Austin, Texas, U.S.A.-based Whole Foods Market has a new set of expectations for the labor practices and human rights standards of its seafood suppliers.
The company’s new Seafood Code of Conduct, announced 28 January 2025, sets policies that are in line with the UN Guiding Principles on Buiness and Human Rights and the International Labour Organization’s (ILO) Work in Fishing Convention, mandating maximum work and time at sea hours, ethical recruitment policies, gauranteed communication access for crew members, and health and safety policies on vessels.
“Our purpose is to nourish people and the planet, and that includes people in our supply chain,” executive leader of quality standards Ann Marie Hourigan told Seafood Source, of the genesis of the program.
The new policy is meant to address persistent labor and human rights issues in the seafood industry, such as predatory recruitment schemes which exploit workers’ citizenship status; accounts of fishing crews working without access to clean water, hot food, or channels through which to communicate with their families or worker representatives are common in the industry.
In its 2022 report, for instance, the ILO estimated that 128,000 fishers were trapped in forced labor worldwide. The ILO has also found that there is a strong link between forced labor and other forms of fishery crime, such as IUU fishing.
The issue of labor injustice in the seafood supply chain has been gaining recognition in the U.S. recently. In mid January the United States Trade Representative (USTR) released a Trade Strategy to Combat Forced Labor for the first time. The program addresses the seafood industry directly, saying that a USTR priority is stopping the importation of fish caught, farmed, or processed by forced labor.
As then USTR Ambassador Katherine Tai wrote in a preface to the new strategy, U.S. trade policies have sometimes “incentivized countries to compete by maintaining or lowering standards, as companies sought to minimize costs in pursuit of efficiency.” This strategy, though it “did generate wealth,” had the downside of incentivizing the cheapest possible labor sources.
Though Whole Foods has long emphasized seafood traceability and sustainability, this is its first prorgram to directly address labor and human rights issues within the industry. Hourigan explained that the decision to launch the Seafood Code of Conduct was one that had been brewing internally for a while.
“For a long time, we’ve been pushing seafood sustainability, and [labor] has been an area that we’ve been wanting to work on, and have been working on in the background,” said Hourigan. “We identified through a saliency assessment that seafood is extremely high risk and that we could start by addressing some of the gaps out there in the industry, by having clear expectations for suppliers around worker welfare.”
The Code of Conduct is unusually specific, offering its suppliers concrete directives, such as a clear prohibition of recruitment fees and a mandate that simple, clear work contracts be used. It also requires safety training, PPE, medical care, and sufficient food and water to be available for all crew members.
“There are certain things in the seafood code of conduct that are there because we want to be really clear about what our expectations are, but just because we have an expectation doesn’t mean that’s where the industry is today,” she admitted, of the call in the Code of Conduct for vessels to prioritize installing wifi so that workers can communicate more easily with those on land.
“We were very intentional with our word choices, so we have very clear statements around things like ethical recruitment, health and safety, working hours, and time at sea. But things like communication and wifi, we expressed our intention where we expect the industry to go.”
Indeed, while the document “mandates crew access to communication channels,” it concedes that not all suppliers will be immediately able to install wifi. Hourigan told SeafoodSource that the next step in the process is to “wor[k] with our suppliers, NGOs, and industry experts on the continuous improvement path to get us there.”
Fishwise social responsibility division director Kelley K. Bell congratulated the market chain on producing a specific, actionable, evidence-based document that “explicitly outlining their stance on key, emerging topics, including responsible recruitment and Wi-Fi on vessels. There should be no confusion about the expectations of those that are a part of the Whole Foods Market seafood supply chain.”
Ultimately the Seafood Code of Conduct offers both a set of expectations for Whole Foods suppliers and a set of ideals for the industry as a whole, however. CEO Jason Buechel said, in a release, that the program was the beginning of “an ongoing effort to raise the industry standard for human rights, responsible sourcing, and supply chain transparency.”
But Buechel emphasized that while Whole Foods would lead the way, it needed other retailers to adopt similar programs to improve working conditions for all: “working together with our industry peers, we can create a fairer, safer, and more ethical seafood industry for everyone.”
