This is part one of a three-part blog series, “Human Rights Due Diligence Snapshots.”

Part 1: The Role of Human Rights Due Diligence in Seafood
Part 3: The Role of Social Certifications and Audits in Human Rights Due Diligence

Given the complexity and breadth of many seafood company operations, and the many human rights due diligence (HRDD) frameworks and tools out there, you may be overwhelmed about how to start engaging workers in your HRDD process. At FishWise, we believe workers should be represented in every stage of HRDD, and they should have clear and safe avenues to advocate for themselves.

Companies undertake HRDD to prevent, identify, mitigate, and account for adverse human rights impacts on workers, communities, and stakeholders. Guidance for how to engage workers in this process varies across international standards and national legislation, but all have a strong emphasis in ensuring workers are enabled to play a significant role. The OECD Guidelines on Responsible Business Conduct, United Nations Guiding Principles on Business and Human Rights (UNGPs), the European Union’s Corporate Sustainability Due Diligence Directive (CS3D), and the International Labor Organization (ILO) Work in Fishing Convention (C188), each outline worker or stakeholder engagement in a different way, but there are consistent themes: ensure workers are meaningfully engaged in due diligence processes, provide workers with access to safe and effective grievance mechanisms, uphold freedom of association and collective bargaining, and promote decision-making power for workers.

The most vulnerable workers in the supply chain are typically those working at the sourcing level. They are also the most familiar with the conditions and can therefore speak to what changes are needed. 

Keeping workers at the core of HRDD means integrating worker participation, worker perspectives, and workers’ rights into how your company talks about and implements HRDD. It is important for companies to express support for freedom of association and collective bargaining throughout the process, and do what they can to enable worker-led efforts. Weave meaningful worker participation throughout your due diligence approach by ensuring the presence of effective grievance mechanisms, engaging responsibly, prioritizing worker safety and worker needs, and bringing worker representatives to the table when key decisions are made.

It is standard practice in any comprehensive HRDD implementation for companies to ensure that all seafood workers have access to an effective grievance mechanism to safely elevate issues, with clear pathways to resolve or remedy. 

• Determine whether there are existing worker-led grievance mechanisms and remediation processes, e.g. through a local worker or community organization and, if so, use that mechanism to identify grievances and remediate issues.
• If no such mechanism exists, collaborate with workers to design and implement operational-level grievance mechanisms and remediation processes with training on their use.
• At a minimum, grievance mechanisms should incorporate a case management system that includes support for workers to avoid a situation where they feel outnumbered or threatened for utilizing the mechanism. 
• Require employers to adopt anti-retaliation policies with associated training for supervisors so workers feel safe to speak up about issues.
• The grievance mechanism should include a clear, time-bound process that provides credible worker-verified remedies. 

It is important that workers are meaningfully engaged in any risk assessment, so action plans reflect their on-the-ground insights and realities.

• As you take the first step to assess risk across all of your supply chains and develop priorities, ensure that worker-informed data is leveraged.
• Then dive deeper into your prioritized supply chains and sourcing geographies to understand the risks from the workers’ perspective within the local context. Where there are unions or other worker organizations in place, you should reach out to them first.
• Include worker surveys and interviews through tools like Social Responsibility Assessments (SRA), and in-depth Human Rights Impact Assessments (HRIA). Share findings with workers and communicate how you will follow up.

With worker-informed data and worker engagement, you can then create action plans that are strategic and aligned with worker needs and conditions.

• Develop an action plan in consultation with the workers who will be impacted by it. The action plan should reflect worker needs, perspectives, and priorities and incorporate an understanding of root causes.
• Share the action plan and get workers’ input on solutions and necessary remediation. Be mindful that worker engagement does not trail off after an action plan is developed. They should be continually engaged in order to keep them informed and address their concerns. Coordinate with them as solutions are implemented to validate the results and communicate the outcomes.

While engaging with workers can be challenging, especially for those at sea, it is the most reliable way for you to learn the reality of workers’ experiences, identify issues, and work to resolve them. 

However, this can be tricky because company engagement in itself can hold risk to workers and risk to the process. Workers might mask issues for fear of losing their jobs, it can put an unfair burden on them, and direct engagement could put seafood workers at further risk if they are already in an unsafe environment. To choose an approach that best fits the context and prioritizes the safety and well-being of workers, you should work through your supply chain partners, and with trusted third-party experts to help guide your company in responsible worker engagement.

This is the time for companies to lean in: engage, allocate resources, take action, and align company practices to their commitments to protect the rights of those impacted by their business. To support your process, FishWise has just released guidance for companies with more detail on thoughtful worker engagement, worker-led efforts and other keys to success, Human Rights Due Diligence: The Fundamentals of Impactful Implementation. In this report, we focus on aspects of HRDD that companies often miss, or struggle to implement.

This is a supplemental guidance document to support the free and publicly available resources on FishWise’s Roadmap for Improving Seafood Ethics (RISE) platform, designed to guide companies in building responsible supply chains through HRDD. When paired together, you have actionable steps and tools to transform HRDD from a compliance exercise to a dynamic strategy focused on improving the lives of seafood workers. For more direct support, remember to consult with like minded peers, and human rights and social responsibility professionals, including FishWise, who can assist you in the design and implementation of your efforts no matter where your company is on its journey.