Prevent Forced Labour and Recruitment Fees Under ASC Feed Standard

Preventing forced labour across feed supply chains

The Aquaculture Stewardship Council established mandatory rules prohibiting forced, bonded and compulsory labour under Criterion 1.4 in version 1.2 of the ASC Feed Standard. This affects quality managers, compliance leads, human resources personnel and procurement officers at certified feed manufacturing facilities. Feed manufacturers must ensure that no forced labour or human trafficking occurs within production sites, through recruitment agencies or across raw material supply chains. Conformity Assessment Body auditors inspect recruitment agreements, worker contracts and identity document storage practices during initial and surveillance audits.

Forced labour occurs whenever work is exacted from a person under the menace of any penalty or where employment is accepted through deception or coercion. Penalties include restriction of movement, physical violence, abusive living conditions, financial penalties, wage withholding, or threats of reporting migrant workers to immigration authorities. In addition, forced labour risks escalate during peak production periods when short-term contract workers or day labourers are hired under time pressure. Failing to screen labor contractors or withholding employee travel documents indicates a non-conformity.

Auditors examine personnel files, review recruitment agency licenses and interview employees to verify voluntary employment terms. Where feed mills hire foreign or domestic migrant workers, management must ensure that contractual conditions match pre-departure offers. In addition, feed mills must extend forced labour rules to ingredient manufacturers and primary raw material producers under Principle 2 Due Diligence. Demonstrating ethical recruitment and voluntary employment safeguards fundamental human rights across global aquafeed supply chains.

Screening and monitoring recruitment agencies

Indicator 1.4.4 requires feed manufacturers to screen and monitor all employment and recruitment agencies used to hire personnel:

• Agency licensing verification: Feed mills must verify that recruitment agencies hold valid operating licenses and business registrations issued by competent national authorities.
• Contractual terms and agreements: Management must execute documented agreements detailing terms and conditions under which local or foreign migrant workers are recruited.
• Foreign worker memorandum: Facilities hiring foreign migrant employees must sign a Memorandum of Understanding with recruitment agencies defining explicit hiring conditions.
• Onsite agency monitoring: Feed mills must audit recruitment agency practices periodically to confirm that sub-agents or finder networks do not exploit job seekers.

Zero recruitment fees and document retention rules

Indicator 1.4.5 and Indicator 1.4.7 enforce strict protections regarding worker fees and legal identity dockets:

• Prohibition of recruitment fees: Employees must not be charged recruitment fees, finder fees, or related costs at any stage of the recruitment process.
• Employer cost coverage: Feed mills must cover all processing expenses, including work visas, medical tests before and after travel, orientation programs, and round-trip repatriation transport for migrant workers.
• Voluntary document storage: Employers or recruitment agencies must not take possession of original passports, identity cards, or travel documents required for worker resignation or travel.
• Document access rights: If a feed mill provides voluntary secure storage for worker identity documents, storage must remain optional and items must be freely accessible to employees at all times.

Workplace movement, transport and prison labour prohibitions

Feed manufacturers must maintain open workplace conditions under Indicators 1.4.8 through 1.4.12:

• Free access to sanitation: Workers must enjoy unhindered movement during work shifts to access sanitary facilities and potable drinking water without restrictive token systems.
• Post-shift movement freedom: Employers must not retain workers involuntarily on site outside shift hours, allowing employees residing in company accommodation to leave premises freely.
• Reasonable transportation provision: Facilities located in remote areas without public transit must provide reasonable and safe transportation so workers can reach nearby communities after shifts.
• Complete prison labour ban: Feed mills and recruitment agencies are strictly prohibited from contracting prison labour, including incarcerated individuals or participants in state reintegration programs.

What to do now

• Audit recruitment agency licenses: Review business registrations and operating permits for all third-party labor suppliers and recruitment agencies.
• Review employment contracts and fee records: Examine worker files and interview migrant employees to confirm that zero recruitment fees or visa costs were charged.
• Inspect identity document storage: Verify that employees retain possession of their passports and national identity cards, ensuring any company storage is strictly voluntary and accessible.
• Formalise freedom of movement procedures: Update site rules to guarantee unhindered access to water and toilets during shifts, and verify post-shift transport for remote facilities.

Reference documents

• ASC Feed Standard, V1.2, Criterion 1.4, Indicators 1.4.1, 1.4.2, 1.4.3, 1.4.4, 1.4.5, 1.4.6, 1.4.7, 1.4.8, 1.4.9, 1.4.10, 1.4.11, 1.4.12
• ASC Feed Standard Interpretation Manual, V1.2, Criterion 1.4