audits to ensure compliance and is always open to new processes when vetted and available.
At this time the NMFS is considering the expansion of Seafood Inspection and Monitoring Program, including squid species. We are reviewing the proposal and are hopeful that a documentation framework encompassing the vessel related issues we are discussing.
As of May 1st, 2023, the MSC will be implementing more stringent labor eligibility requirements for both fisheries and chain of custody certificate holders. With the Argentine Illex fishery slated for a Fishery Improvement Project to begin ASAP, with the end goal being MSC certification, that fishery will be subject to the new requirements. Below is a brief excerpt from the new requirement: The CAB shall: Confirm at initial application, and subsequent surveillance/recertification, that the applicant or certificate holder does not include an entity that has been convicted for a forced or child labor violation in the last 2 years. Consider an applicant or certificate holder as ineligible for audit, assessment or certification if: An entity that belongs to the applicant or certificate holder (client or client group) has been convicted for a forced or child labor violation in the last 2 years... If an entity that has been part of a certificate becomes convicted for a forced or child labor violation: Review and confirm that the certificate holder has excluded the convicted entity, and that the entity remains excluded from the certificate or their certificate membership status remains invalid, for 2 years from the date of the conviction.
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In order to respond, please provide more details as follows: How long were the transmission gaps and where were the starting and stopping points? What are the names and any identifying numbers of the reefer vessels allegedly owned by the Chishan group? What vessels had the transmission gaps, fishing vessels and/or Chishan’s transport vessel? What details do you have in reference to the dead crewmember and what vessel was involved? Specifically what jiggers are you referring to that were “implicated” and where are these details? Are you assuming the transshipment vessels bought and/or brought all products transported on their reefer vessel to a Chishan owned cold store or factory? Our current imports of cleaned calamari were harvested by Argentine or Spanish flagged vessels, inside of the Argentine EEZ that were offloaded in South American ports and exported to China for processing.
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This comingling statement is painting the entire industry with very broad strokes and at best is unfair and misleading. Lund’s has employees who are based in China, and who regularly visit/inspect the plants we are using to verify all operations are being conducted in a manner that meets or exceeds all Lund’s requirements for approved suppliers, including two annual audits which reduces the risk of IUU and legally harvested product being comingled. Furthermore comingling without recordkeeping, if found, would result in loss of SRC/SQF/MSC-COC certificates, effectively stopping, or drastically limiting, the ability of our suppliers to do business in the USA and EU and possibly other nations like Japan.
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Yes, for a period of time we imported whole frozen todarodes for bait purposes but during the past few years we have replaced that line with squid from domestic fisheries.
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Correct – we verified that these are two different companies. Rongcheng Chishan Ocean Fishery belongs to the Chishan group.
Relative to your interest in GPS fishing locations, our fishing vessels are required to only report the statistical areas in which they are operating (https://www.fisheries.noaa.gov/resource/map/greater-atlantic-region-statistical- areas). Catch certificates for our products do not reflect the statistical area fished, only the FAO zone (https://www.fao.org/3/az126e/az126e.pdf).
Wayne Reichle of Lund’s also sent a separate email that day, saying: "As a follow up, it is our understanding that Rongcheng Chishan Ocean Fishery Co., Ltd owns a number of jigger and trawl vessels in addition to 1 small, low horse power freight vessel that does not participate in distant fisheries.
It is our understanding that Rongcheng Ocean Fishery Company and Rongcheng Guangrun Aquatic Foods are under the Shangdong Bodelong Group. We were not able to identify if this group owns their own freight vessels."
The Outlaw Ocean Project emailed Lund's: "Thank you again for your cooperation on this. We really appreciate that you have been tireless in responding to our questions and engaging with us at length on these issues. In response to your query re. if our research and reporting covers additional known importers of Todarodes and Argentine Illex - yes, our project spans dozens of squid importers in the US.
We have just two further questions:
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Our impression is that Lund’s considers itself - and has been shown through your interactions with us - to be a cut above competitors in how you go about tackling the supply chain issues we’ve been discussing. Could you please tell us what you’re most proud of doing to date regarding labor and IUU?
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The continued participation of Lund’s in the NOAA CALM-CS initiative and active engagement with the proposals to expand SIMP indicate a commitment to addressing human rights and labor issues at sea. What additional tools do you wish there were in addressing concerns specifically related to human rights and labor?
In response to your request for further details from our research, it's difficult for us to answer how long each of the vessels on the other side of the transhipment was dark for as that information is not provided by the available tools; however, we have identified over 100 vessels in the Chinese squid fleet that routinely have gaps of seven days or more - and the majority of the fleet has had gaps of three or more days. Long transmission gaps are routine for most of the fleet.
The reefers are named the Lu Rong Yuan Yu Yun 008 (MMSI: 412336831) and Lu Rong Yuan Yu Yun 009 (MMSI: 412331486). It was the fishing vessels that were dark, not the reefers. Jiggers that have rendez-voused with the Chishan reefers and which are implicated in IUU include the Lu Jiao Nan Yuan Yu 177 (MMSI 412331001) and the Lu Rong Yuan Yu 701 (MMSI 412336833), while they and other jiggers that transshipped with the reefers also have a history of disabling their AIS for periods longer than one week.
Two vessels that transshipped with a Chishan reefer each dropped a dead crew member’s body at Montevideo port; one of those is the vessel we referenced in our first email to you, the Zhen Fa 7.
Are you assuming the transshipment vessels bought and/or brought all products transported on their reefer vessel to a Chishan owned cold store or factory? We are assuming this, yes - we have seen images from Chishan's processing plants of squid caught by other companies, including companies with a history of IUU and labor infractions, being delivered."
The Outlaw Ocean Project emailed Lund's: "We wanted to update you on the most recent findings of our investigation, which has focused on the use of forced labor in China’s seafood processing industry.
Further to our previous correspondence regarding your supplier Rongcheng Haibo, our research has found evidence that Uyghurs have been transferred to Rongcheng Haibo from China's Xinjiang province under a state-imposed program. Goods produced by forced labor from Xinjiang cannot be imported to the United States under the Uyghur Forced Labor Prevention Act.
This evidence includes materials produced by the Chishan Group about meetings between high-level management (including Haibo management) and the officials who run the labor transfer program, as well as documentation about persons from Xinjiang working at Haibo. The Chishan Group has written publicly about the use of such labor in newsletters available on their Chinese-language website. We have evidence that shows Uyghurs at the plant as recently as May 2023.
The Uyghur Forced Labor Protection Act, signed into law in December 2021, creates a presumption that goods produced in part or in full in the Xinjiang Uyghur Autonomous Region are the product of forced labor and cannot be imported to the United States unless an importer can provide clear evidence the imports were produced without the use of forced labor. This presumption also applies to goods made by Uyghurs transferred out of Xinjiang via ‘labor-transfer’ programs.
Does Lund’s have any comment or statement to make in light of the above information?"
Wayne Reichle, President of Lund's replied: "It is difficult for us to comment on your allegations without any factual information being supplied from your investigation. As previously discussed, our suppliers are meeting our company’s supplier standards which exceeds U.S. import regulations."
The Outlaw Ocean Project replied: "Thanks very much for your email and for the points you raised. We’re not in a position to provide documentation, but we can say that the materials referenced in our previous email were produced and published by Chishan companies themselves since 2021, in Chinese. They include details on meetings involving Rongcheng Haibo, the Chishan Group, and the persons and agencies that operate the Xinjiang labor transfer programs. You previously mentioned that Lund's requires its suppliers comply with an Ethical Audit standard scheme, specifically SMETA. Can you disclose who carried out the requisite SMETA audit of Haibo?"
Lund’s CEO Wayne Reichle provided a letter and statement to The Outlaw Ocean Project’s publishing partner, The New Yorker: "This letter is in response to your questions pertaining to an upcoming piece by Ian Urbina about forced labor issues in the seafood industry in China. Since last January, when we were first contacted, Lund's Fisheries has fully cooperated with Ian Urbina and other staff of Outlaw Oceans to respond to their questions to the greatest extent possible, including participating in several online video conferences. We have checked in with Outlaw Oceans several times since first working with them nine months ago to inquire as to the status of their efforts, and each time were advised that their reporting was still ongoing. We were unaware that they had completed their work until we were contacted by you for fact-checking. Upon receiving your inquiry, we took steps to research a thorough and accurate response, including assigning a Lund's Fisheries employee to look specifically into the question raised by Outlaw Oceans related to Rongcheng Haibo. Unfortunately, your email was sent to and received by us on Thursday, September 28, the eve of the Chinese Moon Festival and its associated 8-day public holiday (from September 29th to October 6th). This made working with our staff and contacts in China difficult, and made responding by your requested deadline of 5pm ET on Friday, September 29 impossible. Thank you for your understanding, and for working with a member of our media relations team over the past week. Our response follows. • • • Lund’s Fisheries is primarily a supplier of ‘Product of USA’ seafood, with locations in New Jersey, Massachusetts, and California. We are an industry leader in finfish, scallops, and are the only domestic producer of all three U.S. squid species. However, to meet the diverse needs of our customers, we source product globally, in addition to our domestic production. Lund’s Fisheries takes labor issues seriously and responds when any concerns are raised. Lund's Fisheries requires a Sedex Members Ethical Trade Audit (SMETA) from all of our suppliers. SMETA is the world's most widely used audit to assess standards of labor, health and safety, environmental performance, and ethics. - The SMETA audit is designed to help protect workers from unsafe conditions, overwork, discrimination, low pay, and forced labor. In June, Susan Ryan of Outlaw Oceans informed us that they "found evidence that Uyghurs have been transferred to Rongcheng Haibo from China's Xinjiang province under a state-imposed program." When we asked to review the factual information from their investigation, she responded that they were "not in a position to provide documentation." While Lund's Fisheries takes all accusations seriously, we need to know what the accusations are. Nonetheless, when Outlaw Oceans raised questions about Rongcheng Haibo, we initiated an internal audit, and resolved not to renew existing contracts with Rongcheng Haibo until our internal audit was completed. In her June email to us, Susan Ryan stated, "The Chishan Group has written publicly about the use of such labor in newsletters available on their Chinese-language website." This would appear to refer to a September 22, 2022, Chinese-language article on a Chishan website which we are advised contained a serious inaccuracy. The article referenced the "Haibo Company" and described it as treating its Xinjiang workers well and ensuring their quality of life. However, the company that employs Xinjiang workers is the Rongcheng Hailong Cold Chain Co. Ltd. not the Rongcheng Haibo Seafood Co. Ltd. Rongcheng Hailong Cold Chain Co. Ltd. and the Rongcheng Haibo Seafood Co. Ltd. are located in the same industrial park in Rongcheng City, Shandong. However, there is no connection between Rongcheng Hailong Cold Chain Co. Ltd. and the Rongcheng Haibo Seafood Co. Ltd. It is believed that the source of this reporting error might have been that Rongcheng Haibo operates a halal canteen to serve the dining needs of Muslim workers, and it allows employees of Rongcheng Hailong who seek halal meals to patronize that facility. The author may have seen Xinjiang people eating in the halal canteen of Rongcheng Haibo and believed them to be Rongcheng Haibo employees. Lund’s Fisheries has worked with Rongcheng Haibo for ten years, and the firm has consistently passed required SMETA audits. Our investigation did not find any evidence of illegal activity or forced labor in the operations of Rongcheng Haibo. Additionally, we have included below a letter supplied by President Zhao of Rongcheng Haibo, addressing the situation. Let me state, in the clearest terms, that if Lund’s Fisheries were presented with evidence that Uyghurs have been unwillingly transferred to Rongcheng Haibo from China's Xinjiang province, and are working there inappropriately, Lund’s Fisheries would immediately cease to source product from them. However, as noted above, in response to our request for evidence, Ms. Ryan responded that Outlaw Oceans was “not in a position to provide documentation,” and neither our invetigation nor the SMETA audits corroborated their implication. Sincerely, Wayne Reichle President" The email also included a statement provided to Lund's by Rongcheng Haibo: “Regarding the Chishan Group website article involving the use of Xinjiang workers issues in Rongcheng Haibo company In order to improve the quality of life of employees and exchange typical practices of internal enterprises, an article was published in the general issue of Chishan Daily on September 22, 2022, reporting the practices of Haibo Company that treating Xinjiang workers well and ensure their quality of life. The relevant situation involved in the report is hereby clarified as follows: First the report misidentified the employer as “Haibo Company”. The objective fact is that the main unit using the Xinjiang workers is Rongcheng Hailong Cold Chain Co., Ltd., which is a sole proprietorship enterprise and has no connection with Chishan Group and Haibo Company. Because Rongcheng Hailong Cold Chain Co., Ltd. and Haibo Company are located in the same industrial park, Hailong has not set up a separate halal canteen, and it borrows the idle canteen of Haibo Company to meet the dining demands of Xinjiang employees. The author of the article did not understand the above situation, and saw that there were Xinjiang people eating in the canteen of Haibo Company without grasping the real situation, which caused a clerical error. Secondly, the use of Xinjiang employees of Rongcheng Hailong Cold Chain Co., Ltd., is totally legal, and there was no bullying or forced labor behavior during the work of Xinjiang workers. Rongcheng Hailong Cold Chain Co., Ltd. is in the same industrial park with our company. We are more familiar with the management of this enterprise. What we see is: Rongcheng Hailong Cold Chain Co., Ltd. legally provides jobs for Xinjiang workers, solves the employment problem of Xinjiang workers, and provides them with a good working and living environment, pays wages on time and in full, and enables them to learn advanced production skills. There was no forced labor, and all Xinjiang workers enjoyed full freedom and equal pay for equal work. Moreover, the company respects the eating habits of XInjiang workers and provides halal diet to Xinjiang workers. Third, we must be vigilant against the unfounded rumors and slander from the individual organization. We have reason to believe that the evidence of “using Xinjiang workers” produced this time is actually just an attempt by some organizations with ulterior motives to smear our company’s image with the so-called Xinjiang-related issues in order to achieve their purpose of disrupting our normal economic and trade relations. We are firmly opposed to this. We also hope that relevant Chinese and US companies can enjoy friendly cooperation and healthy development in a lawful and just environment. At the same time, we reiterate once again that Rongcheng Haibo Seafood Co., Ltd. has never employed any Xinjiang workers, and our company reserves the right to pursue legal responsibility for the malicious injured. Rongcheng Haibo Seafood Co. Ltd. June 22, 2023”
The Outlaw Ocean Project emailed Lund's and Rongcheng Haibo with further information and questions in response to their email to The New Yorker. The Outlaw Ocean Project's email said:
"Thank you for your letter dated October 6, 2023, and for continuing to engage with regard to our ongoing investigation.
We have been in ongoing conversation with Lund’s since January 23, 2023, when we had a Zoom meeting with the company’s CEO and seven of its staff, during which we explained our findings and methodology, and fielded your questions. In the subsequent eight months, we replied fully to your company’s emails seeking further input from us, and sent you additional questions. We took a similar approach with Haibo, which we contacted by registered letter on February 2, 2023, to detail our initial findings and in which we began asking questions. Throughout our investigation, we have given stakeholders in the industry and tied to our investigation ample time, typically weeks or months, to look into the matters we have been uncovering.
As we explained to Lund’s previously, we cannot provide the exact documents or source names behind various pieces of evidence because to do so runs the risk that the relevant company in China and/or authorities tied to the Chinese state will alter or remove the specific evidence that we are using before (or after) we can complete our investigation. There is also a risk to some of our sources inside China.
Your October 6 letter says that you only began your investigation into the issues we raised when you were contacted by The New Yorker. However, in our Zoom meeting and in your subsequent emails, including one on June 26, 2023, you confirmed that you were investigating the matters that we brought to your attention. The Haibo statement that you enclosed in your October 6 letter is itself dated June 22, 2023.
Your October 6 letter also states that we declined to provide you with any information about the source of our evidence. However, we provided you with descriptions of the type and content of multiple pieces of evidence. Your October 6 letter quotes one of the examples of our evidence that we provided to you. In that reference, you cite our description of a Chishan Group newsletter that you took to be one from September 22, 2022, in which the company explicitly describes Haibo receiving Xinjiang workers. Haibo’s explanation of this - that the workers were in fact from another company entirely unconnected to the Chishan Group or Rongcheng Haibo - is simply not credible given the volume of evidence we have compiled.
Your October 6 letter establishes the extent of your relationship with Haibo and your reliance on SMETA audits for oversight of forced labor concerns at your processing partners. You write for instance: “Lund’s Fisheries has worked with Rongcheng Haibo for ten years, and the firm has consistently passed required SMETA audits. Our investigation did not find any evidence of illegal activity or forced labor in the operations of Rongcheng Haibo.” Thank you for clarifying these points.
Your October 6 letter says that the Chishan Group newsletter citing Xinjiang workers at their plant was incorrect due to a reporting error on the Chishan Group’s part. Again, the explanation provided is simply not credible. We must make clear that our evidence does not rest upon a single document, but on dozens of sources. We found articles in the state news media from 2021, in both Uyghur and Chinese, that describe government labor transfers to Rongcheng Haibo. Three newsletters published by the Chishan Group also describe the use of Xinjiang labor at Haibo, and also detail government labor transfers to Rongcheng Haibo. An additional four newsletters describe Xinjiang workers at other Chishan Group enterprises, including Shandong Haidu, another processing plant that exports to the United States. Detailed in these articles are high-level meetings in 2020 and 2021 between corporate executives, including Rongcheng Haibo senior management, and Chinese government representatives.
In February 2021, the Chishan Group published a newsletter in which an article celebrated the arrival of Xinjiang workers at Rongcheng Haibo. The article included an image of the workers arriving at the site.
In May 2021, a Chishan Group newsletter said the company had held meetings with government officials in which the transfer of additional laborers from Xinjiang was discussed. Present at the meeting was Haibo's general manager, as well as representatives of a Xinjiang Zhongtai Group subsidiary, a company on the Uyghur Forced Labor Prevention Act Entity List for "working with the government of Xinjiang to recruit, transport, transfer, harbor or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of Xinjiang." The article said the Chishan Group was "looking forward to the arrival of laborers from Xinjiang" and said that the meeting concluded with an agreement between the Bayingolin Mongol Autonomous Prefecture Human Resources and Social Security Bureau and the Xinjiang Zhongtai Group subsidiary to facilitate the transfer of "qualified Xinjiang migrant workers to Chishan enterprises as soon as possible."
In October 2021, a representative of Kashgar’s Human Resources and Social Security Bureau and Shandong’s ‘Xinjiang Aid’ program visited Chishan Group to “investigate the employment environment” of the company, alongside a representative from a state-owned Kashgar company and Xu Wu, director of the Public Employment and Talent Service Center and member of the Human Resources and Social Security Bureau of Rongcheng. Xu Wu oversees the Xinjiang Aid Labor Service Workstation, located within the Shidao Management District, which has provided Xinjiang labor to Chishan Group as well as other Rongcheng seafood enterprises, according to state media.
In September 2022, a Chishan Group newsletter said that Rongcheng Haibo implemented special kitchen arrangements for Xinjiang workers.
In addition to this, four other newsletters reference the transfer and/or accommodation of Xinjiang workers at other Chishan Group companies, including Shandong Haidu, another major exporter to the United States. Again, the practice of cooperation with government authorities to facilitate the transfer of Xinjiang workers is described.
Beyond state media and company materials, we've obtained footage uploaded by Uyghurs to social media that shows them working at Rongcheng Haibo. Video clips uploaded by seven users between March 2022 and June 2023 depict scenes that are verifiably shot from within Rongcheng Haibo, and around the company compound, according to our analysis. The videos include images and clips of the Uyghurs in employee overalls on the processing plant floor.
There is also a clip of a Xinjiang worker at Rongcheng Haibo that was uploaded on the same day in 2022 that SGS undertook a SMETA audit of the site. Our evidence further indicates that social audits have consistently failed to detect Xinjiang labor at numerous Shandong seafood plants over a period of several years.
In December 2021, the United States signed into law the Uyghur Forced Labor Protection Act, which introduced a legal presumption that all imports produced “wholly or in part” from Xinjiang were derived from state-imposed forced labor. This presumption also applies to goods made with Uyghur and other ethnic minority labor transferred out of Xinjiang via government affiliated labor transfer programs.
In light of your input and additional disclosures, we have a number of follow-up questions for you.
Questions for Lund’s:
- You have previously disclosed that you hired two people to work full-time for you in China, inspecting the processing plants that export to Lund’s. Have you asked them for any insights on the issues we raised?
- Our email to Lund’s dated June 28, 2023, did not receive a reply. In it we asked about Lund’s requirement for all of its suppliers to comply with the SMETA standard. Can you disclose who carried out that SMETA audit of Haibo for Lund’s?
- Does Lund’s or any partners tied to its supply chain store any of its seafood at Rongcheng Hailong Cold Chain Co. Ltd.? Have they done so at any point in the past?
Questions for Rongcheng Haibo:
Your letter states: “At the same time, we reiterate once again that Rongcheng Haibo Seafood Co., Ltd has never employed any Xinjiang workers.”
- Can you explain the February 2021 Chishan Group article that celebrated the arrival of Xinjiang workers to the Haibo company and included an image of the workers arriving?
- Can you explain why the Haibo Company was party to an agreement with Xinjiang Bayingolin Mongol Autonomous Region Human Resources and the Zhongtai Company to receive Xinjiang workers in May 2021?
- Can you explain why, as detailed in a September 2022 Chishan Group article, the Haibo Company implemented special kitchen arrangements for Xinjiang workers, if it did not employ Xinjiang workers?
- Can you provide an explanation why at least seven workers from Xinjiang took at least 20 videos from inside and outside the Haibo processing plant, including images of them on the processing plant floor in employee overalls, if they were not working at Haibo?
- Can you tell us how many Xinjiang workers were transferred to work at other companies owned by the Chishan Group, such as Shandong Haidu? This process is described in multiple newsletters published by the Chishan Group.
- Does the Chishan Group or its subsidiaries store any of its seafood at Rongcheng Hailong Cold Chain Co. Ltd.? Have they done so at any point in the past?
Thank you for your prompt attention. If you could please get us replies by October 20, 2023, it would be helpful."
In a press statement on October 13, 2023, Lund's announced:
"In light of recent articles presented in the media naming 98 seafood companies, including Lund's Fisheries, Lund's Fisheries would like to issue a statement condemning IUU fishing as well as human right violations.
CAPE MAY, NJ / ACCESSWIRE / October 13, 2023 / Lund's Fisheries takes allegations of this type seriously, which is why we engaged in numerous productive discussions with Ian Urbina and the staff of the Outlaw Ocean Project beginning in January 2023. In good faith, we conscientiously shared documentation, procedures, policies and industry knowledge surrounding domestic and international fishing, foreign processing and imports. We will continue to address Illegal, Unregulated and Unreported (IUU) fishing, and forced labor allegations with industry members, NGOs, and our government to strengthen the seafood supply chain and provide consumers with the utmost confidence.
Upon hearing questions and criticisms raised about Rongcheng Haibo, we initiated an internal investigation, and resolved not to renew existing contracts with Rongcheng Haibo until that work was complete. Although our investigation did not find any evidence of illegal activity or forced labor in the operations of Roncheng Haibo Seafood, we are maintaining our cessation of new business pending further investigation.
Lund's Fisheries requires a Sedex Members Ethical Trade Audit (SMETA) from all of our foreign suppliers. SMETA is the world's most widely used audit in assessing standards of labor, health and safety, environmental performance, and ethics. The SMETA audit is designed to help protect workers from unsafe conditions, overwork, discrimination, low pay, and forced labor. The SMETA process is what companies use to evaluate their suppliers, specifically when referring to forced labor risks. In addition, we also engage with each supplier, requiring that they sign a supplier declaration agreement, wherein they must agree to not employ forced labor. We analyze and evaluate all the documentation they provide to us, including their SMETA audit reports, annually, to verify the results.
As a proud member of the Sustainable Fisheries Partnership's Global Squid Supply Chain Roundtable, Lund's Fisheries is committed to working towards sustainable fisheries and combatting IUU fishing and human rights violations globally.
Lund's Fisheries is a family owned and operated, vertically integrated seafood harvester and processor which operates 19 fishing vessels on the East and West Coast of the United States and 5 seafood processing facilities in New Jersey, Massachusetts, and California. Our US plants produce a variety of Marine Stewardship Council-certified whole and cleaned calamari products, sea scallops, and multiple species of finfish.
Lund's Fisheries will celebrate our 70th anniversary next year. Our relationships with our customers, employees, consumers and partners are our first priority, and we take great pride in maintaining the integrity of what we do each day."
Wayne Reichle, President of Lund’s Fisheries, emailed a response:
"I am writing in response to your email of October 8, 2023, which asked questions regarding our response to the inquiry from the New Yorker magazine fact checking department.
Our October 6 letter was written to the New Yorker, in response to their fact-checking inquiry. It was not directed to, nor was it a response to the Outlaw Ocean Project. It is a mischaracterization to infer that we “only began [our] investigation into the issues [Outlaw Ocean Project] raised when [we] were contacted by The New Yorker.” What we said in that letter is we began our investigation into the New Yorker’s fact-checking questions at that time. After our first conversations in January, and prior to receiving Susan Ryan’s email of June 20, 2023, we had several conversations with Haibo based on the IUU allegations raised by the Outlaw Ocean Project.
Susan Ryan’s email on June 20, 2023, was not following up on the previous IUU allegations, but raised new issues alleging forced Uyghur labor in Haibo’s factory. We immediately questioned Haibo. They responded with the June 22, 2023, letter which we included in our response to the New Yorker. The Haibo statement we supplied to the New Yorker was issued two days after we inquired about Susan’s email. We did not consider it appropriate to share that private response publicly at that time.
You wrote that our “October 6 letter also states that we declined to provide you with any information about the source of our evidence.” To clarify, we did not say that. We said that “when we asked to review information from their investigation, she responded that they were ‘not in a position to provide documentation.’”
Susan’s response to our request on June 28 stated “We’re not in a position to provide documentation, but we can say that the materials referenced in our previous email were produced and published by Chishan companies themselves since 2021, in Chinese. They include details on meetings involving Rongcheng Haibo, the Chishan Group, and the persons and agencies that operate the Xinjiang labor transfer programs.”
You wrote “we provided you with descriptions of the type and content of multiple pieces of evidence.” That is correct, you told us you had evidence, but did not provide any. We were not offered any specific evidence by Outlaw Ocean Project, only descriptions of content. Given the fact that we are strongly opposed to working with anyone using forced labor, we immediately questioned Rongcheng Haibo about the “descriptions of the type and content of multiple pieces of evidence” you referenced and the use of forced labor in their factories. But without any specific evidence, it was difficult to impossible for us to evaluate the allegations raised.
Because this is such a serious matter, despite not having concrete proof of your allegations, we made the decision to cease conducting business with Rongcheng Haibo.
When the New Yorker fact-checking department reached out, we dispatched an employee to China, and we informed Rongcheng Haibo that we would include their June 22 letter, with their explanation, in our response.
In your October 6 email, you stated that Rongcheng Haibo’s explanation, “that the workers were in fact from another company entirely unconnected to the Chishan Group or Rongcheng Haibo - is simply not credible given the volume of evidence we have compiled.” And you then proceeded to outline a much longer list of allegations, quoted below, that were not included in Susan Ryan’s June emails.
• We must make clear that our evidence does not rest upon a single document, but on dozens of sources. We found articles in the state news media from 2021, in both Uyghur and Chinese, that describe government labor transfers to Rongcheng Haibo. Three newsletters published by the Chishan Group also describe the use of Xinjiang labor at Haibo, and also detail government labor transfers to Rongcheng Haibo. An additional four newsletters describe Xinjiang workers at other Chishan Group enterprises, including Shandong Haidu, another processing plant that exports to the United States. Detailed in these articles are high-level meetings in 2020 and 2021 between corporate executives, including Rongcheng Haibo senior management, and Chinese government representatives.
• In February 2021, the Chishan Group published a newsletter in which an article celebrated the arrival of Xinjiang workers at Rongcheng Haibo. The article included an image of the workers arriving at the site.
• In May 2021, a Chishan Group newsletter said the company had held meetings with government officials in which the transfer of additional laborers from Xinjiang was discussed. Present at the meeting was Haibo's general manager, as well as representatives of a Xinjiang Zhongtai Group subsidiary, a company on the Uyghur Forced Labor Prevention Act Entity List for "working with the government of Xinjiang to recruit, transport, transfer, harbor or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of Xinjiang." The article said the Chishan Group was "looking forward to the arrival of laborers from Xinjiang" and said that the meeting concluded with an agreement between the Bayingolin Mongol Autonomous Prefecture Human Resources and Social Security Bureau and the Xinjiang Zhongtai Group subsidiary to facilitate the transfer of "qualified Xinjiang migrant workers to Chishan enterprises as soon as possible."
• In October 2021, a representative of Kashgar’s Human Resources and Social Security Bureau and Shandong’s ‘Xinjiang Aid’ program visited Chishan Group to “investigate the employment environment” of the company, alongside a representative from a state owned Kashgar company and Xu Wu, director of the Public Employment and Talent Service Center and member of the Human Resources and Social Security Bureau of Rongcheng. Xu Wu oversees the Xinjiang Aid Labor Service Workstation, located within the Shidao Management District, which has provided Xinjiang labor to Chishan Group as well as other Rongcheng seafood enterprises, according to state media.
• In September 2022, a Chishan Group newsletter said that Rongcheng Haibo implemented special kitchen arrangements for Xinjiang workers.
• In addition to this, four other newsletters reference the transfer and/or accommodation of Xinjiang workers at other Chishan Group companies, including Shandong Haidu, another major exporter to the United States. Again, the practice of cooperation with government authorities to facilitate the transfer of Xinjiang workers is described.
• Beyond state media and company materials, we've obtained footage uploaded by Uyghurs to social media that shows them working at Rongcheng Haibo. Video clips uploaded by seven users between March 2022 and June 2023 depict scenes that are verifiably shot from within Rongcheng Haibo, and around the company compound, according to our analysis. The videos include images and clips of the Uyghurs in employee overalls on the processing plant floor.
• There is also a clip of a Xinjiang worker at Rongcheng Haibo that was uploaded on the same day in 2022 that SGS undertook a SMETA audit of the site. Our evidence further indicates that social audits have consistently failed to detect Xinjiang labor at numerous Shandong seafood plants over a period of several years.
We received these additional detailed allegations literally just hours before the New Yorker stories were published, leaving no time for additional investigation. Our staff member who was sent to China, and who found no evidence of the earlier allegations, was already en route back to the United States.
We take these matters seriously. Although we have still not been presented with any actual evidence, given these allegations, and our commitment to always operate in the most ethical manner, we have cancelled all contracts with Rongcheng Haibo.
If you have the concrete evidence to back up these serious allegations, we trust you will find an appropriate way to bring the evidence to light without compromising your sources. You asked several other questions in your email.
• You asked who carried out that SMETA audit of Rongcheng Haibo for Lund’s. We are contracted through Société Générale de Surveillance SA (SGS). As I’m sure you know, SGS, headquartered in Geneva is a century-old global testing, inspection, and certification company, and is considered a leader in the field.
• You asked if our full-time employees in China had any insights on the allegations you raised. Our Chinese representatives are engaged to monitor and ensure quality control of the goods being processed. They are neither charged with nor qualified to perform social audits. We rely on recognized and respected third parties to facilitate social audits, and contract through SGS.
• You asked if Lund’s Fisheries stores any of its seafood at Rongcheng Hailong Cold Chain Co. Ltd. We do not store anything there, and we would not know if Rongcheng Haibo does, or does not.
• You asked several other questions that would be appropriately directed to Rongcheng Haibo. We do not speak for other companies, nor is it appropriate for us to respond to allegations directed at other companies.
Lund's Fisheries takes these allegations seriously, which is why we engaged in discussions with you and the staff of the Outlaw Ocean Project beginning in January 2023. In good faith, we shared documentation, procedures, policies, and industry knowledge surrounding domestic and international fishing, foreign processing, and imports. Lund’s Fisheries will continue to address Illegal, Unregulated and Unreported (IUU) fishing, and forced labor allegations with industry members, NGOs, and our government to strengthen the seafood supply chain and provide consumers with the utmost confidence."
The Outlaw Ocean Project emailed Lund's with further information and questions in response to their October 20 email:
"I’m writing in response to your letter of October 20, 2023, which informed us that you have severed ties with Haibo on the heels of the evidence we presented to you pertaining to the existence of forced labor in Rongcheng Haibo, which was previously a part of your supply chain. Thank you for continuing to engage. Your willingness to answer difficult questions has been distinct within the industry and seems to show a genuine desire to confront and correct admittedly very challenging problems facing the global seafood supply chain.
Allow me to start by trying to ensure that we are using the same set of terminology. In your letter, you seemed to use the words, “allegations” and “evidence” interchangeably. What we provided you in our letter of October 8, 2023, was not additional allegations but a detailed summary of the supporting evidence. Our core allegation has been fairly straightforward and consistent: Chinese processing plants tied to Lund’s have within the past five years used Xinjiang workers in seeming violation of the Uyghur Forced Labor Prevention Act. With regard to your mention that you were not provided “specific evidence,” we itemized quite extensively the various forms of proof that Xinjiang workers have in recent years been in the Haibo plant. We are fairly certain that the details that we provided to you and your then-supplier Haibo were specific enough that your staff in China and Haibo could take a look at the items rendered and decide whether you still believe, as you previously said, that there is no “evidence of illegal activity or forced labor,” and as Haibo said, it “has never employed any Xinjiang workers.” Our investigation is ongoing and as we find new materials of these same issues at this or other plants, we will continue to engage you and describe as best we are able the nature of our findings.
Regarding documents, footage or other evidentiary materials gathered in our investigation: I fear that we can not provide materials upon request, privately or piecemeal. Everything we have to offer we are publishing for the full public and on our website. This is important (and the norm) for journalism venues, as you know. It is also essential in the case of this investigation because several law enforcement agencies are working through the evidence presently and they prefer to view materials in their original. Items that we mined from the Chinese internet (corporate newsletters, open-source footage, state media reports, etc) have been saved by us. But these agencies prefer to access such evidentiary materials in their original. If we reveal or publish some of these items, the companies or the government are likely to remove them from the internet and that will undermine the actions being planned by these law enforcement agencies. Our investigation is ongoing and we will publish everything we possibly can on the website and via our partner news outlets around the world.
With regard to our question concerning, “who carried out that SMETA audit of Rongcheng Haibo for Lund’s,” you replied that it was SGS, which you emphasized is a “leader in the field.” So that we can see whether this audit checked for the existence of Xinjiang labor, may we please have a copy of it? As I’m sure you’re aware, the investigation found: “In May, 2022, social auditors from SGS, one of the top auditing firms, completed an inspection of Haibo, and American companies continued to import its products. But, when we investigated the matter, we found that more than a hundred and seventy people from Xinjiang worked at Haibo in 2021, and a half-dozen Uyghur workers posted regularly to Douyin at Haibo throughout 2022. On the same day that the auditors toured, a young Uyghur worker posted pictures of herself near the plant’s loading bays and what seem to be its dormitories. (Wayne Reichle, the president of Lund’s, told me, ‘Our suppliers are meeting our company’s supplier standards, which exceed U.S. import regulations.’ A spokesperson said that the company has begun to investigate the matter….)When pressed, an SGS representative said that the auditors had done what was required of them by Sedex’s methodology.”
That there was footage of Xinjiang workers within this plant and that social audits such as those performed by SGS seem to be overlooking the presence of state-sponsored forced labor as defined by the Uyghur Forced Labor Prevention Act, would seem to beg a larger question: Is Lund’s confident that the audits it is using are sufficient to protect the company from the presence of state-sponsored forced labor from Xinjiang, or other forms, for example, from North Korea?
With regard to your explanation that your own on-site staff in China are “neither charged with nor qualified to perform social audits,” and that for social audits you rely entirely on SGS, we wonder what social audit steps Lund’s is taking to discern labor conditions on the fishing vessels themselves from which the company sources?
With regard to your statement that you will not answer several of the questions that we posed concerning forced labor in your supplier, Rongcheng Haibo, and your statement that we need to ask that supplier, we find this response somewhat perplexing. To be clear, our questions previously presented to you are focused on your knowledge of conditions within a processing plant that you have verified was supplying your company with seafood and because of that relationship, make questions about forced labor within that plant a core concern for Lund’s – at least that is my understanding from your explanation for why you have since decided to sever ties with Haibo. For this reason, the questions we posed to you about the presence of forced labor within a major processing plant that until quite recently was central to your supply chain would seem to be best answered by you. It would seem to me that you either are taking responsibility for concerns about forced labor within plants that are part of your supply chain, or you are not taking responsibility for what happens within those plants, and as such are referring questions to them.
Thank you for your further reassurance that you intend to continue to be transparent and open to what we can only imagine are difficult questions. Even though Lund’s has provided some information and responses, part of the purpose of the investigation and this conversation is to press for more rigor and clarity regarding some of the clear blindspots that seem to exist in the way that companies like Lund’s may have until recently been handling the challenges that exist within the seafood industry to counter the problem of IUU and forced labor on fishing ships and in processing plants."