Correspondence
Email sent to two contact addresses for the media team at Whole Foods Market.
The email said: "Our ongoing investigation into the use of forced labor in China’s seafood processing industry has uncovered new evidence, specifically of North Korean workers in Chinese plants. 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. As part of this work, we have information that as recently as December 2023, there were 50-70 workers at Dalian Haiqing Food Co. Ltd. According to trade records, Tampa Bay Fisheries was the consignee for multiple shipments of seafood, including pollock, from Dalian Haiqing between June 2020 and September 2023. The use of North Korean workers was prohibited by the United Nations Security Council in 2017, with Resolution 2397. Furthermore, 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. Like the Uyghur Forced Labor Prevention Act (UFLPA), which pertains to Xinjiang labor, CAATSA has a "rebuttable presumption" whereby all North Korean workers are presumed to be state-sponsored forced labor.
We have seen the Tampa Bay Fisheries MSC code on packaging for Whole Foods 365 pollock, and have several questions for Whole Foods: 1. While we understand that you may not be aware of the above issues, we want to ask if Whole Foods has any comment about this information that we are presenting? 2. Has seafood from Dalian Haiqing been supplied to Whole Foods, by Tampa Bay Fisheries or any other supplier, since August 2017? 3. The Whole Foods Market Supplier Code of Conduct 2023 has provisions concerning forced labor and says: “Suppliers must not use forced labor” (source). Does this requirement apply to suppliers at all levels of Whole Foods’ supply chain? What systems does Whole Foods have in place for checking compliance? 4. Are you aware of any social audits being conducted at this plant and if so what type, when, with what result, and were these audits unannounced? If audits were indeed conducted at this plant, what - if any - language or process was included in those audits specifically to identify the presence of North Korean workers?"
Stephanie Ferragut, Whole Foods Market Corporate Communications, responded: "Thank you for reaching out. Whole Foods Market does source our 365 pollock from Kitchen’s Seafood – which is a subsidiary of Tampa Bay Fisheries. Based on our audit of the MSC Chain of Custody records, we see that all of the pollock for our 365 products is US-caught and US-processed. The pollock does not go to China."
The Outlaw Ocean Project replied: "Thanks very much for your email, we really appreciate Whole Foods coming back to us on our query. Since our last email, we found another supply chain connection we want to bring to your attention. We understand that Whole Foods is the retailer for the ‘Starfish’ brand from Pacific Seafood Group, with the line including cod, halibut and haddock portions, as well as pollock fish sticks. Trade records show Pacific Seafood was the consignee for multiple shipments from the same Chinese company referenced in our email dated January 19, 2024 - Dalian Haiqing - including cod, halibut, haddock and pollock. Regarding the above, we have the following questions for Whole Foods Market: 1. While we understand that you may not be aware of the above issues, we want to ask if Whole Foods has any comment about this information that we are presenting? 2. Has seafood from Dalian Haiqing been supplied to Whole Foods, by Pacific Seafood or any other supplier, since August 2017? 3. The Whole Foods Market Supplier Code of Conduct 2023 has provisions concerning forced labor and says: “Suppliers must not use forced labor” (source). Does this requirement apply to suppliers at all levels of Whole Foods’ supply chain? What systems does Whole Foods have in place for checking compliance? 4. Are you aware of any social audits being conducted at this plant and if so what type, when, with what result, and were these audits unannounced? If audits were indeed conducted at this plant, what - if any - language or process was included in those audits specifically to identify the presence of North Korean workers? We very much appreciate Whole Foods’ continued engagement on this. Please let us know your responses to the above by close of business on January 29, 2024."
Whole Foods replied: "I’m checking on this and will get back to you. I won’t be able to get you the answer by COB [close of business] today."
The Outlaw Ocean Project emailed: "Just checking back if we'll hear from Whole Foods on this by end of today."
Whole Foods replied: "We are working on this. In this case of Pacific Seafoods, there are some secondary processors, which requires us to do extra checks. We are going to need more time. I’ve asked my business partner, leading our seafood work how long it will take - stay tuned."
Whole Foods emailed: "Whole Foods Market does source from Pacific Seafood. Based on our audit of the MSC Chain of Custody records, we confirmed that all of our product from Pacific Seafood is US-caught and US-processed. The Whole Foods Market products are not caught or processed in China."