Ian Urbina is the director of The Outlaw Ocean Project, a non-profit journalism organisation based in Washington D.C. In this column, he addresses the credibility of audits meant to detect food safety and labour violations in the seafood supply chain.

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Words by Ian Urbina
Photograph by Rachel Martin

Since the release of the last few investigations by The Outlaw Ocean Project on the global seafood industry, we have been asked repeatedly about the credibility of audits meant to detect food safety and labour violations in the seafood supply chain.

In November 2023, U.S. Customs and Border Protection advised companies that a social audit could only be used as credible evidence clearing a company accused of forced labour if it was unannounced, addressed all indicators, and conducted interviews in workers’ native languages. These conditions are rarely met for social audits conducted in China, according to various human rights groups such as the Worker Rights Consortium, which offered testimony before a Senate hearing in February 2023. The organisation reported that social audits in China are typically arranged with the involvement of factory managers and local police, and held on factory grounds.

In January 2022, a law firm called Leigh Day filed a lawsuit in the U.K. against a British auditing firm called Intertek Group PLC for failing to identify forced labour in the global supply chain of British retailer Tesco. “The promise from corporations has been that self-policing through the social audit process effectively roots out dangerous and exploitative practices,” said Oliver Holland, a lawyer from Leigh Day, but “the reality is far from it.” Social audits are typically announced ahead of time, and companies can request new audits if they do not like the results they are given, Holland said. Factory managers can exclude mentions of minority workers from the records that they turn over, according to a 2022 study from a collection of universities. They can also keep workers out of sight of the inspectors, and signs of forced labour such as debt bondage typically fall outside of the scope of the audits, the study said. It concluded: “These systems create an illusion of progress that fuels complacency and displaces effective solutions to address forced labour in supply chains.”

Recent reporting from The Outlaw Ocean Project has also exposed flaws in social audits used to monitor workplaces in India. On November 3, 2023, an auditor arrived at a shrimp-processing plant in Amalapuram, Andhra Pradesh named Choice Canning. They worked for SGS, a Swiss multinational firm that employs nearly 100,000 staff worldwide to provide auditing services. The auditor’s job that day was to conduct an inspection and determine if the plant was in compliance with the requirements set out by Brand Reputation Compliance Global Standards, a non-profit that maintains one of the most relied-upon food safety certification programmes in the world. In total, the auditor found only seven minor flaws across the plant’s operations and at the end of the day gave the plant an A grade, certifying it for another year of operation.

The next morning, another SGS auditor arrived at the plant to conduct an inspection. In their report, a more detailed examination produced daily and intended to help Choice Canning stay on top of safety and hygiene issues, the auditor cited “filth” and “slime” on processing machines and conveyor belts, flies in the shrimp-packing area, and “fungus” forming on walls. But the auditor didn’t produce this report for public consumption. They produced it for Choice Canning’s management team, who had asked them to identify problems for their eyes only.

Dozens of such confidential reports were recently made public by Joshua Farinella, a former manager of the Amalapuram plant who provided thousands of documents to the Outlaw Ocean Project. In these reports, SGS auditors detailed problems at the facility, including unsanitary conditions, improper waste disposal, and the presence of mosquitoes and flies near food preparation areas. (Choice Canning’s lawyers have since said that the internal audit reports showed how the company went to extra lengths to hold the plant to higher hygienic and food safety standards and the company worked throughout to fix the very problems that were being cited in those reports.)

Choice Canning said that it had been certified under not only the Brand Reputation Compliance Global Standards (BRCGS) but also under another third-party programme known as Best Aquaculture Practices (BAP). A spokesperson for SGS said that the plant had complied with the food safety audit requirements. SGS also said that “no certification reports are being shared with the client for internal use,” but did not respond to a request for clarification on the reports produced by SGS auditors for Choice Canning’s internal use.

Labour and supply-chain researchers say that there are fundamental flaws in the auditing system on which restaurants and retailers around the world depend. One of those flaws, they say, is that the auditing firms often cooperate with the food companies they’re auditing to provide them with certification. The system relies on the producers themselves to hire auditing firms to review their compliance, which gives the auditors a vested interest in the company passing the audit. “Ultimately everybody wants money in the industry,” an auditor who worked for 15 years in India told the Corporate Accountability Lab, a non-profit, in a 2024 report. “Nobody is working for the sake of betterment of workers.” The result of this breakdown in proper auditing practices is that multiple categories of problematic food products make it to the shelves of supermarkets and on to the menus of restaurants across the world.

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