Implement Human Rights Remediation Under ASC Feed Standard

Mandatory human rights remediation rules

The Aquaculture Stewardship Council updated human rights remediation rules under Criterion 1.4, Criterion 1.5 and the Remediation Guidance section in version 1.2 of the ASC Feed Standard. This affects quality managers, compliance leads, human resources personnel and grievance committees at certified feed manufacturing facilities. Certified feed mills must ensure that any instance of forced labour, child labour, human trafficking, discrimination or harassment triggers immediate response measures and structured remediation. Conformity Assessment Body auditors inspect remediation procedures, incident records and root cause analysis reports during initial and surveillance audits.

Human rights violations can be discovered through worker grievance mechanisms, internal monitoring, medical checks, external stakeholder reports or third-party audits. Remediation rules apply immediately upon discovering harm or potential human rights abuses within feed mill operations or supply chains. Management remains fully responsible for executing remediation even when grievance committees or external experts manage specific steps. Failing to establish worker-centric remediation procedures or failing to protect affected individuals indicates a dysfunctional management system.

Auditors examine documented remediation protocols, interview personnel and review past incident files to evaluate compliance. Where cases of child labour or forced labour are identified, auditors verify that actions prioritize the best interest of the affected individual. Protecting privacy, providing financial compensation and supporting long-term educational or social rehabilitation demonstrate effective remediation under standard rules.

Immediate response and safeguarding protocols

When human rights abuses are identified on site or in supply chains, feed mills must take immediate safeguarding steps to protect victims:

• Forced labour safeguarding: Facilities must remove the individual from danger, provide safe accommodation, ensure medical treatment and pay an interim stipend equal to the higher of their salary or local minimum wage.
• Legal age child safeguarding: When a child of legal working age is found in hazardous work, management must remove the child immediately, provide health checks and transfer the worker to safe non-hazardous duties at equal pay.
• Underage child safeguarding: Facilities must remove underage children from work, meet their basic needs, locate parents or child protection authorities and provide an interim stipend until a remediation plan is finalized.
• Victim privacy protection: Management must maintain strict confidentiality regarding victim identities during internal investigations, stakeholder consultations and auditor reporting.

Four steps of the remediation process

Feed mills must execute a structured four-step remediation workflow that prioritises the best interest of the person:

• Step 1 Immediate safeguarding: Management secures the safety of the individual, removes them from harm and satisfies basic living and healthcare needs.
• Step 2 Remediation plan development: The feed mill collaborates with the affected individual, family members, local experts, child protection authorities or non-governmental organisations to agree upon a tailored plan.
• Step 3 Implementation and monitoring: Major remediation actions must be completed within ninety days of finding the abuse, while long-term education support for children continues until they reach legal working age.
• Step 4 Corrective action plan: Management conducts a root cause analysis to understand systemic failures and updates operating procedures to prevent future occurrences.

Root cause analysis and preventive measures

Under Indicator 1.4.3 and Indicator 1.5.3, feed mills must perform a root cause analysis following any human rights incident. Management uses the Risk Management Framework in Appendix 7 to evaluate internal and external risk drivers across facility operations. Identifying recruitment flaws, lack of age verification, contractor oversight failures or poverty drivers enables targeted operational corrections.

Preventive measures for child labour include implementing robust age verification systems prior to hiring, verifying birth certificates or national identity cards, supporting local school access and facilitating childcare for workers. For forced labour prevention, feed mills must eliminate recruitment fees, ensure workers retain their passports, establish direct employment contracts and provide literacy or rights training. Aligning corrective action plans with the Appendix 7 framework ensures continuous monitoring and prevents recurring violations across all operational sites.

What to do now

• Formalise human rights remediation procedures: Draft a worker-centric remediation protocol covering immediate safeguarding, interim stipends, expert engagement and ninety-day timelines under Criteria 1.4 and 1.5.
• Upgrade age verification systems: Review recruitment procedures to ensure birth certificates, school leaving certificates or national identity cards are verified before onboarding new workers.
• Audit recruitment agency agreements: Verify that external labor brokers hold valid legal licenses, charge zero recruitment fees to workers and refrain from retaining worker passports or identity dockets.
• Establish expert partner networks: Identify local non-governmental organisations, child protection authorities and labor rights experts to assist with potential remediation plan development.

Reference documents

• ASC Feed Standard, V1.2, Criterion 1.4, Indicators 1.4.1, 1.4.2, 1.4.3, Criterion 1.5, Indicators 1.5.1, 1.5.2, 1.5.3, Appendix 7
• ASC Feed Standard Interpretation Manual, V1.2, Criterion 1.4, Criterion 1.5, Remediation Guidance Section