Establish Worker Grievance Mechanisms Under ASC Feed Standard

Mandatory worker grievance rules under ASC Feed Standard

The Aquaculture Stewardship Council established updated worker and stakeholder grievance mechanism rules under Criterion 1.3 in version 1.2 of the ASC Feed Standard. This affects quality managers, compliance leads, human resources teams and facility managers at certified feed manufacturing units. Certified feed mills must implement a transparent, accessible and predictable procedure to receive, process and resolve complaints from employees and external stakeholders. Conformity Assessment Body auditors inspect grievance logs, worker communication channels and resolution records during initial and annual surveillance audits.

Grievances allow employees, local communities, contractors and supply chain partners to raise concerns regarding working conditions, discrimination, safety hazards or environmental impacts without fear of reprisal. A functioning grievance procedure provides early warning of operational risks and social non-conformities before systemic failures occur. The scope of Criterion 1.3 applies across all operational departments, contractor workforces and employer-provided worker accommodation under Criterion 1.14. Failing to maintain anonymous submission channels or failing to record complaint investigations indicates a non-conformity.

Auditors examine physical suggestion boxes, digital reporting portals and meeting records to verify mechanism accessibility across all shifts and worker demographics. Where certified feed mills employ migrant workers, grievance instructions and submission channels must be available in their native languages. Management must ensure that grievance handling aligns with the Risk Management Framework in Appendix 7 to address underlying operational failures. Demonstrating transparent grievance resolution protects human rights and supports continuous organizational improvement.

Key principles of effective grievance procedures

Feed manufacturers must structure their grievance mechanism to fulfill six core effectiveness criteria defined under Indicator 1.3.2 and international UN Guiding Principles:

• Accessibility: The mechanism must be known to all personnel, contractors and local stakeholders, offering clear submission pathways regardless of literacy level or language.
• Transparency: Management must keep aggrieved parties informed about investigation progress, handling timelines and final outcome decisions without compromising victim safety.
• Predictability: Operating procedures must define clear handling stages, investigation responsibilities, decision-making authorities and timeframes for each phase.
• Equity: Aggrieved parties must enjoy fair access to information, advice and expertise necessary to engage in the grievance process on equal terms.
• Rights compatibility: Grievance outcomes and remedies must accord with internationally recognized human rights and applicable national labor legislation.
• Engagement and dialogue: Mechanism design and periodic reviews must involve active consultation with workers, trade unions or elected worker representatives.

Anonymous submissions and protection against retaliation

Under Indicator 1.3.4, feed mills must provide functional channels that allow employees and external stakeholders to submit anonymous grievances. Anonymous submission options, such as secure physical collection boxes, unmonitored telephone hotlines or encrypted web portals, encourage workers to report sensitive issues like sexual harassment, bribery or supervisor abuse without fear of personal exposure. Management must ensure that anonymous complaints receive equal investigation rigour compared to named submissions.

Indicator 1.3.5 strictly prohibits any form of retaliation, intimidation, discrimination, harassment or disciplinary action against any person who submits a grievance or assists in an investigation. Management must establish clear policy statements guaranteeing that reporting operational or social issues will not negatively affect employment status, promotion opportunities or wage levels. In addition, grievance handlers must maintain strict confidentiality regarding complainant identities throughout internal reviews, expert consultations and auditor inspections.

Timely investigation and record management

Under Indicator 1.3.6 and Indicator 1.3.7, feed manufacturers must maintain detailed records of every grievance submitted to the facility. Grievance records must document the initial complaint details, date of receipt, assigned investigator, investigation findings, agreed corrective actions, implementation timelines and final resolution status. Management must ensure that all grievances are acknowledged promptly upon receipt and investigated in a timely manner without unnecessary administrative delays.

When an investigation confirms operational or social non-conformity, management must implement effective remedies that restore rights or compensate affected parties. In addition, feed mills must analyze recurring grievances as part of annual management reviews under Criterion 1.2 to identify systemic operational weaknesses. Corrective actions resulting from grievance investigations must be integrated into the site Risk Management Framework under Appendix 7 to prevent recurring complaints.

What to do now

• Audit grievance submission channels: Inspect physical suggestion boxes, telephone hotlines and digital portals across all factory departments and worker dormitories to confirm operational functionality.
• Translate grievance instructions: Ensure written grievance procedures, submission forms and policy notices are published in languages understood by all local and migrant workers.
• Review grievance register logs: Examine the site grievance register to confirm that received complaints include investigation records, corrective actions, victim remedies and timely closure dates.
• Formalise non-retaliation policies: Issue an official policy statement signed by top management prohibiting retaliation against any worker who raises concerns or participates in grievance investigations.

Reference documents

• ASC Feed Standard, V1.2, Criterion 1.3, Indicators 1.3.1, 1.3.2, 1.3.3, 1.3.4, 1.3.5, 1.3.6, 1.3.7, Criterion 1.2, Criterion 1.14, Appendix 7
• ASC Feed Standard Interpretation Manual, V1.2, Criterion 1.3