Marubeni Corporation

At the group level:

Marubeni's Green Strategy involves strengthening business areas considered 'green businesses' and 'greening' the company’s overall operations. The strategy also incorporates respect for human rights and mentions the utilisation of information and communications technology, and the development of a data platform for sustainability-related information. The overall aim of the strategy is for Marubeni to become “nature positive” in line with the December 2022 international goals of the Kunming-Montreal Global Biodiversity Framework. While this strategy covers the whole Marubeni group, including the food division, Marubeni does not disclose details of the strategy for the seafood business. Marubeni has registered its intention to adopt the Taskforce on Nature-related Financial Disclosures (TNFD) recommendations and intends to publish its first TNFD-aligned disclosures for the financial year 2025.

Marubeni has identified environmental and social materiality issues, such as “Human Rights & Co-Development with Communities” (including formulation of Human Rights Policy and due diligence process) and " Sustainable & Resilient Value Chains" (including surveys of Tier 1 suppliers and establishing and strengthening traceability). Marubeni’s Basic Supply Chain Sustainability Policy sets out its expectations on issues such as “Respect for Human Rights” and “Conservation of the Environment.'' The company states it will survey all Tier 1 suppliers and conducts due diligence analysis and risk assessment of all suppliers, new and existing ones. The company also assesses its consolidated subsidiaries for sustainability risks and carries out surveys and on-site visits for those where risks are identified. The Marubeni Group Environmental Policy sets out the company’s overall objectives for minimising environmental impact and the related governance structure but does not provide details on how seafood supply chain specific risks are identified and mitigated.

In June 2024, Marubeni published a new seafood products procurement policy that acknowledges the risks IUU, overfishing, aquaculture-related habitat conversion and human rights issues in the seafood supply chain. To mitigate these risks, Marubeni refers to abiding by laws and regulations, procuring more certified seafood (such as MSC, ASC and BAP), utilising Recirculating Aquaculture Systems (RAS) farming, reducing the use of plastics and communicating the company’s human rights and supply chain policies to its suppliers, but does not set any time-bound targets for these actions. On its website, Marubeni also discloses the certification rate for Eastern Fish (82% MSC/ASC/BAP) and Danish Salmon (100% ASC), but not for Marubeni Seafoods Corporation/Benirei. Finally, traceability is mentioned as a tool to identify risks for beef and cotton, but not for seafood.

At the subsidiary/associate level:

• Marubeni Seafoods Corporation/Benirei refers to “marine pollution” and “the decline of marine resources" on its website. Furthermore, it states that “demand for resource-conserving products is increasing”. While Benirei acknowledges that it is dependent on the limited seafood resources that are at risk, it does not define these risks as IUU, overfishing and habitat conversion. Benirei also refers to Marubeni’s group-level policies on human rights and sustainable supply chains.

• Eastern Fish states in its Supplier Code of Conduct that it is committed to environmental improvement in their fisheries and farms and to respecting internationally recognised human rights standards. Eastern Fish also talks about MSC certification as a way of “reversing overfishing” and “combating illegal fishing”. While Eastern Fish acknowledges the risks of IUU, overfishing, wider environmental issues and human rights issues within seafood supply chains, it does not explain how it assesses these risks within its own supply chains or how, beyond aiming to source certified seafood, it mitigates them.

• Danish Salmon (66.7% combined shareholding with Nissui) does not talk about IUU, habitat conversion or human rights issues, but does mention overfishing and describes Recirculating Aquaculture Systems (RAS) farming as a sustainable alternative to prevent some of the risks of traditional fish farming and wild capture fishing. Danish Salmon also states that its feed is fully traceable and certified by third-parties.

All sources of information are available in the company assessment PDF.

At the group level:

Marubeni lists establishing and strengthening traceability as one of the examples of its commitment to “Sustainable & Resilient Value Chains” within its Green Strategy. The company also discloses a traceability commitment for certain other products, such as forest-derived products, beef and cotton, but not marine products. The only mention of seafood traceability is in relation to the Danish Salmon acquisition when Marubeni describes RAS farming as a method that supports traceability.

At the subsidiary/associate level:

• Marubeni Seafoods Corporation/Benirei mentions traceability on their website in relation to “laws and regulations” and to “prevent food accidents” (website translated from Japanese). This does not amount to a traceability commitment for its seafood and feed ingredients.

• Eastern Fish states that “all product is fully traceable from farm to packaging”, but no further detail is provided on whether this traceability commitment also applies to feed.

• Danish Salmon (66.7% combined shareholding with Nissui) has a commitment to traceable seafood and feed, but the company does not specify whether both marine and terrestrial feed ingredients are fully traceable, nor do they elaborate on how traceability is achieved.

Overall, we see no evidence of Marubeni’s commitment to traceability for seafood and/or feed ingredients at the group level, or consistently at the subsidiary level. While Eastern Fish and Danish Salmon have high-level individual commitments to traceability, it is not clear whether these cover all feed ingredients, both marine and terrestrial. While Benirei, Eastern Fish and Danish Salmon likely account for “materially all” seafood business of Marubeni (95% of the company’s total seafood revenues), it is not possible at this time to confirm this based on the publicly disclosed information, as Marubeni does not disclose its total seafood revenues.

Marubeni responded to the investor letter stating that it is challenging to commit to full-chain traceability at the group level, given it is a wholesaler. The company also stated that it will first work with its suppliers through Tier 1 surveys and procurement policies and will continue to handle MSC, ASC and BAP certified products to “understand and reduce risks in the supply chain”.

We note that while certifications are important to seafood sustainability, they are not an alternative to full-chain, digital and interoperable traceability. Only traceability will enable Marubeni to have the required visibility to their seafood supply chain to identify impacts, dependencies, risks and opportunities and to substantiate legality and sustainability of their products. We encourage Marubeni to develop and disclose a group-level traceability commitment that covers all of its seafood and feed ingredients (marine and terrestrial).

All sources of information are available in the company assessment PDF.

At the group and subsidiary/associate level:

Marubeni does not have a time-bound commitment to full-chain, digital and interoperable traceability at the group or subsidiary level. Although Eastern Fish and Danish Salmon (66.7% combined shareholding with Nissui) both state that all seafood is fully traceable, it is not clear whether this also covers all stock inputs and feed ingredients (marine and terrestrial) for aquaculture or aligns with leading practice standards such as the GDST or the ASC feed standard. Marubeni Seafoods Corporation/Benirei has no traceability commitment.

Marubeni responded to the investor letter stating that it can provide information on the existing traceability commitments of some of its subsidiaries. It then stated that:

• For Eastern Fish, over 80% of the products handled are certified, and the company has published its commitment to source 100% of its products from responsible sources by 2025.
• Danish Salmon operates a closed-loop land-based aquaculture business and has obtained ASC certification.
• Benirei Corporation has set "protecting the richness of the oceans" as one of its environmental and social materialities and has a policy of promoting the handling of products certified by the MSC, ASC and others.

We note that certifications are not an alternative for full-chain, digital and interoperable traceability. Therefore, we encourage Marubeni to develop and disclose a group-level, time-bound commitment to full-chain, digital and interoperable traceability in line with the leading practice standards such as the GDST and, where relevant, the ASC feed standard.

All sources of information are available in the company assessment PDF.

At the group and subsidiary/associate level:

Marubeni or its subsidiaries/associates do not disclose any plans or key milestones for implementing traceability commitments.

All sources of information are available in the company assessment PDF.

At the group level: Marubeni does not disclose whether it has any operational traceability systems for seafood at the group level. In the company’s response to the investor letter, the company stated it has no plans to disclose further information. .

At the subsidiary/associate level:

• Marubeni Seafoods Corporation/Benirei does not disclose whether it has operational traceability systems in place.
• Eastern Fish states that “all product is fully traceable from farm to packaging”, which implies the existence of a full-chain operational traceability system.
• Danish Salmon (66.7% combined shareholding with Nissui) states both seafood and feed are fully traceable, which implies the existence of an operational traceability system.

While both Eastern Fish and Danish Salmon disclose that their traceability systems are full chain, they do not disclose the current scope (as it is not specified whether “all product" or “feed” covers both marine and terrestrial feed ingredients) or breadth of the data collected (whether key data elements collected align with the leading standards such as the GDST and the ASC feed standard). For both companies, this information is disclosed in individual policies on their website that are not updated annually.

We encourage Marubeni to implement full-chain, digital and interoperable traceability systems and, once in place, to annually report on the scope, depth and breadth covered.

All sources of information are available in the company assessment PDF.

At the group and subsidiary/associate level:

Marubeni and its subsidiaries/associates do not disclose any third-party verification for their traceability systems, nor do they report on non-compliance.

All sources of information are available in the company assessment PDF.