Information on the Tackling of Human Trafficking Issue
in the Thai Tuna Industry 2016
Prepared by the Thai Tuna Industry Association
In the last few years, several media have reported on forced, slave and child labor in fishing
industries which targeted Thai fishery products. The Thai government and private sectors have been
responsive to these allegations and have worked together on more comprehensive and relevant laws,
regulations and measures to alleviate forced labor and human trafficking issues.
The Thai Tuna Industry Association (TTIA) wishes to reiterate that no forced and slave labor are
used throughout the supply chain of the Thai tuna industry. The TTIA have curbed with forced labour and
human trafficking issues in three main aspects which are as follows;
Part I Imported Raw Materials
Thai tuna industry process 700,000 – 800,000 tons of Tuna per year or 95 percent of the whole
round frozen tuna are imported from many different parts of the world and only 5 percent come from
Thai-owned ships (see Table 1). USA ranks as the second largest source of tuna for the Thai tuna industry
or 14 and 11% of total tuna import in terms of quantity and value(see Table 2) . The number one source
is Taiwan.
Table 1: Supplying of Whole Round Tuna for Thai Tuna Industry in 2013-2015
Tuna Origin
1. Local Tonggol tuna
2. Thai’s frozen tuna import
Total
Quantity (Ton)
2013
37,636
752,725
790,361
2014
34,696
693,927
728,623
2015
33,175
663,505
696,680
%
Growth
14/15
-4
-4
-4
% Share
2015
5
95
100
Table 2: Thai Imports of Frozen Whole Round Tuna from the World in 2013-2015
Product description: Sum of frozen whole round tuna is covered HS Code 0303.41 Albacores,
0303.42 Yellowfin, 0303.43 Skipjack, 0303.44 Bigeye and 0303.49 Other tuna.
Source: www.moc.go.th, Prepared by Thai Tuna Industry Association
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Part 2 Control throughout the Supply
In order to prevent the use of forced and slave labour in TTIA members’ factories and their supply,
the Association has the following policies and measures to control and TTIA members have pledged to
conduct accordingly:
2.1 TTIA’s Ethical Labour Practice – Code of Conduct
One of the key activities that TTIA has done on labour issues is the policy commitment on Ethical
Code of Conduct. Companies applying to our members are required to submit their written commitment
in compliance with TTIA’s Ethical Labour Practice – Code of Conduct, mostly based on Thai law. It covers
8 items as follows:
1) Child Labour: No workers under age of 18 years old is engaged or employed in the processing
plants. Upon recruiting, all applicants shall provide a government-issued passport, Identity card and/or
work permit for verifying age and legality to work respectively.
2) Forced and Compulsory Labour: Workers are not required to pay deposits or recruitment fee
to the company. The company shall not lodge passport, Identity card and/or work permit belonging to the
workers. The company shall not withhold any part of workers’ salary and benefits.
3) Health and Safety: Occupational health and safety of workers shall be of the utmost concern
for the company. At minimum, all legal requirements of related laws must be fulfilled. They include to
the provision of necessary personal protective equipment at the employer’s expenses, first aid treatment,
and assistance for follow-up medical treatment.
4) Freedom of Association and Right to Collective Bargaining: As permitted by Thai law, the
company shall respect the rights of workers for freedom of association and collective bargaining.
5) Discrimination: The company shall not allow any behavior indicating harassment,
discrimination or bullying. Education and training on the fundamental of human rights shall be
conducted for all personnel concerning the supervision of workers and security practice. The company
shall have in place the mechanism and grievance handling to ensure fair treatment of workers.
6) Disciplinary Practices: The company shall not engage in or tolerate the use of corporal
punishment, mental or physical coercion, or verbal abuse of workers. Deductions from wages as a
disciplinary measure are not allowed.
7) Remuneration: The minimum daily wage shall be fully paid according to Thai law to every
workers. Overtime work shall be reimbursed at a premium rate and paid leave shall be granted as defined
by Thai Law.
8) Welfare and Benefit: Social security payments are contributed by both workers and company
– in accordance with Thai Labour Law – which ensure all workers are eligible for national health care
coverage. The company shall register every workers to this scheme from the first day of employment.
For the period where the national health care coverage is not yet in effect, the company shall provide
adequate medical treatment and expenses to assist any work-related injuries and illnesses.
2.2 Ethical Code of Conduct in Supply Chain
The Association policy stipulated that members apply the ethical code of conduct both upstream
and downstream of the supply chain in order to align to the association’s code as follows:
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Supply Chain of Thai Tuna Industry
towards Ethical Code of Conduct
Fishing
Vessels and
Carriers
Fish Brokers, Ship agents,
Unloading Wharfs,
Stevedores and Freezers
Supporting
industries
Tuna
Processing
Factory
Exporting Port
TTIA’s Policy
- Use legal workers only.
- Local fishing vessels supplying Tonggol tuna have to install
VMS system for fishing vessels programme and use legal
workers according to the Thai law. They are regulated and
monitored by DOF and concerned government agency.
- Fishing vessels in high sea have to comply with RFMOs
regulation and be RFMO’s membership.
- Legal workers/ stevedores working on discharging at wharfs.
- TTIA, Ship Agents and Tuna Traders have Tri-Parties Job
Description to improve the unloading frozen tuna activity.
- Each ship agent has sighed MOU with TTIA concerning hiring
legal labour, normal working condition and discharge fees.
- TTIA members in collaboration with tuna traders have
monitored ship agents.
- Registered wharf to discharge frozen tuna shipments.
- Only DOF’s approved freezers can be used to keep raw
material for Thai canneries.
- TTIA members have to comply with TTIA’s Ethical Labor
Practice – Code of Conduct on Workers (8 items) based on
Thai labour law.
- Thai and migrant workers must have a correct and clear
identity, fully understand and accept work conditions, wages
and other benefits that stated clearly in the employment
contracts before signing.
- TTIA members have attended GLP Good Labour Practices
trainings for tuna processing facilities organized by ILO,
Department of Fisheries and Department of Labour
Protection and Welfare.
- Most of TTIA members have already complied with the
three NFI Ethical Standards which are Ethical Trading Initiative
Base Code (ETI), Business Social Compliance Initiative Code of
Conduct (BSCI) and Safe Quality Food Ethical Sourcing Code
(SQF).
- Human Resources meeting is regularly held every 2 months.
- TTIA staffs have conducted GLP visit at tuna factories at least
once a year.
- TTIA encourage new members to comply with GLP.
- All related supporting industries must conduct as the same
direction as Thai tuna canneries done on Ethical Standard in
order to ensure the whole tuna supply chain working in the
same way for sustainability of our tuna industry.
-TTIA members always monitor their suppliers by themselves.
Thai Tuna Industry Association
E-mail: [email protected]
Tel: +662 258 0317-8, Fax: +662 258 0319
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2.3 TTIA’s Additional Regulation to Members
In 2016, TTIA established more conditions to members in order to regulate them to comply with
international labor standards and social responsibility. For examples, getting Dolphin Safe approval by
Earth Island Institute (EII) and cooperating in the implementation of Good Labour Practice (GLP). The
regulations for membership application are as follows:
1) Both ordinary member (tuna processing factory) and extraordinary member (supporting
industry business and traders) shall submit the Letter of Intent to become TTIA Membership, by stating
that the company is pleased to fully support the compliance with TTIA policies in 3 aspects; namely, (1)
Food Safety; (2) non IUU Illegal, Unreported and Unregulated Fishing Policy and Sustainability Policy; and
(3) Ethical Labour practice (Ethical Code of Conduct).
2) Both ordinary member and extraordinary member (for trader only) shall pass certification
program on Dolphin Safe by Earth Island Institute (EII).
3) Ordinary member shall pass certification programs both Good Manufacturing Practice (GMP)
and Hazard Analysis and Critical Control Point Critical (HACCP) as certified by Thai government agency or
certified body.
4) Ordinary member and extraordinary member shall cooperate in the implementation of Good
Labor Practices (GLP) and attend GLP Visit activity by TTIA team at least once a year.
5) Extraordinary member (for trader only) shall submit the Letter of Commitment to comply with
the conditions for extraordinary member, by stating that the company shall commit to purchase tuna
products from ordinary member only. They have to show any documents to confirm that the orders said
are purchased from ordinary member truly and give any evidence documents to TTIA officer for
monitoring without delay.
6) Both ordinary member and extraordinary member shall strictly comply with TTIA policies and
resolutions as any that exists and will be released later for the benefit of Thai tuna industry.
2.4 Implementation of TTIA’s Activities in cooperation with its members to combat human trafficking
2.4.1 TTIA’s meetings designed to exchange data and updates, as well as to monitor labour situations
TTIA hosts a meeting involving its members once every 2 months in order to collectively
deliberate on relevant matters; report details related to labour issues, updates on legislations and
regulations, and developments emanating from labour meetings within the public sector, and NGOs; as
well as engage them in campaigns designed to redress labour situations that have bearing on its members.
Additionally, TTIA also runs campaigns to encourage member participation in its activities in order to
promote good labour practices and the establishment of employees' welfare committees on work
premises.
2.4.2 Implementation of TTIA’s GLP Visit Programme
TTIA has been consistently monitoring GLP arrangements, starting off with its first step in 2013
when it worked on such an activity in collaboration with the International Labour Organization, and the
Thai Frozen Foods Association. After the completion of this programme engagement in 2015, TTIA
continues to encourage its members to proceed with GLP arrangements along the line of the ILO-GLP
Principles. Activities implemented during the 2015-2016 period include the following:
GLP Implementation in 2015 and 2016
- TTIA complied data on its members’ GLP Action plans developed during the 2014-2015 period
for the purposes of an analytical exercise, which was then be included and summarized as part of its 2015
Annual Report.
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- Organizing GLP refreshment training courses for TTIA members in order to enable to them
(and TTIA staff members) to revisit GLP affairs, with an emphasis on issues related to the application of
GLPs so as to enhance healthy working relations between employers and employees, as well as to enable
employers and employees to collectively develop a self-assessment format. In this connection, TTIA has
applied the knowledge gained in designing the color coding criteria to be implemented in the GLP Visits
Programme at member companies.
- Providing an eight-day training course in October 2015 to TTIA staff members who shall serve
as GLP facilitators for TTIA members in a bid to achieve preparedness for GLP activities.
Implementation of TTIA’s GLP Visits in 2016
(1) TTIA designed a GLP output monitoring manual for use in connection with its members, based
on the ILO-GLP Good Labour Practices Guidelines for Packaging and Processing Factories in
the Shrimp and Seafood Industry of Thailand: GLP/ Processing Plants to be applied in GLP
Visits on members’ premises (at least once a year per member);
(2) Steps involved in the implementation of GLP Visits are as follows:
- TTIA makes use of the GLP Visit Follow-Up Manual in conjunction with data on the action
plans TTIA has already received from its members, which in turn shall be applied in its followup stage.
- Visits to TTIA members’ factories and production lines.
- Interviewing representatives of employers and employees on managerial matters and
employees’ life cycle, as well as data on labour standards in accordance with GLP principles;
- Requesting additional documents and proof to be used in TTIA’s deliberation
- Preparing summary reports (to be delivered to TTIA members), and TTIA’s annual
comprehensive industry report
Left side: The implementation of TTIA’s GLP Visits was started at the first time on 18 March 2016.
Right side: an ILO officer participated as an observer during TTIA’s GLP Visits at a TTIA member factory.
Table 3 below shows the outputs of the TTIA’s GLP Visit Programme in 2016. TTIA ensures that
there is no forced, slave and child labor as well as human trafficking issue at its members companies.
Table 3 : Outputs of the TTIA’s GLP Visit Programme in 2016
Fast facts
1. Number of TTIA
members participating in
the Programme in 2016
2. Number of members
having managed to
implement arrangements
in line with GLPs
3. Number of members in
the process of redressing
issues in order to be in line
with GLPs
Programme Outputs
23 out of 25 company members
participated in the programme.
21 companies
2 companies
NB
The other 2 members will
participate in the GLP programme
in 2017.
-
Both members have developed
plans to redress all the issues
identified completely by 2017.
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Table 3 : Outputs of the TTIA’s GLP Visit Programme in 2016
Fast facts
4. Issues identified as not
being in line with the
legislations and the GLP
Principles
Programme Outputs
1. Labour laws: Accommodation
and public utilities coasts (water
and electricity charges) were
deducted directly from workers’
salary payments.
2. GLPs: No salary slips were issued
to workers.
NB
TTIA identified such issues on the
3 members’ premises during its
GLP visits. In this regard, TTIA has
been informed that the 3
members have already redressed
all the issues identified.
3. GLPs: No opinion boxes were
provided to receive employees'
welfare committees’ opinions.
1. With respect to legislations on
occupational safety, hygiene and
work environment: It was found
that employees were supposed to
purchase protective equipment to
ensure work safety, using their
own financial means.
The 2 members have developed
plans to redress these issues
completely by 2017.
2. With respect to labour
protection legislations:
No employees' welfare committee
has been put in place.
5. The number of members
having established the
employees' welfare
committees on their work
premises
Of 23 companies, 21 have put in
place their employees' welfare
committees. 18 of these companies
have had foreign migrant workers
on their the employees' welfare
committee as committee members.
The 2 members who have not set
up their employees' welfare
committee have notified TTIA
that they will have completed the
requirement by 2017.
In summary, the implementation of TTIA’s GLP Visits Programme has induced TTIA members to
appreciate and implement practices along the line of GLPs regularly; has enabled them to be informed of
current situations and labour regulations consistently; and has encouraged them to exchange knowledge
on the resolution of labour-related problems and the enhancement of their welfare arrangements. TTIA
members have accordingly developed policies, and have stepped up communications platforms, training,
and public relations efforts in order to ensure that foreign migrant workers are aware of data, as well as
their rights and duties. In addition, TTIA members have also taken steps to enhance healthy relations
between employers and employees through their employees' welfare committees with foreign migrant
workers’ participation.
Operational Plan for TTIA’s GLP Visits:
1. TTIA implements its GLP visits as its annual activities at least once or twice a year (per plant)
in order to monitor and promote the GLP principles in cooperation with its members
consistently; and
2. TTIA will be improving/ adding new labour-related issues to its TTIA’s GLP Visits Manual in
order to ensure that it is always in line with Thai legislations and current situations with
respect to such issues as the employment of foreign migrant workers, data on the
employment of workers with disabilities, the efficiency of the employees' welfare committees
with foreign migrant workers’ participation, and retirement age.
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Part 3 Cooperation with Government and NGOs in Combating Human Trafficking
The TTIA has worked closely with concerned parties such as the government sector, NGOs and
other international organizations to eradicate human trafficking, child and forced labor practices in the
tuna fishing and manufacturing industry. Our commitment in this effort is also three fold and in 2014,
we have made the following progress:
3.1 Working with Government Sector on Human Trafficking Eradication
TTIA has been working closely with the government sector on eradicating human trafficking both
directly as TTIA, via the Thai Chamber of Commerce, the Federation of Thai Industries, and the Thai
Federation of Fishery Producers. The government counterparts comprised of eight ministries
(departments in US terms) – Labour, Agriculture & Cooperatives, Commerce, Public Health, Social
Development and Human Security, Foreign Affairs, Interior and Justice. A number of conferences,
seminars and meetings have been jointly organized with these government agencies. For example, the
meeting of the Committee of Combatting Unacceptable Forms of Work in the Thai Fishing and Seafood
Industry Project, chaired by Permanent Secretary, Ministry of Labour.
Picture: Public-private sectors meetings on labour issues were held at office of Ministry of Labour.
3.2 Implementation of action to redress human trafficking in conjunction with the International
Labour Organization
Since 2015, TTIA has attended in the Committee of Combatting Unacceptable Forms of Work in
the Thai Fishing and Seafood Industry Project or “ Ship to Shore Right” . The project is implemented by
International Labour Organization in cooperation with Ministry of Labour, industry, workers’
organizations and civil society in financial support funded by the European Union. It consists of the
following 2 task forces.
The first task force is in charge of legal affairs and steering policies in particular for the adoption
of the Work in Fishing Convention, 2007 No. 188 and labour rights in accordance with the Forced Labour
Convention, 1930 No. 29.
The second task force is in charge of law enforcement, labour inspection, labour inspector
training, and activities designed to promote cooperation, which further benefit workers and foreign
migrant workers networks. This will also encourage members of the private sector to implement Good
Labour Practices (GLPs) on a voluntary basis.
Pictures: Meetings of task force under the committee of “Ship to Shore Right”
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3.3 Work implemented in collaboration with non-profit organizations
TTIA has been working with NGOs, which plays a pivotal role in encouraging the industry to
develop its labour component in a variety of ways. Examples of such collaborative work include taking on
board complaints, problems identified, or recommendations as inputs for further improvements, or
organizing workshops for the purposes of deliberation in collaboration with such NGOs as MWRN and
PLAN International Thailand. Collaboration implemented in 2016 involves the following arrangements:
3.3.1 BSCI Training Course, funded by KESKO
In 2016 TTIA in cooperation with PLAN International Thailand arranged the training course of BSCI
the Business Social Compliance Initiative during 16-18 November 2016 for TTIA members attended 15
companies. The financial support in the amount of 2 million baht for the 2016-2018 period of the BSCI
training project was funded by KESKO, Finland. The objective is to promote Supply Chain Engagement
among the Thai tuna industry and related suppliers. For 2017 future plan, PLAN and TTIA will organize
BSCI training course for new TTIA members and set up activities to follow up the trained members in order
to evaluate the outputs of the programme.
Picture: a group photo of TTIA members, BSCI consultants, and PLAN and TTIA representatives during BSCI training course
3.3.2 Applying UNGPs to the tuna industry based on BSCI Standard in actual implementation
In September, 2016, PLAN International Thailand submitted a project in conjunction with the Thai
Tuna Industry Association, and the Thai Frozen Foods Association (TFFA) to the European Union in order
to request financial support with the purpose of promoting the application of the UN Guiding Principles
on Business and Human Rights (UNGP) to Thailand’s tuna and seafood processing industry. TTIA applied
for this financial support together with PLAN as a co-applicant in order to apply the UNGP standards
throughout the supply chain with the BSCI standards as the operational mechanism in the programme.
This programme is currently being deliberated upon by the European Union for financial support.
Picture: Consultation meetings on UNGPs project among PLAN, TTIA and TFFA representatives.
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3.3.3 Organizing social dialogue workshops to promote right awareness, legal knowledge and the
efficiency of the Employee’s Welfare Committee
During the 2014-2016 period the Thai Tuna Industry Association (TTIA) in conjunction with the
Thai Food Processors’ Association (TFPA), the Thai Frozen Foods Association (TFFA), and the Migrant
Worker Rights Network (MWRN) collectively organized workshops designed to enhance relations
between employers and employees (the social dialogue component). In this light, the 3rd Workshop on
“the Role of the Employees' Welfare Committee in enhancing employers’ and employees’ relations” was
organized on 24 June, 2016, as pictures below.
3.3.4 Consultations with MWRN in search of ways to enhance the efficiency of employees’ welfare
committees
The Thai Tuna Industry Association (TTIA) organized a meeting in collaboration with the Thai
Frozen Foods Association, the Thai Food Processors’ Association and the Migrant Worker Rights
Network (MWRN) in order to deliberate on ways to enhance the efficiency of Employees' Welfare
Committees with foreign migrant workers’ participation.
3.3.5 Taking on board requests and complaints from non-profit organizations and ethical practices in
the supply chain
The Migrant Worker Rights Network (MWRN) sent a letter dated 28 July 2016 to TTIA to request
that the Association provides assistance to 14 foreign migrant workers who resigned from a chicken farm
in Lopburi Province on account of labour disputes. This chicken farming business supplies raw materials
to certain TTIA-member tuna processing plants. It is to be noted that the members concerned purchase
minimal quantities of materials from the chicken farm in question. The said TTIA members have already
recruited all the 14 workers to work at their tuna processing plants to concretely reaffirm their
commitment to their supply chains based on human right principles. The TTIA member plants concerned
have also provided other forms of assistance as follows:
- Providing financial contributions for accommodation purposes to all the 14 foreign migrant
workers while they each were yet to receive a monthly income, in amount of 15,000 baht.
- Providing financial contributions to rice and water supplies.
3.3.6 Assistance provided for human rights protection and human rights defender protection
TTIA upholds human rights principles in extending assistance with respect to human right
protection and defender protection by providing a financial contribution to the fine imposed by the court
in the lawsuit in which Mr. Andy Hall, advisor to MWRN, was convicted in the defamation lawsuit filed
against him by a canned pineapple manufacturer. In the action brought against him, Mr. Hall was accused
of committing defamation in the form of publicizing and transmitting false information through a
computer system. The court ruled that Mr. Hall was found guilty as such. He was given a three-year
imprisonment, which is to be suspended for two years, and was ordered to pay a 150,000 baht fine.
In this connection, TTIA has provided a total sum of 50,000 baht towards the fine imposed on
account of his role as a human rights defender.
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3.4 Cooperation with the Thai Fishery Producers Coalition
TTIA in conjunction with the Thai Fishery Producers Coalition (TFPC) has provided budgetary
support for the provision of educational activities for the benefit of transnational children and foreign
migrant workers’ children in the fisheries industry as follows:
1. Provided a 60,000 baht monthly budgetary contribution for the employment of Myanmar
instructors, and the acquisition of educational equipment at the “Wat Si Suttharam School or
Wat Kampra School”, – a budgetary item to be operational up to March 2017.
2. Provided a 40,000 baht monthly budgetary contribution to the MWRN Foundation
3. Provided a 20,000 baht monthly budgetary contribution to the LPN Foundation in support of
its operations related to labour issues.
Picture: TTIA in cooperation with TFPC arranged the activity on the World Day against Child Labour in 2016.
Reported by
Thai Tuna Industry Association
Address: 163 Rajapark Bldg., 11th floor, Sukhumvit 21 Rd.(Asoke), Klongtoey, Wattana, Bangkok
10110, Thailand
Telephone: +66 2 258 0317-8 Fax: +66 2 258 0319
E mail: [email protected] , Website: www.thaituna.org
The updated list of TTIA members is available at www.thaituna.org
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