Grieg Seafood ASA

The company has committed to a science-based target to reduce absolute Scope 1, 2, and 3 GHG emissions by 35% by 2030 and 100% by 2050 from 2018 as the base year. In FY2022, the Scope 3 emissions of the group are reported to be 348 930 tons CO2e, which represents 91.9% of the total group emissions of 379 374 tons CO2e. Therefore, according to the SBTi, the company is required to include Scope 3 emissions in the science-based target.

The company's SBTi covers Scope 3 GHG emissions to be reduced by 35% by 2030 and 100% by 2050 from a 2018 base year. The emissions have been reported for the whole group. Therefore, the geographic scope is considered to be universal. Targets are aligned with a well below the 2-degree pathway.

The company offers its suppliers financial incentives to reduce their downstream and operational emissions. It also asks its three major suppliers to provide annual data on fish feed to calculate the corresponding emissions. It highlights the value of this information when judging the sustainability of possible ingredients. The CDP report covers data from Canada, Norway and the United Kingdom. Therefore, the geographic scope is universal.

The company participates in commercialisation of new marine and protein-based feed ingredients and investigates the opportunities for fish suppliers to use insect meals for growth.

The company is working on the "Green Platform" Initiative, which includes novel production methods such as closed floating farming conditions for post-smolt and floating fish feed. It also discloses testing different energy solutions to fuel many production sites alternatively to diesel generators. Furthermore, it mentions that using semi-closed containment systems contributes to solving biological challenges and reducing carbon emissions.

The company discloses its group-wide emissions from Scope 1, 2 and 3.

The company discloses its Scope 1 and Scope 2 emissions per business division. However, it does not disclose specific animal farming emissions. It discloses its CO2-equivalent emissions from feed production in its CDP climate change report for 2022. It reported emissions for each feed supplier location-wise in 2021. It discloses the global Scope 3 emissions to CDP, including the land use change emissions.

The company responded to the CDP Climate questionnaire in 2022. It discloses to CDP that Scope 1, 2 and 3 emissions data are all audited by a third party, PwC.

The company reports a decrease in its absolute Scope 1, 2 and 3 emissions compared to FY2020, from 439,357 tons CO2 to 379 374 tons CO2 in FY2022. This represents a 13.7% decrease. It discloses to CDP the quantitative decrease in feed emissions. In 2021, the fish feed emissions were 349151 (364131 - 14980) tCO2e, while in 2022, the fish feed emissions were 282456 tCO2e. The absolute reduction from the feed is 66695 (349151 - 282456) tCO2e.

The company discloses that it has completed a climate-related scenario analysis. The assessment tests the company's strategic and financial planning against a 2C and 4C global warming scenario. It discusses physical and transitional risks and the potential impact on its business.

The company discusses its physical risk of extreme weather conditions on feed ingredients' availability and price volatility, providing estimated cost and price increases under the various scenarios it has assessed. It is working on commercialising new feed ingredients. It discusses its chronic risk of increased water temperature, which can cause damage to salmon health. Temperature increase leads to an elevated risk of algae bloom, leading to lower oxygen levels, which can cause higher fish disease and mortality levels. It states that Falconer et al. 2020 used climate models (RCP 4,5) together with industry-specific site temperature measurements to forecast the Norwegian aquaculture industry. It also discloses its current strategy to handle these risks, including introducing large concrete production vessels and overlay-protected work boats to its fleet. The company discloses to CDP that the cost of consumption of fossil fuels, which are used for on-site energy production, will increase based on the increasing consumption tax set by the government. Therefore, it will be a risk for operating costs. It is now testing new technology to reduce fossil fuel demand. It discusses carbon tax as a regulatory risk in its TCFD report, stating that the Norwegian government has introduced a carbon tax following the country's ramped-up climate goal of reducing overall emissions by 50-55% by 2030 (with 1990 as a base year). It discusses the risk it poses to the business due to increased costs and highlights the importance of substituting fossil fuels with renewable energy technologies. It also states that it is electrifying its fleet of boats to mitigate this change. The company discloses the financial impact of material ESG topics. It mentions that farming costs increased in 2022 due to biological events, which include algal blooms and increased sea temperature. Specifically for its Finmark operations, it reports higher seawater temperatures than the region historically experienced. However, it does not specify if those events result from climate risk.

The company does not disclose its commitment to align capital expenditures with its GHG targets.

The company discloses that 13% of its feed ingredients used in Norway and Newfoundland operations are soy protein concentrate, and globally, soy protein concentrate sourced from Brazil represents 10.5% of its feed ingredients. The company reports that the percentage of revenue dependent on soy is 1-5%. Grieg considers soy as a high deforestation risk ingredient. It discloses that in 2022, 100% of its soy was from ProTerra or Round Table on Responsible Soy certified suppliers. In Brazil, it only sources soy from suppliers that have implemented a 100% deforestation and conversion-free soybean value chain, with 2020 as their cut-off date. The company discloses that its Brazilian soy suppliers are CJ Selecta, Caramuru and Imcopa, all of which are considered deforestation-free.

Within its Supplier Code of Conduct, the company highlights the risks of deforestation and the exploitation of limited resources. It mentions providing incentives for suppliers who take action towards zero deforestation. The suppliers who adopt the company's declared cut-off date and take action towards zero deforestation are rewarded. Through this move, the company wants more suppliers and salmon farming companies to use their market power similarly.

The company mentions that 100% of its Brazilian soy protein concentrate was certified according to ProTerra or Round Table on Responsible Soy and also states that it is in close dialogue with its feed suppliers to monitor compliance through geospatial and ground-based monitoring by GPS satellites. It discloses that if non-compliance is detected, it will develop time-bound targets to bring the suppliers back into compliance, provide information on actions, and re-integrate suppliers into the supply chain upon successful and verifiable completion of actions. Furthermore, the company states that if suppliers are non-compliant during an audit, an engagement plan will be introduced to the supplier. If a corrective action plan is not met, it could lead to the suspension of the supplier. The company lists its soy origin by state, covering 100% of the soy sourced.

The company states that in 2021, it initiated a project to undertake an evaluation of ESG risks relating to salmon feed ingredients to increase transparency and traceability, enable benchmarking of feed ingredients on material ESG aspects, and have the ability to reduce risk and drive change throughout its supply chains. The company partnered with WWF US to develop novel feed ingredients. Furthermore, the company states that as a member of the Global Roundtable on Marine Ingredients and the Global Salmon Initiative Climate Taskforce, it commercialises novel feed ingredients.

The company discloses that all sites are certified with either Global GAP or BAP. The Newfoundland greenfield site is not yet delivering to market and is therefore not eligible for certification. Certifications are disclosed at farm level.

The company discloses its feed ingredients by percentage, broken down into categories but not disaggregated by species for marine products. The company states that all sourced soy is certified by Pro-Terra or RTRS, and all sourced marine raw materials were certified according to MarinTrust (including Fisheries Improver programmes) or MSC. In addition, the company discloses its FFDRo and FFDRm for each country it is operationally active in.

The company reports that 35% of fishmeal and 39% of fish oil included in feed was derived from fish trimmings. The company discloses mixed performance across operating regions on metrics of FCR, FFDRo and FFDRm. In Norway, FCR and FFDRo have both decreased, whilst FFDRm has increased. Whereas in British Columbia, FCR and FFDRo have increased and FFDRm has remained consistent. The company also reports metrics from it is Newfoundland site for the first time in 2022.

The company states that it is in dialogue with suppliers regarding the development of novel feed ingredients such as insect meal. The company has targeted a share of novel ingredients of 5% of feed volume by 2030. However, it does not disclose specific actions the company is taking to increase the use of alternative feed ingredients. The company mentions using fish trimmings and dead fish as animal feed, fishmeal, biofuel, or fertilisers but does not disclose a clear strategy for increasing the responsible use of trimmings in fish feed. The company has initiated a project to perform a holistic evaluation of ESG risks relating to salmon feed ingredients to increase transparency and traceability, enabling them to benchmark feed ingredients on material ESG aspects, reduce risk, and drive change throughout our supply chains.

The company has set a target to increase novel ingredients to 5% of feed volume by 2030. However, it does not report any progress towards the target. No information on R&D expenditure has been disclosed.

The company discloses the average sea lice levels per adult fish across all regions from FY2018 to FY2022. The company states that it does not exceed the sea lice limits on average. Finnmark's reported sea lice levels are within the 0.25 Limit of adult female sea lice per fish per site on green licences, which are typically half the limit of regular licenses. However, the disclosed figures include some deviations in the sea lice count for operations in British Colombia in August, where the sea lice level exceeded the limit of 0.3 in an adult female and almost reached 0.6.

The company mentions creating natural 'lice-skirts' barriers, using artificial intelligence tools and using cleaner fish to control sea numbers. The company states that the mortality rate is high in cleaner fish. However, the company is working towards the improvement in the health and welfare of the fish and discloses it is in the process of revising and improving its policies for cleaner fish. This includes working more systematically to report and reduce mortality.

The company mentions that it only had one fish escape event in Finnmark in the reporting period. It also states that British Columbia it uses double nets on all pens to avoid escapes. Similarly, in Rogaland, divers are used during operations and in Finnmark, an ROV is used to inspect the grow nets after each targeted two-week cleaning cycle. The company reports a reduction in escapes from the previous reporting period. The company has a target for zero fish escapes. However, the target is not time-bound.

The company lists its efforts to reduce biodiversity impacts by limiting injury to wildlife. The company runs a programme to measure the number of both farmed and wild salmon in Norwegian rivers. The company also conducts training sessions for its employees on escape prevention. The company aims to minimise the impact on wildlife around its farms, such as birds or marine animals, by using equipment preventing such individuals from entering its pens. It also mentions that it does not use acoustic deterrent devices (ADDs). Additionally, the company reports zero wildlife-related conflicts for the reporting year. However, no time-bound target is set by the company.

The company has a management plan to handle the occurrence of algal blooms. It has introduced improved sensor technology and advanced imaging analysis, enabling the type of algae to be determined early and the appropriate feeding response selected. The company mentions that algae movements and data from oxygen sensors are linked to the oxygenation system at sites with low oxygen levels in the water column. In addition, upwelling systems have been installed to transfer clean, algae-free water from the depths to the top of the pen, creating a protective “bubble” in the pen.

The company mentions in its Sustainable Feed Policy that freshwater use in the production of raw materials or feed ingredients should be sustainable. However, the company does not provide additional information. It does not discuss the guidance, support or incentives offered to suppliers/growers on water use in the company's feed supply.

The company discloses the baseline water stress score of regions where both soy and palm oil destined for feed are sourced. However, the company does not provide this information for other ingredients included within its feed such as rapeseed oil, wheat.

The company mentions that in FY2022, it had zero cases of non-compliance with environmental regulations. None of the company's facilities are located in areas of water scarcity. However, the company does not discuss the use of the WRI aqueduct tool from a quality perspective.

PwC audits the data of the Integrated Annual Report.

The company mentions that fish trimmings from harvesting and dead fish from farms are used for animal feed, biofuel, and fertilisers, depending on the quality.

The company mentions in its sustainable feed policy that the production of raw materials or feed ingredients should not cause significant pollution to communities or ecosystems. However, the company does not mention specifically nutrient pollution or fertiliser use. The company has partnered with WWF US to evaluate ESG risks in salmon feed ingredients, including pollution and soil health. The goal of the project is to be able to benchmark feed ingredients on material ESG issues to reduce material risks.

The company discloses that its materiality assessment determined that pesticide use was not a material risk to the company. Pesticide use was only found to have a moderate risk, as pesticide use in crop production is regulated. It should be noted that this assessment only covered tier 2 suppliers.

The company mentions it has performed environmental impact assessments in 100% of its sites to identify high-risk locations and discloses details of their organic loading methodologies by region. It reports that in 2022, 92% of its sites in Rogaland (down from 100% in 2021), Norway, and 95% of its sites in Finnmark (up from 53% in 2021), Norway, received a very-good or good score in theMOM-B tests undertaken to assess the impact of farming on the seabed. The company discloses the use of farm following to allow seabed recovery. Details are provided about the region-specific following strategies, which can be considered company-wide. Additionally, the company discloses some information about using geospatial modelling to determine optimum farm locations.

The company has been awarded ASC certifications in 29/40 eligible facilities. Subsequently, it must adhere, in certified locations, to principle 7 of the ASC Standard, which requires bi-annual meetings with communities surrounding aquaculture farms. However, the company does not publicly disclose details of this policy and related policies on regular community engagement. We encourage the company to publicly disclose the same information provided to ASC to secure their certifications.

The company has a standalone antibiotics policy, applying to all operations and covering all antibiotic types. It commits to using antibiotics only as a last resort to protect fish health and employs strategies such as vaccination programmes and adapted diets to minimise antibiotic reliance.

The company discloses antibiotic usage per tonne of fish and notes specific quantities of Profenicol and Florfenicol used in the reporting year. It also provides regional breakdowns and cites a decrease in antibiotic use from 46.67g per tonne LWE in FY2021 to 41.4g in FY2022. Audits are conducted by PricewaterhouseCoopers AS. However, despite not using antibiotics in Rogaland for several years, the company resorted to using Profenicol and Florfenicol in two regions in 2022.

The company discusses taking a systematic and long-term approach to fish welfare and has an extensive publicly available welfare policy. It states that it is committed to improving the health and welfare of fish, including cleaner fish. The company's fish welfare policy states that it expects careful handling of live fish during treatments, grading, and transport. In addition, the company discloses that all live fish are anaesthetised by pharmaceutical agents or electrical stunning before killing.

The company does not assure a stocking density of lower than 17kg/m3 for salmon at all times, instead disclosing that stocking densities are kept within the range of 15-25kg/m3. The company does state that it has a fish welfare monitoring system that monitors fish density, mortality, appetite, presence of moribund fish, sea lice levels and water quality each day at every facility by the staff or via digital tools. However, the system is still under testing and development. We encourage the company to disclose performance against these metrics in greater detail.

The company discloses its efforts to improve fish health and welfare. The company is implementing welfare indicators from the Fishwell project, an industry collaboration on welfare. It also improves the welfare of cleaner fish by installing artificial kelp forests in pens to avoid stress, rest and sleep. However, the company does not disclose the amount spent towards such research.

The company discloses survival rates at sea and freshwater across all three regions, i.e. Rogaland, Finmark and British Columbia. In 2022, the company also disclosed survival rates for Newfoundland for the first time. The company discloses incident-based mortality broken down by its operations. It reports the incidents by infectious diseases (bacterial, virus, gill infections) and non-infectious diseases with respective values by the number of fish. The company discloses a target to reduce the mortality rate in sea-based and freshwater operations and that none of the regions reached their target because of biological issues. The company includes mortality performance figures for each region.

The company discloses the weight (tonnes) and the number of fish that died from infectious and non-infectious diseases in its operating regions for the past three years. The company states it selects roe with improved resistance to sea lice and diseases, customises feed for the various stages of the salmon’s life cycle and environmental conditions and issues vaccinations targeting specific diseases. Additionally, it plans to invest 70 million in UV treatment in 2023 to secure the water intake to its freshwater facility.

The company commits in writing to respect all internationally recognised human rights articulated by the Universal Declaration of Human Rights and ILO Conventions.

The company began its human rights risk assessment per the Norwegian Transparency Act in 2022. It identified the significant risk of child labour in sub-suppliers in the feed supply chain. Additionally, it found that some areas in its supply chain entail an exceptionally high risk of breaching human rights through forced or compulsory labour. In response, the company, with WWF and the Global Salmon Initiative, is developing an extensive environmental, social and governance assessment of feed ingredients, which also covers human rights. In addition, the company recently completed an in-depth human rights due diligence for its supply chains and operations. The company's methodology involves identifying and assessing impacts and tracking the results of mitigating actions. Mitigation techniques include integrating due diligence findings across internal functions, taking appropriate action and creating action plans with suppliers deemed closest to breaching human rights. It has also conducted human rights training for 253 (31%) employees in 2022.

The company has prioritised three areas for action based on risks found through the human rights due diligence process. It has identified risks relating to working hours, rest times, living wages, and contractual agreements in its European transportation system. The country has also identified risks in its feed supply chain, which relate to the increased risk of child labour in India and the increased risk of modern slavery, poor working conditions and child labour in South America, Asia and Africa. However, the company does not disclose details of remediating actions taken in response to these risks.

The company commits in writing to prohibit child labour, forced labour, discrimination and harassment and requires suppliers to do the same. The company also offers sick pay leave to all its employees regardless of whether they are permanent or temporary. The company states that third-party certifications include audit policies and standards on human rights. However, this does not cover compliance monitoring of discrimination and harassment policies.

The company conducts third-party human rights audits of its largest European transportation suppliers. However, it needs to be clarified how many suppliers this includes. Furthermore, it is unclear if these audits cover all the selected policy areas relating to discrimination, abuse, child labour and forced labour. The company states that it has a grievance channel operated by a third party (EY). It is available to all employees to report any unwanted behaviour and breaches of the company's Code of Conduct. The company discloses that notifications can be anonymous. In addition, the company has a whistleblowing channel open to external parties where whistleblowers can make anonymous reports. The company reports that zero cases were reported through whistleblowing hotlines in FY2022.

The company has an occupational health and safety management system and a zero-accident policy for all workers. As of 2022, The company states that all its H&S procedures are internally and externally audited through certifications they hold with Global GAP, ASC and BAP. The company also mentions having a health and safety committee in some regions but does not disclose the number or percentage with worker representatives.

The company discloses its lost time injury rate (LTIR) per million hours worked in 2022 as 13, demonstrating an improvement in the group LTIR compared to 2021, which was 16. Also, the company had zero fatalities both in 2021 and 2022. The company reports a turnover rate of 23% for 2022, but this is not disaggregated by seniority level.

The company commits in writing to uphold its employees' rights to freedom of association and collective bargaining and discloses the unionisation rate as 34% and 43% for Rogaland and Finnmark, respectively. The company also requires suppliers to respect their employees' rights to freedom of association and collective bargaining. However, the company does not disclose actions to support freedom of association and collective bargaining beyond policy commitments.

The company discloses the percentage of unionised employees per region. This varies from 0% for its Newfoundland operations, ASA and Sales & Market operations to 34% in Rogaland and 43% in Finnmark. Employees belonging to a union are assumed to be represented by collective bargaining agreements. The company also provides a breakdown of its workforce across existing contractual agreements (permanent, temporary and contractor) across all operating locations.

The company mentions that its farming operations in Norwegian regions, Rogaland and Finnmark, and British Columbia are certified according to GlobalGAP or BAP. Further, its internal processing plants in Norway are certified according to FSSC 22000. These standards are GFSI-recognised. Additionally, external processing partners in British Columbia hold BAP certification for their operations, and future external partners in the Netherlands and Norway either have equivalent certificates or are on a path to GFSI-recognised certification. 100% of farms in BC are BAP-certified. Further, 100% of farms and 100% of processing plants in Norway are GlobalGAP- and FSSC22000-certified, respectively. It prefers suppliers certified according to a GSFI certification and that most relevant suppliers are accredited accordingly. However, the company reports that the BAP and GlobalGAP certifications cover the entire supply chain; hence, total points are awarded.

In the context of product safety, the company reports that its standard audit program includes yearly internal audits and external audits covering the scope of the various standards it is certified for, including each site and processing plant. Further, it mentions that its quality network continuously reviews hygiene-related challenges at its harvesting plants and detects levels of environmental contaminants and relevant foodborne bacteria. Zero severe food incidents safety non-conformities concerning requirements of regulations or voluntary codes were reported in 2022. Further, it discloses having full traceability from origin to the finished product. In addition, each salmon has a CV with information about its origin and production, and each box has a traceable LOT number. The traceability system can provide traceability to the end customers.

The company has a product recall system if a risk to consumer health or safety is detected. The protocol is publicly available online, including disposal procedure, roles and responsibilities. Zero product recalls were disclosed in the reporting period.

The company discloses that it had zero market bans in the reporting period.

The company's board of directors discuss risks and strategy relating to sustainable development and monitors ESG policy compliance as part of an annual plan for its operations. In addition, the company has a materiality assessment process, which is reviewed annually, with the last revision being in 2022. The company discloses the outcomes of the assessment, which are categorised by the pillars of profit and innovation, healthy ocean, sustainable food, people and local communities. The board reviews the list of material topics generated by the materiality assessment. The company disclose board-level expertise in sustainability and innovation but not food safety.

The company states that the corporate executive team is provided with a monetary reward if it meets targets relating to reducing emissions through reducing fish deaths per fish produced and sold. However, the company does not disclose compensation details linked with the target. It is also working with WWF US to develop a new assessment to improve disclosure concerning ESG risks in the salmon feed sector. Furthermore, the company belongs to industry associations, which engage with policymakers in all the countries it operates in on the issues of climate, pollution, circularity, biodiversity, antibiotics, fish welfare, human rights and Indigenous rights. The company also discloses details of trade associations and coalition memberships. The company states that its strategy does not include a plan to align with limiting global temperature rises to 1.5°C but justifies this by saying they have a business strategy plan that aligns with a well below two °C scenario.

The company is focused on sustainable innovation through improving fish welfare, environmental documentation, nutrition and feeding, and production methods, such as providing digital decision-making to support its farmers. Furthermore, one of the board members is actively working on developing new business opportunities related to the energy transition. The company also discloses using technology to create innovative farming processes, such as a post-smolt strategy for salmon, which improves animal welfare, reduces disease prevalence, and digitalises the farming process through tools including artificial intelligence and data analytics. Whilst the company does not explicitly mention that it benchmarks itself against its peers, it does engage with several indexes, such as the Coller FAIRR Protein Producer Index, Sustainalytics ESG Risk Rating, and MSCI ESG ratings. Active engagement with these indexes indicates that the company does consider its standing within the industry about ESG issues.

The company has acknowledged developments in alternative proteins, stating that - in line with the TCFD report - climate change and a growing awareness of the meat industry's substantial carbon footprint are boosting efforts to develop alternative proteins (plant-or lab-based). It recognises that if the alternative proteins can be produced at a competitive cost and quality, it could affect demand for farmed fish. However, it has not yet set a timebound target to diversify protein sources.

The company does not indicate an approach towards diversifying its product range to include plant-based and alternative proteins.