Charoen Pokphand Foods PCL

CP Foods clearly acknowledges the materiality of Illegal, Unreported, and Unregulated (IUU) fishing, overfishing, habitat conversion, and human rights issues within its supply chains, as well as alignment with traceability, through a variety of public policies. These includes CP Foods’s dedicated “Food Traceability Policy” as well as its “Sustainable Sourcing Policy and Supplier Guiding Principle”, “CP Foods Fishmeal Sourcing Restriction”, “Statement on Slavery and Human Trafficking”, and “Supply Chain ESG Management Approach”. The company also discloses details on its materiality assessment and supplier engagement in its latest Annual and Sustainability Report.

Food Traceability Policy:
CP Foods has published a dedicated traceability policy with the goal of an “explicit guideline for the enhancement of CP Foods’s worldwide operations to achieve world-class food quality, food safety, and sustainable management” in support of its Sustainability vision “Kitchen of the World”. This policy applies to all CP Foods companies and subsidiaries for which CP Foods directly or indirectly holds more than 50% of their shares, and has control over their operations. This "Food Traceability Policy" outlines requirements for “precise and timely digital traceability system” across CP Foods’s operations. The policy covers all marine and terrestrial products, including feed.

Sustainable Sourcing Policy and Supplier Guiding Principle: This policy denotes the company’s expectations for its business partners for environmental protection and human and labour rights. Here, the company clearly outlines traceability as a means of ensuring no reduction in “natural resource abundance”, though no further details are provided. Human rights issues, including forced labour, are also underlined as key risks and business partners are expected to comply with set measures. Additionally, CP Foods requests certification as evidence quality and safety standards are met. Notably, the company requires certifications that products are not sourced from deforested areas.

CP Foods Fishmeal Sourcing Restriction: CP Foods is committed to the promotion of sustainable fisheries and to the protection of marine resources throughout international and Thai maritime waters. This policy states that CP Foods only sources fishmeal from processing plants certified by The Marine Ingredients Organisation IFFO RS certification (now known as MarinTrust) and does not include species at risk from extinction as defined by the World Conservation Union: IUCN Red List of Threatened Species.

CP Foods also outlines that fishing vessels, fishmeal processing plants and processing plants within its supply chain must be certified by Thailand’s Labor Standard or have been audited for social responsibility by an external agency according to international standards.

Statement on Slavery and Human Trafficking: CP Foods outlined that it has “put in place systems to ensure that there is no Illegal, Unreported and Unregulated (IUU) Fishing and forced labour in our operations and supply chain”. In its Thailand operations, CP Foods does not operate the fishmeal plant or own fishing fleets but promotes fishmeal suppliers to source marine ingredients responsibly from sustainable origins which are traceable in accordance with the “CP Foods Fishmeal Sourcing Restriction” Policy.

Furthermore, CP Foods aims to monitor and improve its main raw materials’ traceability on an ongoing basis, recognising the importance in protecting biodiversity and safeguarding communities. The main procurement categories (including traceability) are maize, soybean meal, palm oil, fishmeal, and casava.

CP Foods’s Supply Chain ESG Management Approach and Supplier Engagement: CP Foods discloses a dedicated “Supply Chain ESG Management Approach”, where the company outlines its approach to an annual self-assessment process for suppliers and ESG audits for all critical suppliers and those with a high non-compliance risk score. The company indicates that it has achieved 94% progress on on-site ESG audits of critical tier 1 suppliers (target of 100% by 2025) in its latest report. CP Foods also discloses its target to “ensure 100% of key raw materials are traceable”.

Materiality and risk assessment: CP Foods discloses that it conducts a materiality assessment as a component of “Stakeholder Analysis in Business Value Chain”. The company indicates that its Sustainability Department undertakes its materiality assessment, which is then presented to the Chief Executive Officer to identify approaches, policies, strategies, and goals. These are then escalated to the Corporate Governance and Sustainable Development Committee and then to the Board of Directors for approval of the organisational goals and policies.

Furthermore, CP Foods details its approach to risk management associated with “Biodiversity loss and Sustainability in the Supply Chain” in its 2024 Annual Report. CP Foods discloses that it is assessing impacts and reliance on natural resources then establishing the following action plans:

• Avoiding impacts: Educate and support suppliers in their operations, set procurement standards for raw materials, assess supplier’s environmental, social, and governance risks, implement traceability systems for key raw materials, and avoid operations near sensitive areas.
• Reducing impacts: Minimise food loss and food waste, promote the use of sustainable packaging, optimise raw material utilization, reduce waste through recycling, and lower greenhouse gas emissions.
• Reforming practices: Enhance the potential of maize farmers to improve efficiency and reduce costs.
• Restoring ecosystems: Support projects aimed to conserve, protect, and restore upstream forests and mangroves.

CP Foods also has a Sustainability Strategy, with a vision of becoming the “Kitchen of the World”. This strategy is aligned with the 17 goals of the UN Sustainable Development Goals (SDGs), and the 10 principles of the UN Global Compact (UNGC). Notably, within this strategy (“Sustainovation”) the company aims to integrate “technology, science, and sustainable development to enhance operational efficiency, with the least impact on surrounding communities”. Other notable policies and activities include:

• The company highlights that, in 2024, it continued with its human rights assessment for employees, initiated in 2020. It is currently analysing and summarising feedback from employees, regarding the labour and human rights practices, of our business partners.
• CP Foods’s “Biodiversity and Zero Deforestation Commitment” for maize, soy, palm oil, and cassava by 2025. The company discloses information on digital traceability systems, satellite images, connection of the supplier’ traceability databases and sourcing of certified raw materials as means to achieve these commitments.

Based on CP Foods’s public disclosures the company clearly acknowledges all material risks, and links these with traceability. For fishmeal sourcing specifically, as the company “does not own any fishing vessels”, the company solely relies on certifications to mitigate these risks. There is no disclosure detailing measures for other seafood commodities CP Foods procures.

All sources of information are available in the company assessment PDF.

CP Foods has a group-level commitment to traceability within its Food Traceability Policy, supported by a quantitative target for traceability across its value chain. The company also outlines a qualitative commitment to certifications.

Generic traceability commitment: In its “Foods Traceability Policy” CP Foods commits to establishing a “precise and timely digital traceability system” across its value chain in all business units. Furthermore, the company outlines that this covers “all live animals” and “animal feed”, applies to all countries of operations, and to the animal feed production process, farm operation, food processing, logistics, warehouses and distribution centres.

While CP Foods’s traceability commitment meets this assessment’s leading practice criteria by covering “all value chain” for all business units and locations (therefore implicitly seafood and feed ingredients), it does not specifically mention seafood and marine feed ingredients.

Traceability commitment for key raw materials: Furthermore, CP Foods’s “Supply Chain ESG Management Approach” states its 2030 target to “ensure 100% of key raw materials are traceable” as well as “deforestation-free”. The company clarifies what it considers as key raw materials in its sustainability report, namely: maize, soybean, palm oil, cassava, and fishmeal. These five key raw materials have to be traceable back to the “plantation plot of fishing sources”. However, this commitment only applies to materials procured from Thailand, Vietnam, the Philippines, Cambodia, Malaysia, India and Laos, and to the food business’ key raw materials.

Certifications: Within its Annual Report 2024, CP Foods indicates that “each country and production facility is responsible for obtaining certifications from independent external bodies, ensuring compliance with the Company’s policies, customer requirements, and local regulations”. However, this is not linked with a time-bound or quantified commitment for certifications regionally or by volume of commodity.

The company provides detail to support this in its 2024 Sustainability Report: CP Foods disclosed that it has received certifications for certain shrimp and fish operations:

• For shrimp: Best Aquaculture Practices (BAP): Thailand, Vietnam, and India

• For fish: Aquaculture Stewardship Council: Vietnam

Furthermore, in CP Foods’s Fishmeal Sourcing Restrictions, the company indicates its commitment to acquire fishmeal product that is traceable and sourced from processing plants certified by IFFO Responsible Sourcing (IFFO RS) or IFFO RS Improvers Programme (IFFO RS IP), now known as MarinTrust, and that does not include threatened species (as defined by being on the IUCN Red List).

CP Foods also has a commitment to certifications for terrestrial ingredients within its Biodiversity and Zero Deforestation Commitment. Here, CP Foods commits to “ensure traceability from suppliers to monitor the origin of the products, prevent deforestation and monitor biodiversity requirement through suppliers’ product certifications and standards”. The company aims to achieve zero deforestation by 2025 for corn, soy, palm oil, and cassava. CP Foods indicates that this covers “suppliers referred to the tier 1 suppliers and non-tier 1 suppliers who supply raw agricultural commodities of corn, soy, palm oil, cassava, and fishmeal”.

The company also promotes the use of globally recognised certificates to ensure deforestation-free sourcing in its 2024 Sustainability Report. These include: the “Roundtable on Sustainable Palm Oil (RSPO), US Soy Sustainability Assurance Protocol (SSAP), Round Table on Responsible Soy Association (RTRS), and ABIOVE Soy Moratorium Declaration (for soybeans and soybean meal), and the Forest Stewardship Council (FSC) (for paper packaging)”.

All sources of information are available in the company assessment PDF.

CP Foods’s Food Traceability Policy commitment to “precise and timely digital traceability”:

• Scope: covers all of CP Foods’s operations, including “all live animals” and “animal feed”. However, there is no specific mentions of seafood within this policy.
• Depth: includes traceability back to the “animal farm” and “feed mill". However, it is unclear whether marine feed is traced back to the vessel.
• Breadth: no mention of alignment with the GDST.
• Form: not time-bound, but digital. There is reference to “communication” across the supply chain but not interoperability explicitly.

The company commits to 100% traceability of key raw materials by 2030 in its Supply Chain ESG Management Approach, and as detailed in its Sustainability Report 2024.

• Scope: covers “key raw materials” used in feed business procured by Bangkok Produce Merchandising Plc operations in Thailand, Vietnam, the Philippines, Cambodia, Malaysia, India, and Laos.
• Depth: while disclosure indicates traceability back to “plantation plot” or “fishing area”, it is unclear if this is mandated within its commitment.
• Breadth: no mention of alignment with the GDST.
• Form: time-bound, but not explicitly digital or interoperable.

Other relevant commitments include:

• CP Foods has committed to verification of deforestation-free sources (cut off date 31 December 2030). Verification is confirmed by third-party certifications or traceability to legal plantation areas through satellite imagery.

The company also has a commitment to certified fishmeal within its CP Foods Fishmeal Sourcing Restrictions:

• Form: not time-bound, nor digital or interoperable.
• Scope: covers all fishmeal and the “by-product component of fishmeal” and the “by-catch component of fishmeal”. Importantly, fish oil is not explicitly covered by this policy.
• Depth: sourcing must be traceable and sourcing from processing plants that have been certified (IFFO RS, now known as MarinTrust).
• Breadth: no mention of alignment with the GDST.

While, the company indicates it is certified to ASC standard in its Thailand (shrimp) and Vietnam (shrimp & other aquaculture operations) there is no formal commitment.
CP Foods also works with Seafood Business for Ocean Stewardship (SeaBOS) to "promote and support operations that contribute to the sustainability of marine resources, the preservation of ecological balance, and the environment, which in turn ensures food security". While alignment with the GDST standard is not mentioned, CP Foods is a SeaBOS member which suggests it has a public commitment to adopt the GDST principles.

All sources of information are available in the company assessment PDF.

CP Foods has a time-bound commitment to traceability for parts of its key raw materials and describes measures for implementing this within its Sustainability Report – however, the company does not disclose any clear milestones.

CP Foods discloses its management approach to responsible sourcing in its 2024 Sustainability Report; this included four key measures:

• Established the Sustainable Sourcing Policy and Supplier Guiding Principle which serve as guidelines for suppliers in adhering to the Company’s sustainability policies.
• Implementing Supply Chain ESG Management through assessing risks and improving suppliers’ sustainability efforts, by providing training to improve efficiency and capabilities, while also creating incentives.
• Building Transparency throughout the Supply Chain, utilising technology and innovation as part of the process in sourcing quality raw materials from socially and environmentally responsible sources
• Fostering Collaboration in the Supply Chain to expand responsible sourcing practices among partners and suppliers, including farmers in the supply chain, at both local and national levels. The company also links traceability to its “Food Quality and Safety” management strategy.

Marine products: CP Foods indicates some level of digital traceability measures (blockchain and AXONS trace) in its Thailand for its fresh shrimp products. While the company indicates it has traceability for fishmeal to “Production Unit” (fishing area) and “Sourcing area” (collection point, primary process mill), there is limited information detailing what traceability systems are in place or the data collected.

Beyond this, CP Foods’s approach to marine feed traceability is primarily based on certifications. CP Foods outlined that it prioritises “quality inspections in fishmeal procurement”, and that it “recognizes that fishmeal supply chain may pose sustainability risks in both social and environmental dimensions”. The company has implemented this approach since 2013.

While the company has achieved Best Aquaculture Practices (BAP) and ASC certifications, these are not clearly linked with a traceability implementation plan. The company also indicated it has held workshops which address traceability in some measure, though this is not specific to seafood.

Terrestrial products: In its 2024 Sustainability Report, CP Foods provides details on its implementation of traceability for its terrestrial products (ensuring deforestation-free sourcing). This includes:

• The use of globally recognised certifications
• Prioritising farmers possessing land authorised documents
• Utilising GPS and satellite imaging technology (monitoring stubble burning)
• Connecting with the databases of leading global suppliers, ensuring a reliable traceability system with high integrity.
• Traceability Operations room for monitoring and managing animal feed corn supply chain.

Furthermore, CP Foods highlights its application of blockchain within its traceability system, stating that “blockchain technology covers all steps from plantation and transportation to feed mill”, as well as an app for its farmers to simplify traceability data inputs. Additionally, the company indicates that on-site visits take place to verify data. It is unclear in disclosure if these measures extend to marine ingredients.

Overall, CP Foods’s appears to have more advanced traceability systems for its terrestrial products than for its marine products.

All sources of information are available in the company assessment PDF.

CP Foods states that its “Food Traceability Policy” has been set up for the purposes of establishing a precise and timely digital traceability system across CP Foods value chain, in all business units. In addition, the company has a 2030 traceability target linked with key raw materials, which includes fishmeal.

CP Foods only reports against its 2030 traceability target which covers key raw materials (including fishmeal), but does not report against its commitment included in its Food Traceability Policy.

Target of 100% of key raw materials traceable by 2030:

• Performance in 2024: 43%
• Performance in 2023: 49%
  However, this reporting covers all of the company’s key raw materials, including animal feed corn, soy, palm oil, cassava, and fishmeal, and does not disaggregate between these.

Level of traceability of fishmeal for 2024 (2024 Sustainability report):

• Production unit (fishing area): 43.1%
• Sourcing area (collection point, primary process mill): 56.9%

Level of traceability of fishmeal for 2023 (2023 Sustainability report):

• Fishery sources: 34.4%
• Processing facilities: 65.6% We note a decrease in traceability for processing facilities in 2024 relative to 2023 - however, the reporting language does change which may have contributed.

Certifications: The company indicates fisheries providing fishmeal must be sourced through the MarinTrust certification back to the vessel (or in the Fishmeal Sourcing Restrictions - "certified according to international standards or legally examined by various parties that include officials and representatives of the Department of Fisheries, operators, consumers and academia").
CP Foods also disclosed its current coverage of MarinTrust certification for specific operations, and its total global operations.

• Thailand operations: 100% of fishmeal is by-product from aquaculture processing plants of suppliers, certified under MarinTrust standards.
• Vietnam operations: 41% of fishmeal is by-product from aquaculture processing plants of suppliers, certified under MarinTrust standards.
• Global operations: 43% of fishmeal is certified by MarinTrust

All sources of information are available in the company assessment PDF.

CP Foods indicates third-party audit measures for its traceability system for terrestrial products, and for marine products in certain regions (through certification schemes). There is no evidence of non-compliance reporting linked with traceability.

For terrestrial products, CP Foods seeks to expand the animal feed corn traceability system from Thailand alone to neighbouring countries, such as Myanmar. In Myanmar, the traceability system has been audited by Control Union, a global expert in sustainability standards verification and certification for agriculture and environmental practices.

Regarding marine products, CP Foods indicates in its Fishmeal Sourcing Restrictions policy its commitment to acquire fishmeal product that is traceable and sourced from processing plants certified by IFFO Responsible Sourcing (IFFO RS) or IFFO RS Improvers Programme (IFFO RS IP), now known as MarinTrust. Furthermore, the policy specifies that fishing vessels, fishmeal processing plants and processing plants within the supply chain must be certified by Thailand’s Labor Standard or have been audited for social responsibility by an external agency (third-party) according to international standards.

The company also highlights that it has obtained ASC certification for shrimp in Thailand and India, and fish in Vietnam. Additionally, CP Foods has obtained BAP certification for shrimp in Thailand, Vietnam, and India. Notably, the company does not disclose its certification coverage in these regions.

All sources of information are available in the company assessment PDF.