Correspondence
Email sent to the CFO of Toppits Foods Ltd., Brad Zhang.
The email said: "I’m contacting you in light of our latest investigation which concerns abuses 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 Toppits Foods have any comment to make in response to the above information? Please respond to this email by close of business July 18, 2023."
The Outlaw Ocean Project emailed: "We emailed Toppits on July 13, 2023, regarding our latest investigation which concerns abuses 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 in 2022. 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.
Trade data viewed by The Outlaw Ocean Project shows that Toppits was the consignee for dozens of shipments of seafood products from Rongcheng Puchen between 2018 and 2022.
While we recognize that you may not be aware of the above problems, we wish to ask you if Toppits has any comment to make in response to the above information?
Please let us know by close of business on September 27, 2023, noting that interactions remain on record."
Toppits Marketing replied: "Thank you for contacting us. We have investigated the concern below. None of our products have come from this unregulated fishing activity that took place in the details described below."
The Outlaw Ocean Project emailed Toppits: "We last emailed Toppits in September 2023 regarding our investigation into the Chinese squid fishing and seafood processing industries. Our ongoing investigation into the use of forced labor in Chinese seafood processing has uncovered evidence which we wanted to bring to your attention.
We have investigators on the ground in China who have been engaging with labor brokers directly involved with the transfer of North Korean workers to factories in China. Through this and other investigative means, including collecting online footage from the plants and interviews with workers recently returned to North Korea from China, we’ve found large numbers of North Korean workers at a range of seafood processing plants in Liaoning province, on China’s border with North Korea.
We have information that as recently as December 2023, there were 50-70 workers at Dalian Haiqing Food Co. Ltd. in Liaoning.
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.
According to trade records seen by The Outlaw Ocean Project, Toppits was the consignee for multiple shipments of seafood from Dalian Haiqin since 2017.
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While we understand that you may not be aware of the above issues, we want to ask if Toppits has any comment to make in response to this email?
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Can you confirm or deny if any seafood from Dalian Haiqing has been supplied by Toppits to any of the following: Metro Canada, Violá, Costco, MVR Cash & Carry, or Steward Foodservice Inc.?"
Jillian Andreas Director of Retail Sales, replied for Toppits: "Please be aware that Toppits does not procure any products from this supplier. Thank you."
The Outlaw Ocean Project replied: "Thanks so much for your email and for coming back to us so quickly on that.
Can we just clarify something with you? The trade records we’ve seen were compiled by the trade data firm ImportGenius and they show over a dozen shipments from Dalian Haiqing consigned to Toppits Ltd. between August 2017 and September 2020. The arrival port is listed on each as Seattle, Washington. Is it the case that the trade relationship between Toppits and Dalian Haiqing had ceased after, or by, the time of that shipment in September 2020?
Thanks again for your engagement with us on this."
Jillian Andreas Director of Retail Sales, replied for Toppits: "Yes that is correct. We stopped purchasing from them in 2020. Let me know if you need anything else."