Nissui Corporation
Seafood Traceability Engagement
Analysis Overview
Analysis Breakdown
Traceability and Commitment
Nissui acknowledges the growing concerns about overfishing and depletion of marine resources and the threat this poses to its business model as a seafood company. The company also recognises the risk of IUU fishing and human rights issues in its seafood supply chains.
In 2021, Nissui formulated its long-term vision, “Good Foods 2030,” and its mid-term business Plan, “Good Foods Recipe 1”. As part of these plans the company has set specific sustainability targets, such as only procuring marine products from sustainable resources (80% by 2024 and 100% by 2030) and assessing all Tier 1 suppliers for compliance with the company’s Supplier Guideline (parent company suppliers by 2024 and group suppliers by 2030).
The company undertakes a survey on the sustainability of its procured marine resources every three years.
In 2024 (based on 2022 procurement data), the survey found that while 75% came from “well managed” or “managed” resources (4% increase from 2020), 8% came from resources needing improvement (no change from 2020) and the remaining 17% from “not scored” resources (4% decrease from 2020). To improve the results of the survey, the company states it will monitor the policies of its fishing countries (especially regarding IUU fishing) and make proposals to them on scientific resource management as a member of SeaBOS. Nissui disclosed that fish oil and fish meal used in aquaculture feed account for a significant part of the ‘not scored’ category. The company stated that it will “strive to enhance traceability in cooperation with external parties” to try to reduce that category.
Nissui has conducted a group-level human rights risk assessment for its value chains and has since revised its Supplier Guidelines to include requirement to eliminate any ties to forced and child labour. These guidelines also require suppliers to reduce their negative environmental impacts and prohibits IUU fishing and deforestation. There is also a requirement for suppliers to ensure the traceability of raw materials “to identify the risk of depleting resources”, but there is no further detail on how this requirement should be implemented. Nissui states that by 2023 it had collected written confirmations for compliance from parent company Tier 1 suppliers and had assessed 92% of these suppliers with self-assessment questionnaires. The company intends to expand this effort to the whole group’s Tier 1 suppliers and to Tier 2 and further suppliers in the future. Nissui has set a target of assessing 100% of the parent company Tier 1 suppliers by 2024 and 100% of the whole group’s Tier 1 suppliers by 2030.
As part of its SeaBOS membership, Nissui stated in its 2023 Sustainability Report that in 2021 it did not have any exposure to IUU fishing or labour violations. This statement was not made in the 2024 Sustainability Report.
In 2023, Nissui disclosed its first assessment of the company’s dependence and impact on nature and evaluation of the associated risks and opportunities in line with the Taskforce on Nature-related Financial Disclosures (TNFD) Framework. This assessment covered the entire upstream value chain of its fisheries and aquaculture business. The company states that in response to the risks identified, it has established five Sustainability Committee sub committees (the Marine Resource Sustainability Subcommittee, the Sustainable Procurement Subcommittee, the Marine Environment Subcommittee, the Plastics Subcommittee and the Environmental Subcommittee) to lead the sustainability work.
In its response to the investor letter, Nissui referred to its TNFD assessment (as discussed above) and stated it is currently conducting the Third Survey of Procured Marine Resources Sustainability with results available in September 2024. As of October 2024, we note that the results of this Third Survey have been published (in Japanese only). Nissui clearly recognises the risks of IUU, overfishing and human rights issues in its seafood supply chains, but does not mention habitat conversion apart from prohibition of deforestation in the Supplier Guideline. Nissui describes that it carries out risk assessments and provides some explanation of how these risks are identified and mitigated. However, we encourage Nissui to acknowledge the risk of habitat conversion, and to disclose more detail on how it identifies and mitigated these risks. This exercise would be complementary to its future TNFD reporting.
All sources of information are available in the company assessment PDF.
As part of reporting for the results of the sustainable resources survey, Nissui states that it will strive to enhance the traceability of marine feed ingredients. The Supplier Guideline also states a high-level requirement to ensure the traceability of raw materials. However, this does not amount to a commitment to implement traceability for all seafood and feed ingredients of the company.
Only full-chain, digital and interoperable traceability will ensure that Nissui has the required visibility to its supply chains to comply with current and future regulatory and food safety requirements, and to prove legality and sustainability of its products.
All sources of information are available in the company assessment PDF.
Scope and Implementation Plan
Nissui’s SeaBOS membership suggests that it is committed to implementing traceability systems aligned with the GDST. Cooperating to achieve the GDST was also noted in the 2018 survey results announcement , but this is not mentioned again in the current year’s reporting, or on the Nissui website.
During the call with investors and FAIRR, Nissui acknowledged that traceability is important, but challenging due to the wide range of fish procured and suppliers involved. However, Nissui also stated that while the company procures c.300 species in total, this is concentrated to certain species. Notably, the company’s top three species – Alaskan pollock, Peruvian anchoveta and Japanese sardine – account for approximately 50% of procurement, and the top 10 species for 75% (as also disclosed in the survey). Nissui also stated that 17% of its seafood procured in 2022 is “not scored”, but that the company has information on the resource management status for the remaining 83% of species procured. This means that Nissui has traced the seafood back to fishing grounds, but not full chain back to the vessel. Finally, the company stated it already collects some of the GDST KDE data for the resource management survey, but not all the data prescribed by the GDST. However, this mapping of survey data to GDST KDEs has not been publicly disclosed.
We encourage Nissui to disclose a group-level commitment to full-chain, digital and interoperable traceability systems that align with 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.
Nissui does not disclose a traceability commitment, and therefore does not have an associated implementation plan.
All sources of information are available in the company assessment PDF.
Monitoring and Reporting Progress
Nissui does not disclose whether any operational traceability systems are in place for its seafood supply chains. We encourage Nissui to implement traceability systems covering all the seafood business and to annually disclose their coverage in terms of the scope, depth and breadth of data collected.
All sources of information are available in the company assessment PDF.
Nissui does not disclose any details of operational traceability systems. We encourage Nissui to ensure that traceability systems covering all the seafood business are in place and annually verified by a third party.
All sources of information are available in the company assessment PDF.
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Seafood Traceability Engagement