Correspondence
Email sent to Media Team at Metro Canada.
The email said: "I’m contacting you in light of our latest investigation which concerns the use of forced labor in China’s food processing industry, and a link we’ve discovered between companies engaged in such practices and one of your suppliers - High Liner Foods. Metro stocks a range of High Liner Foods products containing white fish.
High Liner has imported shipments of cod, pollock, haddock, yellowfin sole, ocean perch and flounder from Yantai Sanko Fisheries Co. Ltd., a seafood processor based in China. Yantai Sanko Fisheries Co. Ltd. has received persons from the Xinjiang region of China under a government labor transfer program since 2019 and until at least April 2023.
High Liner has also imported shipments of yellowfin sole from Yantai Longwin Foods Co. Ltd. Yantai Longwin is linked to Yantai Sanko through corporate ownership. Our investigation has also found Uyghurs working at Yantai Longwin, since August 2020 and until as recently as March 2023.
The United Nations, human rights organizations and academic experts agree that since 2018, the Chinese government has systematically subjected Xinjiang’s predominantly Muslim ethnic minorities to forced labor across the country via state-sanctioned employment programs which use coercive methods in worker enrollment and obstruct freedom to terminate employment. The U.S. has prohibited the importation of goods produced from state-imposed forced labor.
Could you confirm whether white fish sourced from Yantai Sanko or Yantai Longwin has been used in any of the High Liner branded white fish sold by Metro since 2019? Does Metro have any comment or clarification to make regarding the above information? Please let us know by close of business August 30, 2023."
Stephanie Bonk, Communications Manager at Metro, replied: "Confirming receipt. I will get back to you by your deadline."
Stephanie Bonk, Communications Manager at Metro, replied with a statement: "All METRO suppliers are required to respect working conditions across the supply chain as outlined in our Supplier Code of conduct for responsible procurement (SCoC). We assess suppliers’ conformity to our SCoC through our partnership with Supplyshift, a cloud-based platform supported by a team of ESG experts. METRO knows that the fishing and aquaculture industries face challenges that concern the sustainability of fish and seafood stocks, the protection of biodiversity and ecosystems, as well as working conditions. This is why we support excellent procurement practices in our fish and seafood department. Please see our Sustainable Fisheries and Aquaculture Policy that covers fresh, frozen and canned fish and seafood. We are in communication with High Liner and have confirmed that their practices are inline with our SCoC. We will continue to monitor the situation and follow up with them on their corrective action plan." The email linked to the company's Supplier Code of Conduct for Responsible Procurement (dated January 2022) and Sustainable Fisheries and Aquaculture Policy (dated January 2022).
The Outlaw Ocean Project replied: "Thank you for your response and for sharing the METRO Supplier Code of Conduct. We note that it applies to all entities in your extended supply chain (first, second, third tier suppliers, etc) and includes a prohibition on forced labor.
Please could you outline the steps METRO has taken to monitor compliance with its Code of Conduct at the Chinese factories referred to in our August 22, 2023, email that supply High Liner with seafood?
You state that High Liner is in compliance with the METRO Supplier Code of Conduct, which we note includes the following as part of principle 3.2: "METRO expects its suppliers to provide products and services that are based on practices that ensure that workers are treated with dignity, respect and equity in a healthy and safe work environment that provides decent conditions and is free of abuse."
Does METRO believe that High Liner's purchasing practices, in which it buys seafood from Chinese factories using state-imposed forced labor, meets this expectation?
Could you also please provide further details on High Liner's corrective action plan, specifically what the corrective action plan is designed to address."
The Outlaw Ocean Project emailed: "Trade records seen by The Outlaw Ocean Project show that, between 2019 and 2022, Premier Marine Canada was the consignee for at least seven shipments of seafood from processors in China that have received people from the Xinjiang region of China under a state imposed labor transfer program. The processors, Rizhao Meijia Aquatic and Rizhao Jiayuan, are both owned by the Meijia Group. The Meijia Group has received persons from the Xinjiang region of China under a state-imposed labor transfer program since 2019 and until as recently as May 2023. We have uncovered evidence of Uyghur workers in Rizhao Jiayuan in 2019. Trade records also show that Premier Marine Canada was the consignee for seafood from Yantai Sanko Fisheries in 2019, a processor referenced in our previous correspondence with you regarding the use of Uyghur forced labor. According to Premier Marine Canada’s official website, Premier Marine is a private label partner of your company. While we recognize that you may not be aware of this problem, we wish to ask you: Can you confirm or deny if any seafood from Rizhao Meijia Aquatic, Rizhao Jiayuan or Yantai Sanko Fisheries has been used in any products sold by your company since 2019? Does Metro have any comment or clarification to make in response to the above information? "
The Outlaw Ocean Project emailed Metro: "We previously emailed Metro on September 25, 2023 regarding our investigation into the use of forced labor in China’s seafood processing industry. Since then, our ongoing investigation has uncovered additional evidence.
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.
We have information that as recently as December 2023, there were 50-70 workers at Dalian Haiqing Food Co. Ltd. in Liaoning.
According to trade records, Aqua Star was the consignee for multiple shipments of seafood, including haddock, from Dalian Haiqing between 2017 and 2023.
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. Metro stocks a number of Aqua Star seafood products (for example, haddock fillets).
In light of the above, we have some questions for Metro:
- While we understand that you may not be aware of the above issues, we want to ask if Metro has any comment to make in response to this, or our previous, email?
- Can you confirm or deny if Metro has been supplied by Aqua Star with any products from Dalian Haiqing?"
Stephanie Bonk, Communications Manager, replied for Metro: "Thank you for bringing this issue to our attention. We will investigate the situation with Aqua Star.
As previously mentioned, all METRO suppliers are required to respect working conditions across the supply chain as outlined in our Supplier Code of conduct for responsible procurement (SCoC). We assess suppliers’ conformity to our SCoC through our partnership with Supplyshift, a cloud-based platform supported by a team of ESG experts.
Through this program, we have confirmed that Aqua Star’s practices are in line with our SCoC. We will continue to monitor the situation and follow up with them on their corrective action plan.
METRO knows that the fishing and aquaculture industries face challenges that concern the sustainability of fish and seafood stocks, the protection of biodiversity and ecosystems, as well as working conditions. This is why we support excellent procurement practices in our fish and seafood department. Please see our Sustainable Fisheries and Aquaculture Policy that covers fresh, frozen and canned fish and seafood."
A coalition of eighteen NGOs wrote to thirteen major seafood distributors and retailers, including Metro, asking a series of questions connected to The Outlaw Ocean Project's reporting. Their email to Metro said: "Dear Metro,
We are writing to you on behalf of a consortium of human rights NGOs requesting an update on the steps Ahold Delhaize 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 Metro,
The undersigned organizations, experts on human rights, labor rights, Uyghur rights, North Korean rights, and trade law, are requesting an update on the steps Metro 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, Metro 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"