Correspondence
Email sent to Ruggiero's contact address. January 17, 2023: A letter with the same text as the email dated January 10 was sent by certified mail.
The email said: "I’m writing to you in light of our latest investigation, which concerns abuses in the Chinese squid fishing industry, and a link we’ve discovered between companies engaged in abuses and your supply chain. 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 to a large Chinese fisheries company in Shandong province called the Chishan Group. Further to its connections to the vessel, ships owned by the Chishan Group were found fishing in North Korean waters in violation of UN sanctions in 2017 and 2018. Chishan’s two biggest squid processors, Shandong Haidu and Rongcheng Haibo, supply squid products to Ruggiero Seafood. Import records show that between 2018 and 2022, Shandong Haidu supplied 42 shipments of squid to Ruggiero, with Rongcheng Haibo supplying 287 shipments of squid to Ruggiero over that same period. In turn, Ruggiero supplies squid to Performance Food Services and Sysco.
Does Ruggiero Seafood Inc. have any comment or statement to make on the record in response to this information?"
A new email was sent to Ruggiero, saying: "I contacted you earlier this year regarding The Outlaw Ocean Project’s investigation into abuses in the Chinese squid fishing industry as it related to your supply chain. I am contacting you again in light of new findings made as part of our ongoing reporting, which concerns the use of forced labor in China’s food processing industry.
Ruggiero Seafood Inc.’s supplier Rongcheng Haibo has received persons from the Xinjiang Uyghur Autonomous Region of the People’s Republic of China under the state-imposed labor transfer program. The United Nations, human rights organizations and academic experts agree that since 2018, the Chinese government has systematically subjected Xinjiang’s predominantly Muslim ethnic minorities to forced labor across the country via state-sanctioned employment schemes which use coercive methods in worker enrollment, and obstruct freedom to leave employment. The U.S. has prohibited the importation of goods produced from state-imposed forced labor.
Does Ruggiero Seafood have any comment or statement to make in light of the above information?"
The Outlaw Ocean Project emailed Ruggiro, saying: "We see in industry press today that you severed ties with the Chinese seafood group, Chishan. A link to that piece is here.
We have further reporting coming tied to the global seafood supply chain. We wanted to resurface unanswered questions to Ruggiero from our last exchange linked here and add a couple of new ones. Again, our hope is to give you plenty of opportunity to engage on issues in your industry which are being raised in our reporting. Our assumption is that Ruggiero, as a major seafood distributor in the U.S., will want to engage openly with us on such matters. This is our motivation in continuing to submit questions to you.
Questions:
- We wrote to you earlier this year to say your supplier Rongcheng Haibo, a Chishan company, has received persons from the Xinjiang region of China under a state- imposed labor transfer program, and that the U.S. has prohibited the importation of goods produced from state-imposed forced labor. We asked if you had any comment to make - does Ruggiero have anything to say on this now?
- Can you describe the process behind Ruggiero’s decision to cut ties with Chishan?
- One of the findings of our ongoing investigation into the use of forced labor in the seafood industry is a fundamental gap in how auditors and auditing programs vet companies for signs of forced labor in their workforce. What systems does Ruggiero have in place to vet suppliers for forced labor, including state-imposed forced labor such as the use of Xinjiang labor or North Korean overseas labor?
- We understand that Ruggiero continues to use companies in China to source, process or package seafood. What assurances has Ruggiero received that these suppliers do not engage in forced labor practices?
- If audits were conducted at the plants of Ruggiero's other Chinese suppliers, what language or process - if any - was included in those audits specifically to identify the presence of Xinjiang or North Korean labor?
Please let us know your responses to the above by close of business on January 25, 2024, noting that interactions remain on record."
The Outlaw Ocean Project emailed Ruggiero: "We previously emailed Ruggiero about our investigations into China's squid fishing and seafood processing industries. As part of our ongoing investigation of global seafood, we have questions for Ruggiero arising from research we conducted about a certain plant that was recently formed.
We’ve received information from a source in China that this company named Shandong Nabaixian is either the same plant as one previously called Rongcheng Haibo, or is very closely affiliated with Rongcheng Haibo. The source has had direct dealings with Shandong Nabaixian. We also checked various trade and company databases and found that this company called Shandong Nabaixian was created in October 2023 and that it was listed in a Chinese business directory with the same email address and phone number that appeared in Haibo’s listing.
- Import records show that Ruggiero was the consignee for dozens of shipments of seafood from Shandong Nabaixian since December 2023. Can you confirm that Ruggiero receives seafood from this plant?
- Can you explain what the relationship is between Shandong Nabaixian and Rongcheng Haibo?
- Records also indicate that the Shandong Nabaixian plant is owned by Chishan Group. As raised in our previous correspondence to Ruggiero, we read in industry press link here published in January 2024 that Ruggiero had decided to cut ties with Chishan Group. Is that no longer the case? If so, when did Ruggiero renew a supply relationship with Chishan Group?
Please let us know your responses to the above questions by close of business on August 2, 2024, noting that all interactions remain on record."
Brian McDonough of Kessler PR Group responded: “My name is Brian McDonough and I’m with Kessler PR Group. My firm has a longstanding relationship with Chiesa Shahinian & Giantomasi PC, which is outside counsel to Ruggiero Seafood. In response to your inquiry, we are providing the below statement from attorney Frank Giantomasi. We hope you will accurately report the extensive vetting process undertaken by Ruggiero.
Can you please confirm receipt of the below statement?
For nearly 100 years, Ruggiero Seafood has been recognized for providing fresh seafood and having positive relationships with our vendors. The company performed extensive due diligence on Shandong Nabaixian. The company’s procedures included requesting, and receiving, certificates of approval from the FDA (Food and Drug Administration), BRC (Brand Reputation through Compliance), HACCP (Hazard Analysis and Critical Point), and MSC (Marine Stewardship Council). Ruggiero also requested a social audit from SMETA, the world’s leading auditor for labor, health and safety, and environmental practices. That audit provided Ruggiero with data that demonstrated Shandong Nabaixian’s business practices complied with U.S. and international labor laws.
Ruggiero Seafood also specifically asked and was reassured in writing from Shandong Nabaixian’s leadership that the company had “completely no relation with Chishan Group”.
Francis J. Giantomasi, Member, Chiesa Shahinian & Giantomasi PC, Outside Counsel to Ruggiero Seafood”