Culimer USA's Tuna Sourcing Commitment

Culimer Sustainability Vision

Culimer USA recognizes the importance of conserving the natural environment, preventing the depletion of natural resources (UN SDG 12 & 14), and upholding labor rights throughout our supply chains and in our company (UN SDG 3 & UN SDG 10). Culimer USA’s core purpose, to Enrich Society Through Food, supports people’s daily lives along the entire supply chain, from bait to plate. As an influential buyer, importer, and distributor of seafood from global producers around the world, Culimer has developed category-specific sourcing statements.

Approach

To achieve our vision and make progress toward our goals, we will use our due diligence framework to systematically and proactively address the environmental and social impacts within the seafood supply chain. Culimer defines Sustainability based on the United Nations’ definition as meeting present needs without compromising future generations’ ability to meet their needs (UN, 2023).

Tuna Sourcing Statement

We understand that tuna species are vital to the marine ecosystem and the livelihoods of millions of people worldwide (WWF, 2023; FAO, 2023). To support global tuna conservation efforts, we abide by both national and international laws. We consult with organizations such as the, Global Sustainable Seafood Initiative (GSSI), Regional Fisheries Management Organizations (RFMOs), Global Dialogue on Seafood Traceability, and the Global Tuna Alliance (GTA) to ensure we follow science-based management practices. These organizations provide valuable information about the health of the planet’s tuna stocks and the soundness of fishing practices to inform our tuna sourcing policies. Moreover, all of our tuna is processed in facilities using Global Food Safety Initiative (GFSI) benchmarked standards to ensure high-quality, trusted, and safe food for all of our customers.

GTA 5-year Strategy Alignment

Our goal is to source tuna from healthy and well-managed stocks, and we strive to use environmentally and socially responsible methods. As a Partner of the GTA, we share their dedication to core principles of environmental sustainability, social responsibility, and tuna traceability. We subscribe to the GTA’s Five-Year Strategy and take steps towards fulfilling its objectives. We also report our progress anonymously to the GTA, which collates and publishes it annually in the public domain as part of their progress-tracking exercise.

We align with the GTA Environmental Sustainability policies, including; Sourcing Policies, Harvest Strategies, FAD Management, Fin Naturally attached advocacy policies, and Biodiversity Beyond National Jurisdiction. Culimer USA sources wild and ranched tuna, including Atlantic Bluefin, Southern Bluefin, Bigeye, Skipjack, Yellowfin, and Albacore. We use certifications benchmarked by the Global Sustainable Seafood Initiative (GSSI), including the Marine Stewardship Council (MSC) and Aquaculture Stewardship Council (ASC).

Environmental Sustainability

Sourcing Policies & FIPs/ AIPs

All our tuna products are sourced from fisheries using science-based management plans and measures, ensuring acceptable impacts on the environment or a pathway to sustainability.

• We commit to sourcing 100% of bigeye, skipjack, yellowfin, and albacore products from fisheries with GSSI-recognized certification by 2025, and 100% of our wild tuna is MSC certified sustainable.

• We are committed to supporting RFMO management of tuna fisheries and encourage our suppliers to do the same. We also support credible Fishery Improvement Projects (FIP) and Aquaculture Improvement Projects (AIP) on the journey to becoming certified sustainable.

Our procurement team researches FIPs worldwide using Fishery Progress dashboards and alerts to qualify those that meet our criteria based. We work closely with FIPs and AIPs to help them on the journey towards sustainable certification.

• We develop FIP-specific sourcing guidelines, such as buying from comprehensive FIPs that are listed on the Fishery Progress site, and engage with them to achieve sustainability certifications as a long-term goal.

Fin Naturally attached advocacy

Culimer adheres to the GTA’s strict standards for naturally attached Fins, which follows the new MSC Fisheries Standard. All bigeye, yellowfin, skipjack, and albacore fisheries must prove that shark finning is not occurring and are audited for shark finning. We educate our clients on our naturally attached policy and sustainability requirements.

By-Catch & Endangered, Threatened, Protected (ETP) species

Bycatch is classified as “unwanted catch” by the MSC, which includes undersized or surplus fish that fisheries do not have a quota for and ETP species. It’s important to note that all tuna fishing methods have some impact on the marine environment, including on other species such as sharks, sea turtles, rays, and seabirds. Still, effects can be minimized to prevent long-term impact in the broader ecosystem. The MSC program, which Culimer USA uses, helps fisheries manage their unwanted catch levels by providing a benchmark that includes the latest science and best practice in fisheries management.

 We recognize the importance of reducing bycatch in tuna fisheries for the marine ecosystem’s long-term sustainability and the fishing industry’s economic viability.

• We commit to collaborating with stakeholders to promote best practices and sustainable fishing methods that improve longline fishing practices, such as using circle hooks and adopting best practices for handling and releasing bycatch.

Social Responsibility

Culimer USA recognizes the importance of social responsibility in achieving sustainability. Exploitative labor practices, including modern slavery and human trafficking, have been exposed by media reports. Culimer USA acknowledges that the seafood industry has recorded human rights violations, and it aims to work in collaboration with suppliers and industry groups to assess and mitigate any relevant occurrences within its seafood supply chain. Culimer USA is committed to:

• Achieving the Global Tuna Alliance’s social responsibility commitments (including a commitment to Employer Pays Principle, which includes ensuring socially responsible seafood supply chains, compliance with the International Labour Organization’s Convention 188, observer safety, and the International Maritime Organization Cape Town Agreement by 2025.
• Effectively manage human rights risks through comprehensive due diligence processes, proactive actions with supply chain partners, focused on high-risk supply chains, and regular public reporting. Culimer USA’s MSC-certified fisheries also leverage a social and labor audit, which serves as an MSC certification baseline requirement.
• Culimer is committed to working with suppliers to resolve and remedy any issues that arise. If issues are deemed to violate its zero-tolerance policy, Culimer will initiate a 12-month remedial process, followed by a reassessment. It will also publicly report on managing the human rights risks, including remediation actions taken.

Traceability, Verification, and Transparency

Tuna is a globally traded commodity that often passes through many hands, making it challenging to record and share product information throughout the supply chain accurately. Without proper traceability, significant risks such as illegal and unethical activities, can arise. Traceability is tracking and verifying the information about the origin and journey of tuna products through the supply chain. Culimer USA is committed to:

• Protecting against fraudulent activity by fully mapping our supply chain by 2025 and providing full-chain traceability through working with Trace Register, an electronic platform;
• We will never knowingly purchase or sell any illegal, unreported, or unregulated (IUU) fish and are committed to eliminating these issues through thoughtful purchasing and vigilant monitoring.

We recognize the importance of traceability for food safety, legality, and sustainability. As part of our commitment to the Global Tuna Alliance (GTA) Traceability commitments, we follow a strict five-year strategy for achieving traceability and transparency. Maintaining MSC Chain of Custody Certification for 100% of our wild tuna products to meet our baseline traceability standards.

• Ensuring all vessels have identifiers and a vessel flag as legal requirements for SIMP and transshipment transparency.
• Verifying all information and monitoring progress towards our goals on public progress reports and sharing publicly our ESG reports.
• Finally, we will never knowingly purchase or sell any illegal, unreported, or unregulated (IUU) fish and are committed to eliminating these issues through thoughtful purchasing and vigilant monitoring.

Global Dialogue on Seafood Traceability (GDST)

Culimer endorses the Global Dialogue on Seafood Traceability (GDST) Standards and Guidelines for Interoperable Seafood Traceability Systems (Version 1.0) as the minimum industry-wide standards for seafood traceability. We use GDST survey tools to assess current readiness for GDST implementation in internal and supply chain reviews. As part of our commitment to the GDST 1.0 commitments, we implement an electronic traceability system for all our tuna products, using the universal Key Data Elements developed through Global Dialogue on Seafood Traceability (or equivalent system).

We understand that electronic traceability alone cannot protect from fraudulent activity. We take necessary steps to verify all data to ensure requirements are being met across the supply chain. Therefore Culimer USA is committed to:

• From 2023, we will only purchase tuna products from suppliers that are identifying, capturing, and sharing GDST universal Key Data Elements (KDEs) (30%, 50%, & 80%). This will be reviewed on an annual basis.

Observer Coverage & Electronic Monitoring

Independent monitoring of fishing activity is not mandated in many tuna fisheries worldwide, which means there is much we cannot see, including many known conservation and compliance problems. The Marine Stewardship Council’s (MSC) sustainable fishery certification has updated its evidence requirement framework. The new standards will require fisheries to independently monitor 30% of catches to ensure accurate information on how the fishery interacts with other species and habitats. This can prompt more companies to consider implementing EM to validate sustainability claims for premium market access.

The Port State Measures Agreement (PSMA)

The Port State Measures Agreement (PSMA) is an international standard that, if ratified, could support a reduction in IUU fishing. As more nations implement port State measures, IUU fishing will no longer be a low-risk, high-reward enterprise. Culimer can assure that it is not inadvertently contributing to illegal fishing by supporting the adoption and effective implementation of the Agreement.

• From 2022, we will continue to purchase tuna products that are landed at Ports that operate Port State Measures (GTA KPIs) Ratified PSM but not implemented.

To maintain our sustainability commitment and achieve our aspirational goals, Culimer uses the following standards and tools to monitor traceability and prove sustainability from fisheries to transshipment transhipment. We use a combination of tools such as Trace Register and GS1 and partner with key bodies that align with our mission, including GTA, GDST, GFSI, Ocean Disclosure Project, Fishery Progress and the MSC/ASC. This allows us to be publicly transparent with our commitments.

Global Tuna Alliance

The relationship between the GTA and its Partners is synergistic. Partners are encouraged to be active participants in shaping and amplifying GTA campaigns. In return, the GTA provides exclusive toolkits, training, resources, and information and a forum for discussion with other Partners based in the “Partner Portal” on our website. What makes the GTA different is that they want to invest their time and resources into their Partners’ development, educating them on industry-related issues and facilitating their advocacy, enabling them to feel like active participants instead of offering support in-name-only. In return, the GTA gains an increase in its collective influence and global reach.

Fishwise

Culimer USA engages with Fishwise, a seafood industry compass that provides market-based tools and expertise in sustainability services, human rights action, and traceability best practices. Its employees use Fishwise’s Roadmap For Improving Seafood Ethics (RISE) learning module.

Global Dialogue for Seafood Traceability

The Global Dialogue for Seafood Traceability (GDST) is an international platform that brings together seafood industry stakeholders, including businesses, governments, NGOs, and academics, to develop and promote standards for interoperable seafood traceability systems. The GDST aims to provide a common framework that enables seafood traceability information to be shared accurately and efficiently across supply chains, which can help improve transparency and sustainability in the seafood industry. The GDST works to establish consensus on the key data elements that should be included in a seafood traceability system and the technical specifications needed for interoperability between different systems. The GDST is guided by a set of principles, which include openness, inclusivity, collaboration, and consensus-building.Culimer was the first company in the world that made a time bound commitment to implementing the 1.0 standards. See Press Release.

GS1

The GS1 traceability tool is a global standard for supply chain traceability that helps seafood companies track and trace their products through the entire supply chain, from harvest to distribution. It uses a unique identifier system to provide accurate, standardized information about each product, allowing for easy tracking and traceability. The tool enables seafood companies to share information with their supply chain partners in real time, ensuring transparency and accuracy in product information. It also enables companies to capture data at each stage of the supply chain, including harvesting, processing, transportation, and distribution. With this information, seafood companies can identify and address issues related to sustainability, such as overfishing, illegal fishing, and environmental impacts. They can also ensure that their products are safe, authentic, and meet legal requirements, such as the labeling and traceability regulations of the FDA and other regulatory bodies.

Global Food Safety Initiative (GFSI)

The Global Food Safety Initiative (GFSI) is an international collaboration between some of the world’s leading food safety experts from both the private and public sectors. GFSI aims to improve food safety by creating common benchmarks and guidelines for food safety management systems, which can be used by food businesses all over the world. GFSI works with key stakeholders in the food industry, including retailers, manufacturers, food service companies, and certification bodies, to promote and encourage the adoption of these benchmarks and guidelines. The GFSI benchmarks are recognized worldwide as a mark of food safety excellence. They are used by food businesses as a way of demonstrating their commitment to food safety and quality. GFSI’s work in benchmarking and harmonization aims to foster mutual acceptance of GFSI-recognized certification programs across the industry with the ambition to enable a “once certified, accepted everywhere” approach.

Global Sustainable Seafood Initiative (GSSI)

The Global Sustainable Seafood Initiative (GSSI) is a global partnership established to improve the sustainability of seafood production and supply chains. GSSI works towards achieving this by creating a benchmarking process for seafood certification schemes, ensuring that they meet certain scientific and technical criteria for sustainability. This process aims to increase transparency, consistency, and credibility of seafood certification and to provide a tool for businesses to make informed decisions about sustainable seafood sourcing. GSSI also provides guidance and support to seafood businesses to improve their sustainability practices and has a network of partners and stakeholders from across the seafood industry.

Ocean Disclosure Project

The ODP works towards the goal of 100% sustainably produced seafood by coordinating efforts to deliver greater transparency in global seafood supply chains. We help companies to disclose their seafood sourcing through an ODP profile that identifies the origin of their seafood, along with information on the environmental performance of those sources.

Fishery Progress

Fishery Progress is a platform developed by the Environmental Defense Fund to support and promote the improvement of global fisheries. It aims to accelerate the adoption of sustainable fishing practices and to provide a transparent and credible way for fisheries to demonstrate their progress toward sustainability. Fishery Progress works with seafood companies, governments, and non-governmental organizations to develop and implement fishery improvement projects (FIPs) that address each fishery’s specific sustainability challenges. The platform provides a comprehensive framework for measuring and reporting progress, allowing stakeholders to track each FIP’s performance over time. The ultimate goal of Fishery Progress is to help ensure the long-term health and viability of global fisheries while also supporting the livelihoods of the millions of people who depend on them.

Marine Stewardship Council

The Marine Stewardship Council (MSC) is an international non-profit organization that works with fisheries, seafood companies, scientists, conservation groups, and the public to promote sustainable fishing practices and to recognize and reward environmentally responsible seafood products. The MSC operates a certification program for wild-capture fisheries that evaluates them against strict criteria for sustainable fishing, including healthy fish stocks, minimal impact on the marine ecosystem, and effective management practices.

Aquaculture Stewardship Council

The Aquaculture Stewardship Council (ASC) is an independent, non-profit organization that was founded in 2010 by the World Wildlife Fund (WWF) and the Dutch Sustainable Trade Initiative (IDH) to promote responsible and sustainable aquaculture practices. The ASC develops and manages a certification program that assesses and recognizes seafood products that are produced in a socially and environmentally responsible way. The ASC certification program sets standards for responsible aquaculture practices that cover a range of issues, including animal welfare, environmental impact, social responsibility, and food safety.