Bolton Group

Lobbying
While Bolton Group provides some trade associations of which it is a member, it has an opportunity to show leadership by providing a full list separate from other partnerships. Additionally, while the company discloses some advocacy initiatives undertaken in the fishing sector, it has an opportunity to further show leadership by disclosing a full annual review of all the advocacy activities it has undertaken, making clear what its positions are for each activity.

Sustainability strategy and accountability
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 and reports consistently against all its targets.

Ecosystem conversion and restoration
The company is committed to minimizing ecosystem conversion and discloses certain activities to achieve this.

Resource exploitation and circularity performance
The company follows an international standard for disclosing its inputs. It also provides a management plan to prevent overexploitation and the use of threatened species in direct resource exploitation. Furthermore, the company discloses activities aimed at enhancing soil health or promoting agrobiodiversity in its production or sourcing practices.

Solid and air pollution
The company is reducing the production of hazardous substances and waste, and has targets to eliminate or reduce products and replacing them with sustainable alternatives, and reports progress against them. It also discloses the proportion of hazardous waste treated to reduce pollution, the hazardous waste diverted to and from disposal. Furthermore, the company demonstrates commitment, partakes in activities and discloses quantitative data related to plastic use reduction and transitioning towards sustainable packaging. The company has also set a target to increase the proportion of reusable or refillable packaging and reports progress against it.

Water
The company demonstrates reducing water withdrawal in its own operations. It also reports how much water is withdrawn for its own operations in water-stressed areas, and  The company engages with suppliers to reduce water withdrawal.

No leading practices were identified for the company in the social inclusion and community impact area.

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
The company 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.

Lobbying
The company has an opportunity to disclose a clear and detailed framework for assessing alignment of its trade associations with its sustainability targets and to report (potential) misalignments.

Stakeholder engagement
The company does not disclose how it engages with stakeholders, nor the issues it raises during such activities.

Sustainability strategy and accountability
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. Additionally, although the company discloses a remuneration policy related to sustainability, it could link this policy to improvement in nature-related objectives and social issues. Lastly, it could further disclose whether its highest governance body has expertise with respect to the company’s most material sustainability topics.

Ecosystem conversion and restoration
The company has revealed some indications of addressing conversion issues, but this doesn’t necessarily imply adherence to DCF-aligned practices. There are no time-bound objectives in place for achieving conversion-free supply chains. Furthermore, the company lacks a commitment to achieving zero conversion and restoring ecosystems. Details and outcomes of ecosystem restoration projects, whether affected by the company’s own operations or its suppliers, are not being disclosed.

GHG emissions
The company should set time-bound targets to reduce its scope 1, 2 and 3 greenhouse gas emissions as well as report progress against them. Crucially, the company needs to reduce its scope 1,2 and 3 emissions and its targets need to align with a 1.5-degree trajectory.

Impact and dependencies assessment
The company has an opportunity to disclose assessments of its impacts on nature, including biodiversity, within its own operations and in its supply chain. It also has the opportunity to disclose its dependencies on nature within its own operations and upstream business relationships.

Invasive species
The company has not identified any activities that could lead to the introduction of invasive alien species in its own operations.

Key areas and species
While the company does indicate the endangered status of bluefin tuna, it has an opportunity to comprehensively disclose the status of all species found in or adjacent to its own locations and those of its suppliers, according to national and international conservation lists. Furthermore, the company could enhance transparency by identifying locations in or adjacent to areas important for biodiversity, both within its own operations and its supply chain.

Resource exploitation and circularity performance
The company does not report quantitatively on its group-wide circularity performance. The company has an opportunity to disclose a target to improve soil health in its production or sourcing practices and report progress against it.

Solid and air pollution
The company should commit to avoid developing or marketing new chemicals or products with SVHC (substance of very high concern) properties. It has an opportunity to report on the amount of plastic waste generated and proportions directed from or to disposal. The company could also report on air quality parameters of emissions of harmful air pollutants and disclose time-bound targets to reduce air pollutants across the most material parts of its value chain.

Water
The company has an opportunity to further improve water withdrawal by engaging with suppliers. The company does not disclose relevant information on water pollution or rights to water in its operations or supply chains.

Indigenous Peoples’ and land rights
The company does not show if it is committed to respecting Indigenous Peoples’ rights or land rights of local communities.

Safe, clean, healthy and sustainable environment
The company has an opportunity to commit to respecting local communities’ right to a safe, clean, healthy and sustainable environment, and to zero tolerance for acts of violence, threats, intimidation or judicial harassment committed against land and environmental rights defenders. Moreover, it should track its actual or potential negative impacts on the health of local communities.

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.