Meeting Social Competency and Training Requirements for Due Diligence Assessors under ASC Feed Appendix 10

Understanding the Scope of Assessor Competency Rules

Under Indicator 2.2.12 and Appendix 10 of the ASC Feed Standard V1.2, feed manufacturers must ensure that any individual, team, or external consultancy evaluating ingredient supply chain risks possesses verified qualifications and competencies. These requirements apply whenever a feed mill utilizes Pathway 2 (Sub-national, Sectoral, or Fishery Assessments) or Pathway 3 (Ingredient Manufacturer Assessments).

By contrast, checking pre-determined risk scores under Pathway 1 (Country Score Cards) or verifying approved third-party certifications under Pathway 4 (Accepted Schemes) does not require specialized Due Diligence assessor qualifications. Furthermore, individuals relying solely on published desktop reports without collecting primary data are exempt from Appendix 10 competency tables.

Baseline Qualifications for All Due Diligence Assessors

Prior to evaluating specific risk categories, every individual involved in conducting Pathway 2 or Pathway 3 assessments must fulfill baseline qualification criteria outlined in Appendix 10, Table 8:

1. Academic Background: A minimum of a post-high school diploma or equivalent qualification involving at least two years of study.

2. Relevant Work Experience: At least three years of professional experience in a sector relevant to the ingredient under review, such as industrial processing, agriculture, aquaculture, fisheries, or forestry. Assessors must also demonstrate prior experience conducting supply chain risk assessments or due diligence in a comparable industry.

3. Mandatory ASC Training: Successful completion of the official ASC Feed Standard training module provided by ASC prior to carrying out any Due Diligence assessments.

Specific Qualifications for Evaluating Social Risks

Evaluating social risk factors—such as labor rights violations, forced labor, child labor, discrimination, and worker grievance mechanisms—requires specialized expertise beyond baseline technical skills. Under Appendix 10, Table 10, individuals assessing social risks must meet three mandatory pillars:

1. Education in Social Impacts: A university or postgraduate degree in Social Science or another academic discipline directly related to social impacts and human rights.

2. Work Experience in Social Risk Assessment: Direct experience conducting social due diligence, labor rights audits, or social impact assessments. When assessing social risks in marine ingredient supply chains, the individual must specifically demonstrate prior experience working on social issues in fisheries or fishing communities.

3. Social Training and Legal Knowledge:

• Demonstrated knowledge of local labor legislation and human rights laws applicable to the country or sector being assessed.
• Proven technical competency in identifying indicators of forced labor, debt bondage, and child labor.
• For fishery social assessments specifically, documented attendance at a recognized training program on fisheries social risk assessment or participation in a structured fisheries social initiative.

Collective Team Competency and Management Oversight

The ASC Feed Standard recognizes that individual professionals may not possess every technical, environmental, and social qualification simultaneously. Therefore, Appendix 10 permits competency requirements to be met collectively by an assessment team or through a combination of internal staff and external expert consultants.

Top management holds formal responsibility for governance under Indicator 1.2.4 and Appendix 10:

1. Competency Evaluation and Approval: The designated management representative must review, evaluate, and formally approve qualification credentials for all internal personnel and external consultants before assessments begin.

2. Record Retention: The feed mill must maintain a centralized register of verified competency evidence, including diplomas, CVs, training certificates, and audit logs, categorized by risk scope (legal, social, or environmental).

3. Assessment Report Review: Designated management must review completed Due Diligence reports to verify that methodology aligned with standard risk management frameworks and that all findings are backed by credible evidence.

4. Third-Party Supplier Assessments: If a feed mill accepts Due Diligence reports prepared by an ingredient manufacturer for its own primary raw material suppliers, the mill management must review the report to confirm that the assessment was conducted by qualified personnel meeting Appendix 10 standards.

Best Practices for Managing Assessor Compliance

1. Map Internal Team Competency Gaps: Review the qualifications of procurement and sustainability staff against Tables 8, 9, and 10 to identify whether external social or fishery consultants are required.

2. Complete the Mandatory ASC Module: Ensure all personnel involved in ingredient approval complete the official ASC Feed Standard training module as soon as it is available.

3. Audit External Consultant Credentials: Before hiring third-party risk assessment agencies, obtain documented proof of their social auditing qualifications, degree certificates, and fisheries social training records.

Reference Documents

• ASC Feed Standard V1.2 (Criterion 1.2, Criterion 2.2, Indicator 2.2.12, Appendix 3, Appendix 10)
• ASC Feed Standard Interpretation Manual V1.2 (Criterion 1.2, Criterion 2.2 Guidance, Appendix 10)
• UN Guiding Principles on Business and Human Rights
• OECD Due Diligence Guidance for Responsible Business Conduct