Bolton Group

Sustainability strategy
Bolton Group discloses its process for identifying and prioritizing 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.

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 fisheries and aquaculture
Bolton Group demonstrates its commitment to sustainable seafood by adopting environmental sourcing criteria. Additionally, the company provides quantitative evidence that it has increased the percentage of its sustainable seafood operations and sourcing through certification. In line with its commitment, the company has set a goal to source 100% of its tuna products from responsible fisheries for all of its brands by 2024. The company reports on its progress towards this objective and transparently discloses which parts of its portfolio certified, in an improvement project, or covered by another sustainability program.

Traceability systems and commitments for seafood products and aquaculture feed ingredients
The company’s subsidiaries, Bolton Food Group and Tri Marine, actively participate in the Global Dialogue on Seafood Traceability (GDST) and have endorsed the GDST standard, showcasing their strong commitment to traceable seafood. Bolton Group uses an ISO 2205 certified traceability system for 500 products under the Rio Mare and Saupiquet brands. Regarding its tuna products, the company states that it collects the following key data elements: species, fishing vessels, fishing areas, fishing methods, as well as certification status or involvement in a Fishery Improvement Project (FIP). Nevertheless, the company has an opportunity to disclose more information about the traceability system(s) in place across its entire seafood portfolio and not just tuna. Furthermore, the company can further reinforce its commitment by setting a specific time-bound target to achieve the GDST standards in all its operations and supply chain.

No leading practices were identified in the social responsibility area.

Respect human rights
Bolton Group 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.

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.

Act ethically
Bolton Group 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.

Sustainability strategy
While Bolton Group discloses some sustainability objectives/targets including environmental, social and traceability issues, it has an opportunity to establish group-wide targets for the most material parts of its value chain.

Accountability for sustainability strategy
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.

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.

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.

Ecosystem impacts of fisheries
Bolton Group sources from certified fisheries and supports Fishery Improvement Projects (FIPs). The company is also a member of the International Seafood Sustainability Foundation (ISSF). Bolton Group states that 79% of its branded tuna come from Marine Stewardship Council (MSC) certified fisheries or credible and comprehensive FIPs. The company also states that it aims to source 100% of its raw materials from suppliers who are certified and compliant with its sustainability policies. Nevertheless, the company has an opportunity to disclose the proportion of its entire product portfolio (not just tuna) is certified.

Risk-based approach to illegal, unreported and unregulated (IUU) fishing
Since 2021, Bolton Foods has established a collaborative partnership with the World Wildlife Fund (WWF), working on the implementation of a comprehensive Illegal, Unreported, and Unregulated (IUU) Risk Assessment across its entire supply chain. While this initiative demonstrates the company’s commitment to combatting IUU activities, there is an opportunity for further transparency by publicly disclosing the outcomes and findings derived from the risk assessment process as well as potential measures being deployed to address any IUU risks found in the assessment.

Disclosure of the source of seafood products and marine feed ingredients
Bolton Group provides a comprehensive overview of its sourcing, albeit not for all its products, as it encompasses only 90% of its sourcing. This overview includes pertinent details about species, geographic location, and management status of each source. Bolton Group has an opportunity to achieve complete transparency concerning the origin of all its seafood products.

Forced Labour
While Bolton Group does not allow a restricting of 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.

Farmer and fisher livelihoods
Bolton Group has an opportunity to identify living income benchmarks and assess living income gaps for some commodities and regions. Also, it could adopt procurement practices and develop supply chain relationships that improve farmers’ income resilience.

Working and living conditions on board fishing vessels
Bolton Food has implemented a comprehensive Code of Conduct for Tuna Suppliers, which prioritizes the provision of fair and adequate working and living conditions on fishing vessels. Furthermore, Tri Marine, one of the company’s subsidiaries, conducts surveys to assess the working and living conditions onboard these vessels. However, there is an opportunity for the company to further strengthen its practices by publicly presenting the results of its monitoring and follow-up actions taken based on the results of these surveys.

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.

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.

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.