Thai Union Group PCL
Seafood Traceability Engagement
Analysis Overview
Analysis Breakdown
Traceability and Commitment
As part of its SeaChange® 2030 strategy, Thai Union has committed to restore ecosystems and responsibly source wild-caught seafood, farmed seafood and agricultural ingredients. During the call with investors and FAIRR, Thai Union stated that this strategy was developed in collaboration with all business units which are now responsible for the day-to-day implementation to ensure strong buy-in across all levels in the organisation. Thai Union describes traceability as the backbone of its sustainability programme, helping to prevent the biggest issues in seafood sustainability, such as IUU fishing and human rights abuses. The company explained that its responsible sourcing efforts are prompted by various drivers such as regulatory compliance and customer sourcing requirements, reputational benefits and NGO partnerships.
For wild-caught seafood, the company has a target to source 100% of its products from fisheries that are at sustainable levels or “verifiably improving” and from vessels that adhere to best practices (or are verifiably improving) to prevent IUU fishing and modern-day slavery.
For shrimp, there is a target in place to source 100% from farms that minimise ecosystem impacts and are “safe and decent” workplaces.
For marine feed ingredients, the company states these must originate from responsibly managed fisheries (we note that this commitment was listed on the SeaChange® 2030 strategy website but not repeated in the more recent 2023 Sustainability Report disclosure).
Terrestrial feed ingredients must come from deforestation- and conversion-free sources (we note that this commitment was listed on the SeaChange® 2030 strategy website but not repeated in the more recent 2023 Sustainability Report disclosure). However, Thai Union has also committed to sourcing 100% deforestation- and conversion-free soy and palm oil across its entire supply chain and has committed approximately US $7 million for each “community-based programmes” and “the protection and restoration of critical ecosystems”.
All sources of information are available in the company assessment PDF.
Thai Union discloses its group-level traceability commitment for both wild-caught seafood and aquaculture in its SeaChange® 2030 strategy. The company also commits to establish traceability to “farm and feed across the global supply chain” and “downstream to farm, feed producers, soy producers” and “to ensure marine feed ingredients originate from responsibly managed fisheries” and ”agricultural feed ingredients originate from deforestation- and conversion-free sources”. This commitment meets the leading practice criteria of covering all seafood and feed ingredients.
However, we note that these commitments were reworded in the recent 2023 Sustainability Report.
For wild-caught seafood, Thai Union states “As part of our SeaChange® 2030 objectives and commitments, Thai Union is dedicated to ensuring the responsible sourcing of all our wild-caught seafood. This includes full traceability”. However, in the table showing the commitments, the company has included a note “data and monitoring systems are being developed for the 2030 goals” and only lists the TC25 commitments for tuna.
For aquaculture, the traceability commitment is now stated as “100% of farmed shrimp can be traced back to the farm level.” This wording differs from the original commitment on the SeaChange® 2030 strategy website as it now only refers to shrimp. Thai Union also states that its “vision extends to achieving full traceability of its products to the farm level” but then talks about certifications as means of achieving this, not implementation of full-chain, digital and interoperable traceability systems.
For feed ingredients, the commitment was reworded to state the following: “100% of shrimp feed used in shrimp products supplied to Thai Union is produced responsibly.” The commitment is now focused on shrimp feed only and is less specific given it does not mention traceability and only refers to certifications such as ASC, the ASC Feed Standard and BAP to ensure responsible production.
It is unclear whether its SeaChange® 2030 strategy commitments to traceability for all wild-caught and aquaculture seafood have been reduced to tuna and shrimp only. If this is the case, Thai Union should consider disclosing a breakdown of its overall seafood business by species. Furthermore, there is a lack of clarity on whether its commitment to responsible sourcing of aquaculture feed ingredients has been reduced to shrimp feed only or whether it still covers all aquaculture feed ingredients (marine and terrestrial). If the former, Thai Union should consider disclosing a breakdown of its exposure to overall aquaculture feed which should include the percentage for which shrimp feed accounts for. Clarification is also needed to ensure whether this commitment still covers full-chain traceability of feed ingredients, or only the sourcing of certified feed ingredients.
Thai Union’s commitment has been graded as partial disclosure. While Thai Union's traceability commitment is at the group-level, from the company’s most recent public disclosure (2023 Sustainability Report), it is not clear whether this commitment covers all seafood and feed ingredients, both of which the company has significant exposure to.
All sources of information are available in the company assessment PDF.
Scope and Implementation Plan
Thai Union has two traceability commitments in place.
TC25 is species-specific, time-bound (to be achieved by 2025), full-chain (“trace all tuna to a vessel or a group of vessels”) and aligned with the GDST standards (“GDST Standard 1.0 is implementable”). This alignment with the GDST means that Thai Union commits to collect traceability data in line with the GDST’s universal list of KDEs.
As part of the SeaChange® 2030 Strategy, there are several sourcing commitments in place with the target year of 2030. These include: For wild-caught seafood, Thai Union commits to responsible sourcing, including “full traceability”. For aquaculture, Thai Union commits to establish traceability to farm and feed across the global supply chain, ensuring marine feed ingredients originate from responsibly managed fisheries and agricultural feed ingredients originate from deforestation and conversion free sources.
Thai Union does not define “full traceability” for its wild-caught seafood commitment. However, the company states that it will be able to “trace each of our products back to its source – from the boat that caught it or the pond that produced it” elsewhere on the SeaChange® 2030 website. Therefore, the Thai Union traceability commitments appear to be full-chain to the vessel, the farm or the feed source, and cover all seafood and both marine and terrestrial feed ingredients. However, these commitments to traceability for all seafood, and aquaculture feed ingredients are no longer reflected in the 2023 Sustainability Report.
Thai Union states that it is a founding member of the GDST, publicly endorses the GDST’s standards and is actively involved in its work, including as a member of the Board of Directors of the GDST. However, the SeaChange® 2030 strategy does not specify a commitment to digital and interoperable traceability systems, which are aligned with the leading standards, such as the GDST.
We therefore encourage Thai Union to clarify whether its SeaChange® 2030 strategy traceability commitments are focused on full-chain, digital and interoperable traceability systems in line with leading practices such as the GDST and, where relevant, the ASC Feed Standard. Further, the scope of the commitment remains unclear, specifically whether it covers all seafood and both marine and terrestrial feed ingredients, or whether the initial scope is limited only to certain species. Finally, further clarity is needed on how Thai Union is defining full traceability.
Thai Union publicly reports on progress towards both traceability commitments (TC25 and the SeaChange 2030 Strategy) within its annual sustainability report.
However, for its SeaChange® 2030 strategy commitments, Thai Union does not disclose the interim or key milestones to be achieved ahead of 2030. However, during the call with investors and FAIRR, Thai Union confirmed that it has internal milestones in place, and it will consider disclosing this information.
Further, the company stated it has a budget of US $200 million to implement the SeaChange® 2030 strategy, and that there is a detailed financial analysis behind every commitment in the strategy, with the exception of greenhouse gas Scope 3 emissions reduction. Thai Union did not provide a further breakdown of the total amount, but confirmed that aquaculture receives the largest portion of this overall budget, followed by wild-caught seafood. Thai Union expects to make significant investments into aquaculture improvement projects, scaling auditing practices, as well as allowing for the cost premium for purchasing deforestation- and conversion-free (DCF) soy and for certified fish meal and fish oil.
For tuna, Thai Union has published a Tuna Commitment 2021 Progress Report, but this document does not disclose key milestones achieved on traceability. The company has stated that it will develop the interim milestones and targets covering the years 2020-2025. These have not yet been disclosed.
All sources of information are available in the company assessment PDF.
Monitoring and Reporting Progress
For the TC25, Thai Union reports publicly on the depth (traceable to the vessel) and breadth (current alignment with the GDST Standard 1.0., although it is unclear whether this will change to align with the latest standard) of this traceability commitment in the company’s annual sustainability report. The company discloses to have already achieved GDST-aligned KDE data for all tuna “purchased directly from fisheries”, but does not quantify how this compares to the total amount of tuna or to the total amount of seafood procured. Thai Union also states that “with further benchmarking and monitoring work, this will be further extended to complete each product’s traceability against the GDST as standard operational practice". Such a statement suggests that Thai Union is collecting additional GDST-aligned KDE data for tuna and potentially also for other species.
For the SeaChange® 2030 commitments, Thai Union reported on the status of some factors of its operational traceability systems (depth and breadth specifically for tuna and farmed shrimp supply chains). However, the overall scope of seafood business covered by traceability systems or alignment with GDST standards is not yet fully disclosed. Specifically, the company stated in its 2023 Sustainability Report the following:
For wild-caught seafood, the company has only reported on the TC25 commitments and states that “data and monitoring systems are being developed for the 2030 goals” . For tuna, 100% is traceable to vessel, but “GDST digital interoperability is in progress”. Therefore, it seems there has been no further progress since 2022 and the new commitments are actually not yet reported on.
For aquaculture, Thai Union reports to have achieved 100% paper-based traceability for all farmed shrimp traced back to the farm level. However, 0% is achieved for GDST-aligned digital and interoperable traceability. Also, this is limited to farmed shrimp, and the wider commitment to traceability of all aquaculture and feed ingredients is not reported on.
Whilst Thai Union acknowledges the ASC research finding that feed ingredients can account for up to 90% of environmental impacts of fed aquaculture production, the company does not report much information on its feed traceability. Thai Union owns and operates mills producing aquaculture feed, and one of them is now ASC Feed Standard certified. During the call with investors and FAIRR, the company confirmed that certifications are its preferred way to improve traceability for aquaculture feed ingredients.
During the call with investors and FAIRR, Thai Union stated that it is facing various challenges in implementing full-chain, digital and interoperable traceability systems aligned with the GDST standards including the lack of interoperability between systems, availability of data for certain species/ fisheries (e.g. artisanal fisheries such as blue swimming crab) and the digitalisation of data (e.g. captain statements are legally required to be in paper format).
All sources of information are available in the company assessment PDF.
While progress towards the TC25 tuna commitment is annually verified by the external consultancy Key Traceability, third-party verification is not discussed as part of the company’s wider SeaChange® 2030 strategy commitments, which cover other species and feed ingredients. Cases of non-compliance are not disclosed.
All sources of information are available in the company assessment PDF.
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Seafood Traceability Engagement