Correspondence
Email sent to Carolyn Steere in Corporate Affairs at Simplot Australia.
The email said: "I’m contacting you in light of our latest investigation which concerns the use of forced labor in China’s seafood processing industry, and a link we’ve discovered between a company engaged in such practices and a supplier in your supply chain - Rongcheng Puchen.
We have evidence of squid catch from a Zhoushan Ningtai Ocean Fisheries vessel that engaged in unregulated fishing activity - the Ning Tai 58 - at Rongcheng Puchen’s processing plant. Another 14 vessels owned by Zhoushan Ningtai are linked to a range of environmental and human rights issues including forced labor, AIS spoofing, shark finning, and unauthorized transhipment. Unauthorized transhipment can undermine supply chain traceability by obfuscating the movement of catch from vessel to processor.
Does Simplot have any comment or clarification to make regarding the above information? Does Simplot supply any Puchen-sourced product to Woolworths or Coles? Please respond to this email by close of business July 24, 2023."
The Outlaw Ocean Project sent an email to Carolyn Steere in Corporate Affairs at Simplot Australia: "I contacted you last month regarding our investigation into abuses in China’s seafood processing industry. I’m emailing today as we have additional findings to raise with you.
According to trade records, Simplot has imported squid from a processor called Rongcheng Haibo Seafood Company, which is based in eastern China.
Rongcheng Haibo is a Chishan Group company. Fishing vessels owned by the group have been observed fishing in North Korean waters in contravention of UN sanctions and fishing illegally in Indonesian waters. The group also owns at least two reefer vessels which have transshipped with dozens of fishing ships tied to illegal, unreported and unregulated fishing as well as human rights abuses.
The Chishan Group has received persons from the Xinjiang region of China under a state-imposed labor transfer program since 2021 and until at least May 2023. We have found evidence of Uyghurs working at Rongcheng Haibo Seafood throughout this period.
The United Nations, human rights organizations and academic experts agree that since 2018, the Chinese government has systematically subjected Xinjiang’s predominantly Muslim ethnic minorities to forced labor across the country via state-sanctioned employment programs which use coercive methods in worker enrollment, and obstruct freedom to leave employment.
Simplot Australia owns the Bird’s Eye brand in Australia, which supplies products containing squid to major retailers such as Woolworth’s, Cole’s, Drake’s and IGA. Could you clarify if raw material from Rongcheng Haibo Seafood or the company mentioned in my previous email, Rongcheng Puchen, has been used in Bird’s Eye products containing squid? Have any Simplot squid products processed by Rongcheng Haibo or Rongcheng Puchen been supplied to Superior Foods?
Does Simplot have any comment to make in response to the above information? Please let me know by close of business on August 11, 2023."
Carolyn Steere, Head of Communication and Corporate Affairs at Simplot, replied: "I am not sure how the other email has been missed, please accept my apologies for that. I am just letting you know I have received this email and will come back to you by the end of the week."
Carolyn Steere replied: "Simplot Australia is committed to upholding human rights and taking the necessary steps and actions to ensure that we identify, manage, and mitigate the risks of modern slavery, including forced labor. In late July, we were contacted by Sedex, who advised that the Outlaw Ocean Project had uncovered that one of our suppliers was potentially using forced labor from the Xinjiang Uyghur Autonomous Region (XUAR) in its operations.
We immediately investigated and identified the supplier was listed by our broker/agent as a designated contingency supplier. Upon further investigation, we uncovered that we had never needed to place orders with this contingency supplier and subsequently required our broker to de-list the supplier. Regarding the suppliers listed in your most recent email, we can advise that we have never sourced from Rongcheng Haibo. In terms of Rongcheng Puchen, we do source from this supplier; however, they have confirmed to us that the vessels you have identified are not associated with their operation, and we have subsequently independently verified this information. We welcome any evidence that is contrary to enable us to investigate further.
Given recent developments and the seriousness of the issue, we have taken immediate action by undertaking a review of the total risk profile of our suppliers and, additionally, the onboarding process for Chinese suppliers. This is in addition to requesting Sedex provide us with the outcomes of their investigation into their auditing standard and associated processes that they undertake in the region, as Sedex and the Sedex supplier self-assessment questionnaire and SMETA audits form a key element of our risk mitigation efforts. Simplot is committed to continuous improvement in identifying and mitigating the risks of modern slavery in our supply chain and operations and working closely with our team members, suppliers and customers to further embed our policies, practices and standards."
The Outlaw Ocean Project emailed Simplot: "Thank you very much for your reply to our query and for providing us with such a detailed response.
We’d like to seek further clarification on your business relationship with Rongcheng Haibo. According to publicly available trade data we have access to, Simplot Australia is listed as the consignee of at least one shipment of todarodes pacificus squid tubes in February 2022 from Rongcheng Haibo Seafood. Do you have a record of this specific shipment?
Additionally, what independent steps did Simplot take to verify that Rongcheng Puchen does not source from the Zhoushan Ningtai-owned vessels referenced in our previous emails? For your awareness, our investigation spans 2018 to 2023.
More generally, what visibility does Simplot have on vessel-level traceability when sourcing squid from processing facilities? Is this data provided with each purchase or does it require further correspondence with your purchasing partners?
Finally, could you also clarify if raw material from Rongcheng Puchen has been used in Bird’s Eye products containing squid?
Thank you again for your time in responding to our queries. Please let us know Simplot’s responses to the above questions by close of business September 7, 2023."
Carolyn Steere, Head of Communication and Corporate Affairs at Simplot, replied: "Please find responses to your queries.
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Simplot Australia is listed as the consignee of at least one shipment of todarodes pacificus squid tubes in February 2022 from Rongcheng Haibo Seafood. Do you have a record of this specific shipment? Simplot has never purchased any squid from Roncheng Haibo.
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What independent steps did Simplot take to verify that Rongcheng Puchen does not source from the Zhoushan Ningtai- owned vessels referenced in our previous emails? For your awareness, our investigation spans 2018 to 2023.
Our supplier provided a signed declaration stating they had never sourced raw material from the vessels, and we also undertook our own internal investigation. We have no evidence to suggest that the supplier has purchased from these vessels.
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What visibility does Simplot have on vessel-level traceability when sourcing squid from processing facilities? Is this data provided with each purchase or does it require further correspondence with your purchasing partners? Simplot traces back to the vessel, fishing zones, and catch date on all products ordered and certificates are provided for purchase orders.
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Could you also clarify if raw material from Rongcheng Puchen has been used in Bird’s Eye products containing squid? We do not use raw materials from Rongcheng Puchen in any of our Birds Eye products."
The Outlaw Ocean Project emailed Simplot, saying: "Regarding Rongcheng Puchen: Our evidence includes video from April 2022 showing large amounts of squid from the Ning Tai 58 in the Rongcheng Puchen plant. Regarding Rongcheng Haibo: The trade records we've seen show a shipment of Todarodes Pacificus Squid Tubes consigned to Simplot Australia Pty Ltd. in February 2022. Could it have been purchased for Simplot via a third party broker?"
Simplot Australia's communications team replied: "Thank you for sharing the information below. To help us delve into this matter further, could you advise which platform you have used that shows we have consigned Todarodes Pacificus Squid Tubes in February 2022? We will do our best to respond by Monday but your support with the above information would help us with our inquiries and assist us greatly in meeting this deadline."