Bolton Group

Lobbying and advocacy
Bolton Group provides some trade associations of which it is a member. It could, however, provide a full list separate from other partnerships. Furthermore, while it reports some advocacy initiatives undertaken in the fishing sector, it could disclose a full annual review of all the advocacy activities it has undertaken, making clear what its positions are for each activity.

Sustainable development strategy
The company discloses its process for identifying and prioritising its most relevant sustainability impacts as well as the outcome of this process, in relation to its sustainability strategy. Furthermore, it reports consistently against all its targets.

Plastic use and packaging waste
The company demonstrates commitment through its policies and activities aimed at reducing plastic use and transitioning to sustainable packaging. It also discloses quantitative data regarding their efforts in plastic use reduction and use of sustainable packaging. Additionally, the company has set targets to increase the proportion of reusable or refillable packaging and provides progress reports on these targets.

Sustainable fishing and aquaculture
Bolton Group demonstrates its dedication to sustainable fishing and aquaculture through qualitative evidence, specifically by adhering to environmental sourcing criteria. Additionally, the company provides quantitative evidence by actively increasing the percentage of its sustainable fisheries and aquaculture operations and sourcing. In line with its commitment, the company has set a goal to obtain 100% tuna from responsible fishing practices for all of its brands by 2024. The company regularly reports on its progress towards this objective and transparently discloses the extent to which each certification scheme, improvement project, or other sustainability program covers its portfolio.

Water withdrawal
The company actively demonstrates its commitment to reducing water withdrawal in its own operations. This is further supported by their practice of reporting the amount of water they withdraw from water-stressed areas. Moreover, the company actively engages with its suppliers to encourage and facilitate their efforts in reducing water withdrawal.

No leading practices were identified in the nutrition area.

Forced labour
The company discloses a commitment to prohibit the payment of any recruitment fees or related costs to secure a job, to retain workers’ personal documents or to restrict workers’ freedom of movement in its supply chain.

Act ethically
The company has a policy prohibiting bribery and corruption and a public commitment to protect personal data. It also specifies that it does not make political contributions.

Provide and promote decent work
Bolton Group has a publicly available policy statement in which it commits to respecting the health and safety of workers and expects its business relationships to commit to respecting the health and safety of their workers. While the company discloses that it has 33.33% women on the board it targets to have 40% women in top management positions by 2023. Furthermore, the company provides the proportions of age group and proportion of women of its total direct operations workforce for each employee category by age group. It also has a time-bound target for paying all workers a living wage.

Moreover, it publicly states that all overtime work must be consensual and be paid at a premium rate and that workers shall not be required to work more than 48 hours in a regular work week or 60 hours including overtime. Additionally, the company describes how it works to support the practices of its business relationships in relation to freedom of association and collective bargaining.

Respect human rights
The company has a publicly available policy statement committing it to respect human rights and the ILO core labour rights and expects its suppliers to do so. Furthermore, it describes the process for identifying human rights risks and impacts in its supply chain and publicly discloses the results of its human rights risk assessments. The company discloses categories of stakeholders whose human rights have been or may be affected by its activities such as workers in the plants, fishermen and women.

Governance and accountability for sustainable development
The company has an opportunity to link performance criteria in senior executives’ remuneration policies to targets and objectives which cover environmental and social issues. Furthermore, it could disclose whether its highest governance body has expertise with respect to the company’s most material sustainability topics.

Lobbying and advocacy
The company has an opportunity to disclose a clear and detailed framework for assessing alignment of its trade associations with its sustainability targets. Additionally, it can report any potential misalignments between the lobbying activities of its trade associations and its sustainability targets.

Stakeholder engagement
The company has an opportunity to disclose how it engages with stakeholders, the issues raised during such activities, and the outcomes of its stakeholder engagement.

Sustainable development strategy
While the company discloses some sustainability objectives/targets including climate, social inclusion and ecosystem conversion, it has an opportunity to establish group-wide targets for the most material parts of its value chain.

Scope 1, 2, and 3 greenhouse gas (GHG) emissions
Bolton Group has an opportunity to reduce its scope 1 and 2 greenhouse gas emissions. Although it discloses its commitment to 2025 to cut GHG emissions and has disclosed its progress in reducing CO2 emissions against a baseline year of 2017, its goal to reduce scope 1 and 2 emissions is not time bound. There is also an opportunity to align the company’s scope 1 and 2 emissions targets with a 1.5-degree trajectory. Similarly, the company has an opportunity to reduce its scope 3 greenhouse gas emissions, disclose relevant time-bound reduction targets, in line with a 1.5-degree trajectory, and report progress against its targets.

Animal welfare
The company has an opportunity to disclose animal welfare targets applicable to all species, geographies and products.

Water withdrawal
The company has disclosed a target to reduce water consumption, but there is no evidence that the company has disclosed a target to reduce water withdrawal across its own operations or reports progress against this target.

Availability of nutritious foods
The company has made commitments to reduce salt and added sugars in certain products. However, it can further improve by reporting on its overall efforts to reduce sugar, salt, and fat, and increase the presence of positive nutrients in all its products. Additionally, the company could consider adopting a nutrient profiling system that aligns with government-endorsed or externally validated nutritional guidelines and setting a sales-based target to increase the proportion of more nutritious products.

Clear and transparent labelling
The company has an opportunity to adopt front-of-pack labels or any other consumer- facing nutrition labels that support consumers with making healthier food choices. Additionally, it can disclose the percentage of products for which its front-of-pack labelling schemes have been rolled out.

Workforce nutrition
The company has an opportunity to disclose evidence of workforce nutrition programmes.

Child labour
The company has an opportunity to disclose examples of remediation programmes when a case of child labour is found in its operations and to indicate how it is building the capacity of its suppliers to prevent child labour impacts. While the company prohibits its suppliers from using child labour, it could require them to have an age-verification system in place.

Forced labour
While the company does not allow to restrict workers’ freedom of movement, it has an opportunity to disclose a prohibition to pay recruitment fees for its operations. Furthermore, it could indicate how it is building the capacity of its suppliers to prevent forced labour impacts

Living wage
While the company has committed to map the minimum living wage in all the geographies where it has activities and close possible gaps by 2024, it has an opportunity to expand this target to paying a living wage across its direct suppliers and describe how it determines a living wage for the regions where it sources. Also, it could disclose the percentage of workers across its own operations or direct suppliers that are paid a living wage.

Act ethically
The company could describe the process for identifying its bribery and corruption risks and impacts in specific locations or activities covering its own operations and could include anti-bribery and anti-corruption clauses in its contracts with business relationships. Furthermore, while the company has a mechanism for stakeholders to raise bribery and corruption concerns, it is unclear if this mechanism is accessible to all stakeholders and if complainants have the option to identify themselves or remain anonymous.

Additionally, it also has an opportunity to have a policy setting out its lobbying and political engagement approach and to disclose its expenditures on lobbying activities. The company also consider disclosing that it requires third-party lobbyists to comply with its lobbying and political engagement policy.

Provide and promote decent work
The company has an opportunity to disclose how it monitors the health and safety performance of its suppliers. Furthermore, it could disclose how it determines a living wage for the regions where it operates and how it works to support the payment of a living wage by its suppliers.

Moreover, while the company has a statement on gender equality, it has an opportunity to disclose a public commitment to women’s empowerment and can consider disclosing the ratio of the basic salary and remuneration of women to men in its total direct operations workforce for each employee category, by significant locations of operation.

Respect human rights
The company has an opportunity to describe the process for identifying its human rights risks and impacts in specific locations or activities, covering its own operations. The company could also disclose a global system to act on, prevent or mitigate its salient human rights issues.