Correspondence
Email sent to Molly Blakeman Senior Director, Communications at Walmart. Query also submitted via online submission form on Walmart's website.
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 in that industry and Walmart’s calamari supply chain. On the Ocean Disclosure Project website, Walmart lists a fishery in the South China Sea as a source of its mitre squid. The squid is processed at the Shantou Haimao Foodstuffs Factory and packaged for Walmart under the Great Value brand; plant codes on Walmart Great Value branded seafood products also correspond to Shantou Haimao. Satellite data shows that some of this squid is caught by Chinese vessels fishing in waters claimed by Taiwan. Does Walmart have any comment or statement to make on the record in response to this information?"
Blair Cromwell, Director of Global Responsibility Communications at Walmart, replied: "Thank you for contacting Walmart. I wanted to get clarification on your findings. Are the allegations environmental or human rights related? Can you share more details about the nature of abuses you’re uncovering in the squid fishing industry and the allegations specific to Shantou?"
The Outlaw Ocean Project replied: "Thank you very much for your quick reply to my message, I really appreciate your engagement on this. Through our research on the Chinese squid fishing fleet, we have identified two primary areas of concern:
- illegal, unreported and unregulated fishing, and, 2. human rights abuses. We have uncovered a wide range of abuses under each category, to the extent that a quarter of the vessels in the total squid fleet have a history of human rights and/or environmental abuses in the past five years. For example, one brand called PanaPesca (which is stocked by Walmart) is connected to Chinese squid fishing ships known to have dropped a dead crew member’s body off at a South American port or disabled their vessel monitoring systems for several days at a time."
The Outlaw Ocean Project emailed: "In addition to the PanaPesca squid supply chain concerns raised in my last email, I wanted to highlight further findings in our Chinese squid investigation that pertain to companies whose products are carried by Walmart in different countries.
We have found connections between vessels involved in labor abuses and/or IUU and the following brands: Searay Foods Inc, who produce the Searay Seafood Medley stocked by Walmart Canada ██████████ Rhee Bros, who produce the Assi range of products, several of which are carried by Walmart in the US Sea Relation, who produce Sea Apple Seafood Mix stocked by Walmart businesses Paiz and Maxi Dispensa in Guatemala
More widely, our investigation has found that a significant proportion of the Chinese squid fleet is connected to labor abuses, ranging from not paying crew to disembarking dead bodies at distant ports, and illegal fishing practices such as disabling vessel monitoring systems and fishing without permission. Analysis of satellite tracking also reveals a high number of unreported transshipments at sea in the Chinese squid industry.
Traceability in the squid supply chain is particularly murky. Overall, we’ve heard from multiple stakeholders at all levels of the squid industry – importers, exporters, squid fishing fleet owners, cold storage owners, processing companies – that there are many places where the catch can get comingled. At the reefer level, after squid is caught by multiple ships, it can be comingled. At the docks level, it can get comingled as it comes off the ships. At the processing level, it can get comingled in the plant. The added reason that there are concerns by industry analysts about the possibility of comingling is that much of the squid from the Chinese-processed supply chain is being off-loaded at sea from squid jiggers 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 of catch.
Comingling means that it’s particularly difficult for squid suppliers who use Chinese processors to say with certainty that their stock is not linked to any vessel with a history of human rights and/or IUU. Could you please send me your response to the above information by end of day February 7, 2023, as we are preparing for publication."
Blair Cromwell, Director of Global Responsibility Communications at Walmart, replied: "Walmart expects all our suppliers to comply with our standards and contractual obligations, including those relating to human rights. From what you’ve shared, we don’t have sufficient information to address these allegations. If you can provide more detail on specific allegations, we can look into them."
The Outlaw Ocean Project replied: "Thanks for your email and continued interest in this. I’m happy to provide you with additional information on these supply chain issues in as much detail as we can provide at the moment: Rongcheng Guangrun Aquatic Food Co., Ltd. is linked to 3 squid jiggers which have disembarked dead crew at South American ports, and one vessel which turned off its vessel tracking. Trade records show that this processor has supplied squid to Searay Foods Inc and to Sea Relation.
Rongcheng Xinhui Aquatic Products Co., Ltd. is linked to a jigger on which crew were subject to physical abuse as well as forced labor. Trade records show that this processor has supplied squid to Sea Relation.
Zhejiang Industrial Group Co., Ltd. Food Processing Factory is linked to a jigger which has disembarked a dead crew member, and 2 jiggers which turned off their vessel tracking. Trade records show that this processor has supplied squid to ███ and to PanaPesca.
Shandong Haidu Ocean Food Co., Ltd. is linked to 2 jiggers observed fishing in North Korean waters despite UN sanctions and 2 vessels which turned off their vessel tracking. Trade records show that this processor has supplied squid to Searay and Sea Relation.
These specific cases raise documented concerns of actual instances of IUU and/or labor abuses, but more generally we - as raised in our previous emails - have heard that many in the industry are concerned about the challenges to ensuring supply chain traceability given the risk of comingling at many points along the chain.
In light of this, our questions for you are: Walmart’s ‘Supplier Expectations Compliance Areas’ includes a section specifically concerned with Global Sanctions which says: “Suppliers are prohibited from engaging in trade, commerce, or any dealings with sanctioned countries or regions subject to applicable local laws.” How can you ensure that all of the squid sold on your shelves is in compliance with this requirement?
Walmart’s ‘Human Rights Statement’ says: “Walmart’s commitment includes respecting the dignity of those who grow, catch and produce products for our customers. That is why Walmart suppliers globally—including seafood suppliers—are expected to comply with Walmart’s Standards for Suppliers and applicable Responsible Sourcing program requirements. Walmart’s Standards for Suppliers set out our expectations of suppliers and their facilities regarding the ethical treatment of workers, workplace safety, environmental responsibility, and appropriate business practices. The Standards apply throughout the supply chain, including vessels, hatcheries, feed mills, farms, and final processing facilities.” What specific check mechanisms does Walmart have in place to ensure that vessel-level crimes are not occurring, whether IUU or labor-related?
The ‘Worker Dignity & Safety’ policy, which specifically references the risk of forced labor in the seafood industry, says: “Walmart is actively working with suppliers and others to help mitigate risks for those most vulnerable to forced labor and trafficking.” How do you ensure that none of the squid sold on your shelves is connected to forced labor at the catch or transshipment level?
How do you handle reports of IUU and forced labor within your supply chain?
Do you require work sites, including vessels, in your seafood supply chain beyond tier one to undergo audit?
What do Walmart’s expectations on supplier traceability look like in practice for suppliers of wild capture seafood?"
The Outlaw Ocean Project emailed Walmart: "I'm emailing to check in for a response to our previous email of February 13, and I also wanted to add one additional follow-up.
We have identified another company that is a Walmart supplier which owns vessels on which crew were subject to forced labor, physical abuse and neglect. The company is called Shandong Baoma Fishery Group, and it says on its website that it is a supplier of Walmart in China. This gives a total of five companies in Walmart's supply chain where there are documented concerns or actual instances of IUU and/or labor abuses.
One note to point out: We want to be sure we clarify two important distinctions so that we know how to handle your replies. The first distinction is between IUU crimes/concerns as apart from labor and human rights crimes/concerns. The questions here are how Walmart tackles those two separate issues. The second distinction is between onland and offshore or, alternatively put processing plant concerns versus ship concerns. Here too we hope to keep our questions and your answers clearly delineated.
To reiterate our questions: Walmart’s ‘Supplier Expectations Compliance Areas’ includes a section specifically concerned with Global Sanctions which says: “Suppliers are prohibited from engaging in trade, commerce, or any dealings with sanctioned countries or regions subject to applicable local laws.” How can you ensure that all of the squid sold on your shelves is in compliance with this requirement?
Walmart’s ‘Human Rights Statement’ says: “Walmart’s commitment includes respecting the dignity of those who grow, catch and produce products for our customers. That is why Walmart suppliers globally—including seafood suppliers—are expected to comply with Walmart’s Standards for Suppliers and applicable Responsible Sourcing program requirements. Walmart’s Standards for Suppliers set out our expectations of suppliers and their facilities regarding the ethical treatment of workers, workplace safety, environmental responsibility, and appropriate business practices. The Standards apply throughout the supply chain, including vessels, hatcheries, feed mills, farms, and final processing facilities.” What specific check mechanisms does Walmart have in place to ensure that vessel-level crimes are not occurring, whether IUU or labor-related? The ‘Worker Dignity & Safety’ policy, which specifically references the risk of forced labor in the seafood industry, says: “Walmart is actively working with suppliers and others to help mitigate risks for those most vulnerable to forced labor and trafficking.”
How do you ensure that none of the squid sold on your shelves is connected to forced labor at the catch or transshipment level?
How do you handle reports of IUU and forced labor within your supply chain?
Do you require work sites, including vessels, in your seafood supply chain beyond tier one to undergo audit?
What do Walmart’s expectations on supplier traceability look like in practice for suppliers of wild capture seafood?"
The Outlaw Ocean Project emailed Walmart: "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 on human rights and environmental issues connected with the world’s oceans.
Further to my previous correspondence, we have uncovered a link between a company engaged in the use of Uyghur forced labor in seafood processing and a supplier in your supply chain.
Yantai Sanko Fisheries Co. Ltd., which supplies white fish products to High Liner Foods Inc., has received persons from the Xinjiang region of China under a state-imposed labor transfer program as recently as 2022.
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. The U.S. has prohibited the importation of goods produced from state-imposed forced labor.
High Liner white fish products are stocked by Walmart and Walmart Canada. Does Walmart have any comment or statement to make in response to the above information? Please reply to this email by close of business June 27, 2023."
The Outlaw Ocean Project emailed Walmart: "Our investigation continues to surface additional questions in relation to your company’s supply chain, specifically your supplier High Liner Foods.
In addition to the supplier Yantai Sanko mentioned in our email dated June 23, 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.
Walmart stocks High Liner products containing sole at stores nationwide.
Our investigation demonstrates the presence of Uyghur workers at Yantai Sanko from as early as 2019 to as recently as April 2023.
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 Walmart since 2019? Please reply to this email by close of business August 31, 2023."
The Outlaw Ocean Project sent an email to Blair Cromwell, Director of Global Communications at Walmart, saying: "We last emailed you on August 23, 2023, to highlight additional findings from our investigation into abuses in China’s seafood industry, as they related to Walmart’s supply chain. Our ongoing investigation has further findings which we want to bring to your attention. We have uncovered evidence that a Chinese seafood company called Donggang Haimeng Food Co. Ltd. used North Korean labor after the December 2019 deadline for the repatriation of overseas North Korean workers required under United Nations Security Council sanctions. This evidence shows North Korean labor at Haimeng’s factory in Liaoning, China, as recently as 2023. Furthermore, under the Countering America's Adversaries Through Sanctions Act (CAATSA), passed in 2017, the U.S. 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. Trade data shows: Canadian Fish Exporters was the consignee for dozens of shipments of dried and salted pollock from Haimeng since 2017. Salted pollock from the Canadian Fish Exporter brand Buena Ventura was listed on Walmart’s website as of November 9, 2023. Trade data also shows that a company called Quirch Foods Caribbean imported dozens of shipments of seafood from Haimeng since 2017. Salted pollock from Quirch Foods Caribbean’s brand Panamei Seafood is listed on Walmart’s website. While we understand that you may not be aware of the above issues, we want to ask if Walmart has any comment in response to this email? Can you confirm if seafood sourced from Haimeng has been used in any of the Canadian Fish Exporters or Quirch Foods Caribbean products sold by Walmart since 2017?"
The Outlaw Ocean Project emailed: "As we haven't heard back from you on this, we wanted to check if Walmart has any comment or statement to make at this time?"