Nomad Foods Ltd

Nomad recognises that negative social and environmental impacts within its seafood supply chains can lead to reputational, market and/or regulatory risks for its business model as a seafood company. The company acknowledges that the seafood supply chains are at risk of a range of human rights abuses, and overfishing poses a material risk to current and future fish stocks, compounded by poor fishing practices and the negative consequences of climate change. Negative environmental impacts from poor management of aquaculture farms are also acknowledged by the company.

In terms of Nomad’s overall supply chain management, the Supplier Code of Conduct applies to all its supply chain partners and sets out the company's expectations on human rights, environmental impacts, supply chain responsibility and traceability. This includes the requirement for all suppliers to have fully mapped their supply chains and to be able to evidence the origin of their products. Compliance with the Code is assessed through self-assessment questionnaires. The information from these questionnaires, along with country/sector data, also feeds into a risk score for the supplier. High-risk suppliers are required to complete a third-party ethical audit every two years.

Nomad's Palm Oil Policy states that it will only purchase palm oil from sources certified by the Roundtable for Sustainable Palm Oil, which can be traced back to RSPO-certified mills. Nomad's Soy Policy commits the company to verifying that the soy in its supply chain (including soy used in feed) is not from deforested land (legally or illegally). The policy also states that soy should be sourced from “relevant certification schemes wherever possible.” Where this is not yet possible, and soy is not 100% sustainably certified, Nomad compensates through the Roundtable on Responsible Soy credit scheme.

Nomad is developing its post-2025 targets and looking into ways to reduce carbon and promote biodiversity in their supply chains, including an updated deforestation policy in line with the forthcoming EU and UK legislative changes. In 2024, the company is also expecting to publish updated human rights policies and standards and is aiming to enhance its risk-assessment processes, expand its audit programme and explore how it can increase human rights due diligence within the upstream fish supply chain. During the meeting with investors and FAIRR, Nomad acknowledged that supplier audits on their own are not a sufficient tool to mitigate supply chain human rights issues, and that the company is considering new, more effective, approaches.

Nomad states that it works actively with its suppliers to exclude any fish originating from IUU fishing, or from fish stocks that are depleted or recovering, from any of its markets. As part of its Appetite for a Better World Sustainability Strategy, Nomad has two targets for “Better Sourcing”: i) to source 100% of its fish and seafood from sustainable fishing or responsible farming and ii) 100% of its vegetables, potatoes, fruit and herbs from sustainable agricultural practices, both by 2025. Nomad’s policy on Fish and Seafood Sourcing states that it only sources from suppliers that comply with either the FAO Code of Conduct for Responsible Fisheries or the FAO Technical Guidelines for Aquaculture. Apart from this policy, the company appears to rely on external certifications to meet its targets for sustainable fishing/responsible farming and its commitment to avoid seafood from IUU fishing and overfishing.

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

Nomad states it carries out regular traceability challenges as part of its supply chain product audits and refers to traceability in terms of legal requirements for food safety and labelling regulations, but these only apply in certain jurisdictions.

The company also asks its suppliers to have mapped their supply chains and to provide proof of the product origin at request.

While this policy applies to all food and food ingredients, it states Nomad can request the data but does not hold it or aspire to do so. Therefore, Nomad does not disclose a traceability commitment for all seafood and/or feed ingredients.

During the meeting with investors and FAIRR, Nomad stated that it is looking to explore digital traceability systems for its supply chains, and would be looking to leverage its relationship with certification bodies (such as the MSC and ASC) and utilise existing data to enable these organisations to offer digital traceability systems as part of the certification programmes.

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

Nomad has a target to source 100% of its seafood from sustainable fishing/responsible farming by 2025. Nomad defines sustainable fishing and responsible farming as MSC/ASC certified. In 2023, 99.5% of Nomad’s sourced fish and seafood volume was MSC- or ASC- certified. However, we understand that this certification rate excludes the company’s fish and seafood from the Adriatic region, a business that was acquired in 2021, which represents 5.5% of the total fish and seafood volume procured across the Group. The company states it procures around 30 species of seafood but stated in the investor call that the additional species from the Adriatic region “could be in the region of 20”.

For palm oil, Nomad achieved its 100% target to source only Roundtable for Sustainable Palm Oil Segregated certified sources for in-house production. For soy, only 14% of the purchased soy was certified as responsibly sourced in 2023 and, therefore, the company compensated through the Roundtable on Responsible Soy credit scheme for the remainder of the soy procured.

Overall, Nomad currently relies on external certifications and does not yet have a traceability commitment for seafood or feed ingredients. While MSC- and ASC-certified seafood, and other certified products with a Chain of Custody Standard, are verified to ensure that products from certified sources are separated from non-certified products and come from a specified fishery, this does not amount to full-chain, digital and interoperable traceability: Nomad does not have access to this data, the fish is not traced to vessel and the data collected does not align with the GDST’s universal list of KDEs. Only full-chain, digital and interoperable traceability will ensure that Nomad can prove legality and sustainability of its product and comply with current and future regulatory and food safety requirements.

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

Nomad does not have a traceability commitment, and therefore, no implementation plan in place.

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

Nomad does not disclose whether any operational traceability systems are in place for its seafood supply chains, or any details of its coverage in terms of scope, depth or breadth of data collected.

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

Nomad mentions conducting “regular product audits” within its supply chain on various factors, including traceability. The company also explains that it carries out “hundreds of traceability exercises every year.” However, no further details are provided on these audits, and rather than audits of existing digital traceability systems, we understand these are periodic checks on the authenticity of traceability documentation the suppliers hold in their records.

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