Correspondence
Email to the press office of AH's parent company, Ahold Delhaize.
The email said: "I’m contacting you in light of our latest investigation which concerns the use of forced labor in China’s seafood processing industry, and a link we’ve discovered between companies engaged in such practices and a supplier in your supply chain - Yantai Sanko Fisheries. According to product labeling, Yantai Sanko Fisheries has supplied two types of dog food to Albert Heijn: AH twister snacks and AH sushi snacks. Yantai Sanko Fisheries Co. Ltd. has received persons from the Xinjiang region of China under a state- imposed labor transfer program under a state-imposed labor transfer program since 2019 and until at least April 2023. The United Nations, human rights organizations and academic experts agree that since 2018, the Chinese government has systematically subjected Xinjiang’s predominantly Muslim ethnic minorities to forced labor across the country via state-sanctioned employment schemes which use coercive methods in worker enrollment. The U.S. has prohibited the importation of goods produced from state-imposed forced labor. Does Albert Heijn or Ahold Delhaize have any comment or clarification to make regarding the above information?"
Pauline van Den Brandhof, Manager of External Communications at AH, replied: "We want customers to be able to shop with peace of mind. That's why suppliers of our private label products are certified according to social and environmental standards; we see this as an important foundation. In addition, as part of our purchasing conditions, we apply codes of conduct for our suppliers. These are brought together in the so-called Standards of Engagement. Additionally we do SMETA audits. An audit which helps to understand standards of labour, health and safety, environmental performance, and ethics within your own operations or at a supplier site. In this case the company has a clear policy of human rights and it was communicated to all appropriate parties including its own suppliers. Please could you tell me what is the source of your information? We don’t recognize it. Thanks in advance."
The Outlaw Ocean Project emailed: "Thank you very much for your reply to Ian’s email, and for engaging with us on this issue. You asked about the source of our information. We are unable to share any documents or other materials at this time, but we can say that our evidence includes footage showing people from Xinjiang, including Uyghurs, working inside the facility, as well as Chinese media coverage of Yantai Sanko accepting labor transferred out of Xinjiang. Was there anything in the audit reports or related materials that AH received about this supplier that indicated there are Uyghurs or other minorities from Xinjiang on-site? Do you know if this was specifically checked under the auditing criteria? And do you know when the most recent SMETA audit was carried out? Does AH distribute any pet food products containing raw materials from this supplier, Yantai Sanko Fisheries, to subsidiaries in the US, Indonesia or Europe?"
Pauline van Den Brandhof replied: "The Smeta audit was performed by Bureau Veritas, which is a publicized and reputable organization." The email then enclosed a snippet of the Smeta audit relating to forced/trafficked/bonded labor in the supply chain of the audited site. The email continued: "But if you have information that people are forced to work, that's not what we want. Please could you send images or other information to me (under embargo)?"
The Outlaw Ocean Project replied: "Thanks so much for that insight, Pauline. Do you know when that particular audit was carried out?"
In correspondence with The Outlaw Ocean Project's Dutch publishing partner, RTL, Albert Heijn said they have launched an investigation into the two products they have on the shelves that contain ingredients from Yantai Sanko Fisheries.
The Outlaw Ocean Project emailed Albert Heijn: "We last emailed Albert Heijn in August 2023 regarding our investigation into the use of forced labor in China’s seafood processing. Since then, our ongoing investigation has uncovered further evidence which we want to raise with Albert Heijn.
We have investigators on the ground in China who have been engaging with labor brokers directly involved with the transfer of North Korean workers to factories in China. Through this and other investigative means, including collecting online footage from the plants and interviews with workers recently returned to North Korea from China, we’ve found large numbers of North Korean workers at a range of seafood processing plants in Liaoning province, on China’s border with North Korea.
We have information that as recently as December 2023, there were 50-70 workers at Dalian Haiqing Food Co. Ltd. in Liaoning. The use of overseas North Korean workers was prohibited by the United Nations Security Council in 2017, with Resolution 2397 setting a deadline of December 2019 for the repatriation of all such workers to North Korea. Under the Countering America's Adversaries Through Sanctions Act (CAATSA), passed in 2017, the United States prohibits the import of any goods produced by North Korean nationals unless clear and convincing evidence is provided that indicates the materials were not made with forced labor.
According to trade records seen by The Outlaw Ocean Project, Pickenpack was the consignee for multiple shipments of seafood from Dalian Haiqing in 2020, 2021 and 2022. Packaging analysis shows that Pickenpack has supplied Albert Heijn’s own brand of fish sticks.
In light of the above, we have the following questions for Albert Heijn:
- While we understand that you may not be aware of the above issues, we want to ask if Albert Heijn has any comment to make in response to this email?
- Can you confirm or deny if Pickenpack supplied any product from Dalian Haiqing to Albert Heijn?"
Pauline van Den Brandhof, Manager of External Communications at Albert Heijn, replied: ""My colleague will come back to you, I hope today, or later this week."
Laura Jungmann, Director of Sustainability, at Albert Heijn emailed: "Thanks for your email. At Albert Heijn we take these allegations seriously, and have engaged with our supplier Pickenpack on these allegations. Please find attached their reaction. Pickenpack has assured us that respect for all human and labor rights is always a top priority for Pickenpack and Trident Seafoods corporation. Pickenpack has begun an independent investigation into the matter. As a precaution, they have suspended all trade with Haiqing on January 25th, 2024."
Attached to the email was a document from Pickenpack Seafoods signed by Pickenpack's Managing Director Thomas Scherer and dated February 9, 2024. This document said:
"Dear business partner, thank you for reaching out regarding the Outlaw Ocean Project allegations pertaining to the use of forced North Korean labor at one of our China supplier processors, Dalian Haiqing Foods (“Haiqing”). Trident Seafoods Co. (“Trident”) is the parent company of Pickenpack Seafoods, and Trident was notified of similar allegations in late January 2024. While no evidence has been provided to Trident to substantiate these allegations, out of an abundance of caution, the company voluntarily elected to suspend trade with Haiqing on January 25th, 2024, while we conduct an independent investigation.
Trident and its subsidiary companies have a zero-tolerance policy for human and labor rights abuses, and we take seriously any violations of our Global Supplier Code of Conduct. Our current investigation is ongoing, and we are specifically seeking evidence to support or refute the Outlaw Ocean Project allegations. As you may be aware, we are heading into Chinese New Year, when most companies in China shut down for annual holidays. While this will delay our investigative process, we are committed to conducting a thorough investigation as quickly as possible.
Trident is dedicated to ensuring people are treated with dignity and respect throughout the seafood supply chain.We take an active approach to ensuring that our unique Corporate Social Responsibility (CSR) program and policies are adhered to in all operations. Our CSR requirements are often more stringent than local laws. Leadership at each of our suppliers has signed and accepted Trident’s Human Rights Policy and our Global Supplier Code of Conduct. If you would like to know more about our program and how Trident is taking the lead on demanding accountability in global seafood supply chains, please visit our global website to read our CEO op- eds - Trident Seafoods Call to Action: We Must do Better (October 2023) and Doing What’s Right (January 2024). In addition, all Trident seafood suppliers in China have current third-party SMETA audits. Trident requires the comprehensive 4-Pillar SMETA versus the narrower scope 2-Pillar SMETA option. Strategically, we use two independent audit firms for social audits in China to invite new perspectives and opportunities for improvement through the audit process.
Regardless of the outcome of our investigation, we will use this opportunity to review our CSR program and determine if there are opportunities to continue to strengthen and improve our approach.
Your partnership is important to us. There is nothing you need to take action on today, and we will follow up with you at the conclusion of our investigation.
Please reach out to Oliver Wadel if you have any questions."
The Outlaw Ocean Project replied: "Thank you for that update and the statement from Albert Heijn. We do very much appreciate your engagement with our questions and with the issues raised by our reporting.
Thanks also for sharing the customer statement furnished by Pickenpack Seafoods and Trident. We do want to address one point raised in that statement, the claim that “no evidence has been provided to Trident to substantiate these allegations”. We have discussed in detail the methodology, findings and evidentiary materials of our investigation with Trident in email correspondence dating back to January 12, 2024. In what we detailed for them over various on-record email exchanges, we cited interviews with North Korean workers from the plant who are now back in North Korea as well as interviews with managers and business leaders who visited and/or worked at the plant. All of them confirmed the presence of North Koreans on site in significant numbers. We also have tried to be extra transparent with Trident in explaining the methods used for conducting worker interviews in China and North Korea, as well as how we were able to dispatch investigators to various seafood processing plants in China.
We would also like to note that the findings of our previous investigations, of Uyghur forced labor in Chinese processing plants and forced labor on Chinese squid ships, have been accepted by both the industry and by policymakers."