Bolton Group

No leading practices were identified for the company in the governance and strategy measurement area.

No leading practices were identified for the company in the ecosystems measurement area.

Commitment to traceability
Bolton Group has made a commitment to traceability by stating that its current traceability system, based on the ISO 22005:2008 standard, which is already in place for its tuna sourcing, will be extended to all other species in its portfolio by the end of 2024. While its subsidiaries Tri Marine and Bolton Food have participated in drafting the Global Dialogue on Seafood Traceability (GDST) standard, Bolton Group can contribute to traceability in the seafood industry by formally adopting the GDST standard.

No leading practices were identified for the company in the social responsibility measurement area.

Sustainable development strategy
Bolton Group and its newly acquired subsidiary, TriMarine, have separate sustainability strategies. As such, Bolton has set time-bound targets on its most material topics, one being responsibly sourced tuna, and a set on social responsibility. TriMarine’s targets, while more related to the seafood industry, are not all time-bound and no reporting on progress has been found. Bolton Group has an opportunity to set company-wide time-bound targets on material issues to the seafood industry.

Governance and accountability for sustainable development
Accountability and oversight of Bolton Group’s sustainability strategy lie with its highest governance body, the Group Executive Board. The company also discloses its decision-making process and oversight responsibilities, as well as its remuneration policy regarding sustainability objectives. It has an opportunity to further improve by including explicit environmental criteria in its remuneration policy.

Stakeholder engagement
While Bolton Group reports engaging with some nongovernmental organizations, no overview was disclosed of all its stakeholders nor about issues raised with them. In addition to listing its stakeholders, the company has an opportunity to disclose its process for identifying and engaging with stakeholders, the outcomes of its engagement and its integration into its sustainability strategy.

Engagement in policy advocacy
Bolton Group provides several examples of policy advocacy activities, mainly focused on the environmental management of tuna fisheries. These include hosting advocacy calls from regional fisheries management organisations, supporting the Global Treaty on Plastic Pollution, being an active member in the International Seafood Sustainability Foundation (ISSF) and signing the 2020 tuna traceability declaration of the World Economic Forum. While the ISSF reports on progress and impacts of policy advocacy activities, the company has an opportunity to further explain the results and impacts of its own policy advocacy activities.

Commitment to sustainable fisheries and aquaculture
Bolton Group has several commitments to sustainability depending on the seafood products and the subsidiaries involved. At group level, the company states that it aims to source 100% of its raw materials from suppliers who are certified and compliant with its sustainability policies. The objective of its subsidiary Bolton Foods is that by 2024 all its tuna, mackerel and sardines will be sourced from Marine Stewardship Council certified fisheries or robust fishery improvement projects (FIPs). For aquaculture products, the same commitment and deadline applies, but with Aquaculture Stewardship Council certifications and robust aquaculture improvement projects. The company has an opportunity to set group-wide time-bound targets and to consolidate its reporting to make sure its entire portfolio is sustainable by 2024.

Ecosystem impacts of fisheries
Bolton Group and its subsidiaries report several activities to mitigate its impact on by-catch, endangered species and sensitive habitats of its tuna supply chain. Together, they demonstrate that all their tuna sourcing applies ISSF conservation measures. The company also reports that it complies with the Global Ghost Gear Initiative and is involved in several projects on biodegradable materials and non-entangling fish aggregating devices. The company’s activities demonstrate that it is working to achieve its commitments, but there is still room for improvement. Where risks have been identified, Bolton Group could clearly report which source fisheries are in improvement projects and which are not and also describe its approach for improving all problematic fisheries.

Ecosystem impacts of aquaculture
Although aquaculture products represent only a small part of the company’s sourcing, Bolton Group can improve its reporting on how it promotes sustainable aquaculture practices in its supply chain. In addition, it can disclose how it addresses important issues in aquaculture, such antibiotic use, animal welfare, and impacts on endangered species and sensitive habitats.

Traceability system for seafood products and aquaculture feed ingredients
Bolton Group reports that it relies on a fully digitalised traceability system for its entire tuna supply and explains which data is collected. It also uses its Supplier Workplace to provide its suppliers with required traceability documentation. The company has an opportunity to explain how it traces the origins of other species and how traceability of its seafood products is harmonised between its various subsidiaries.

Risk-based approach to IUU fishing
Bolton Group and its subsidiaries report on several measures to address illegal, unreported and unregulated (IUU) fishing risks. These include using the IMO database and Proactive Vessel Register, advocating for stronger regional fisheries management organisations, complying with the ISSF conservation measures and compliance process, and strengthening monitoring, control and surveillance. These activities demonstrate good performance, though it is not clear whether these only apply to the company’s tuna supply chain and how it assessed IUU fishing risks for other parts of its portfolio.

Disclosure of the origin of its seafood and marine feed ingredients
Bolton Group discloses the management status for its key species and the FIPs it sources from. However, specific information for each fishery, such as management status and geographic location, are not publicly disclosed, nor are the sources of its aquaculture products. The company could improve its transparency by publishing these.

Child and forced labour
While Bolton Group is committed to prohibiting child and forced labour in its own operations and requires its tuna suppliers to adhere to the same standard, it has an opportunity to expand the scope of this requirement to include its entire supply chain. In addition, the company can improve disclosure on how it monitors for the presence of child and forced labour in its operations and supply chains.

Health and safety of vulnerable groups
While Bolton Group recognises the health and safety risks to young workers, it does not provide evidence of supporting activities that improve their health and safety.

Farmer and fisher productivity and resilience
Bolton Group is committed to supporting fishers and small-scale producers through fair-trade terms, such as its subsidiary TriMarine obtaining FairTrade certification in the Solomon Islands or providing training to processing facility staff through SolTuna, an affiliated company. However, the company has an opportunity to demonstrate that it is measuring the impact of its activities and report these externally.

Working and living conditions on board fishing vessels
Bolton Group’s code of conduct for its tuna suppliers contains requirements on the right to decent living standards, accommodation and adequate food and water while on board vessels at sea. The company has room for improvement by expanding this code to its entire supply chain and disclosing a monitoring mechanism to ensure compliance.

Respecting customary and indigenous rights and support for local communities
Bolton Group does not demonstrate that it respects customary and indigenous rights. Subsidiary TriMarine reports investing in local communities through fishing and processing bases in Ecuador and the Solomon Islands. On employment and beyond, the company has an opportunity to disclose the outcomes of its community engagement and elaborate on a commitment to respect customary and indigenous rights.

Bolton Group commits to respecting human rights and core labour rights of the International Labour Organization (ILO) in its operations. It also discloses a statement expecting suppliers to respect ILO core labour rights. However, the company does not demonstrate it has in place a grievance mechanism that is accessible to all workers and third parties. Moreover, Bolton Group does not provide evidence of a human rights due diligence process nor disclose how it engages with affected and potentially affected stakeholders.

Bolton Group commits to respecting the health and safety of its workers. It expects its suppliers to do the same and monitors their performance. However, the company can improve disclosure by reporting on, for example, the number of fatalities and high-consequence injuries in the workplace. Bolton Group discloses data on the proportion of its workforce by gender, but it lacks disclosure on other markers of diversity, such as age and ethnicity. No commitments or policies were found related to the other decent work topics, such as living wage, working hours, collective bargaining, and gender equality and women’s empowerment.

Bolton Group prohibits bribery and corruption in its operations and includes related clauses in its contracts with business relationships. However, it does not disclose how it identifies bribery and corruption risks and impacts. While the company discloses a privacy statement on the collection, sharing and access or personal data, this is limited to data collected through its website, which excludes other types of personal data. Bolton Group does not disclose a global tax strategy or a policy setting out its approach to lobbying and political engagement, nor does it report on tax and lobbying expenditures.