Lerøy Seafood Group ASA

The company commits to reducing absolute Scope 1, 2 and 3 GHG emissions by 46% in 2030 from a 2019 base year. The targets covering greenhouse gas emissions from company operations (Scopes 1 and 2) are consistent with reductions required to keep warming to 1.5°C. It has a target completion rate of 200% as of the current reporting period. The company has disclosed to the CDP that the SBTi has approved its target. The Scope 3 emissions are reported to be 1,038,392.00 tons of CO2e, constituting approximately 85.3% of the total emissions (1,217,274.20 tons of CO2e). Therefore, it is required to include Scope 3 emissions in its science-based target.

The SBTi has approved the company's commitment to reduce absolute Scope 1, 2, and 3 GHG emissions by 46% by 2030, using 2019 as the base year. This aligns with the reduction necessary to limit global warming to 1.5°C. It has set a net-zero target to reduce emissions by 2050. However, whether this target is intended to be validated by the SBTi has not been mentioned.

The company indicates its intention to actively work with suppliers to enhance fish feed's life cycle analyses, improve its composition, and make more climate-friendly decisions. It also plans to collaborate actively with its fish feed suppliers and transportation providers to reduce GHG emissions and achieve cost savings. Additionally, it actively communicates with authorities, stating that its participation in policymaking will mitigate climate-related risks and keep the company ahead of potential regulatory changes.

The company is researching and testing alternative feeds, such as insect proteins, the use of microalgae, and blue mussels. It also discloses promoting regenerative agriculture. However, it is unclear what definition of this the company uses and which practices are being implemented.

The company discloses investing in Marine Gas Oil (MGO) alternatives and broadly implementing measures to reduce transportation emissions.

The company discloses that during 2022, its Scope 1 emissions amounted to 169,913 tCO2e, Scope 2 location-based emissions were 8,970 tCO2e, Scope 2 market-based emissions totalled 44,843 tCO2e and Scope 3 emissions reached 1,038,392 tCO2e.

The company discloses that farming activities resulted in Scope 1 emissions of 54,092 tCO2e and Scope 2 emissions of 3,855 tCO2e in 2022. It reports that its consumption data is based on volumes purchased throughout the year. Therefore, information about the carbon intensity of fish feed is collected from relevant suppliers. In FY2022, the total emissions from the Scope 3 'Purchased Goods and Services' category amounted to 527,804.8 tCO2e. It does not provide a bifurcation of GHG emissions that includes land-use change. It discloses that it does not own or manage land for agricultural activities.

The company responded to the latest CDP Climate Change questionnaire in 2022. It states that the third-party firm, PwC, audits its GHG inventory data.

The company discloses a 6.9% decrease in emissions, from 1,308,278 tCO2e in FY2021 to 1,217,275 tCO2e in FY2022. Compared to FY2020, there is a 14.42% decrease in absolute emissions, from 1,422,389 tCO2e to 1,217,275 tCO2e in 2022. It discloses that the Scope 3 emissions in 2022 have decreased by 10.26% due to a significant decrease in emissions from fish feed.

The company states that it completed an assessment of various climate-related scenarios according to TCFD recommendations to identify and evaluate the Group's exposure to climate risk. The results of this analysis are detailed on the company's website.

The company discusses the potential impact of extreme weather conditions, such as droughts and floods, on the availability and cost of feed raw materials (including soy, wheat, rapeseed oil, and corn). It mentions conducting risk assessments for all ingredients used in its spread to mitigate this risk. To address this risk, it discloses that it is undertaking R&D efforts and establishing strategic partnerships to develop new alternative feed ingredients. It discusses the impact of temperature increases and variability on fish productivity and mortality. It discloses that extreme weather events can lead to changes in water quality, resulting in diseases, parasites, and algae that can kill fish overnight. It identifies any events impacting ocean biology, especially algal blooms, as a significant risk to its revenue. The company mentions that increased risks for diseases or pathogens and lice infections, lower oxygen content in the waters and HAB potentially threaten the production due to climate change, will pose costs associated with climate change adaptation, such as medicine costs for de-licencing fish or a potential northward move of facilities. It mentioned the impact of increased energy costs in the Annual Report, including fuel costs on healthy boats. However, it does not mention the mitigation plan to address this challenge. It states that carbon pricing and taxes would have a significant financial impact, mainly due to transporting products to overseas markets via air freight. It also relies on MGO and diesel in its operations, making it vulnerable to potential taxation on fossil fuels. To address this, the company aims to actively collaborate with transportation providers to be at the forefront of low-emission goods transportation. It seeks to enhance its reputation, lower emissions, and reduce costs by avoiding carbon or fuel taxes. Furthermore, it mentions in its CDP Climate disclosure that it is regulated by Norway's carbon tax regulations, with 86.36% of its Scope 1 emissions subject to carbon tax. It reports that it has not incurred significant costs due to climate risk in 2022.

The company has established a Green Finance Framework that encompasses the issuance of green bonds and loans, aligning its financing activities with its GHG targets. The framework aims to allocate proceeds towards financing investments and expenditures that facilitate the transition to sustainable, low-carbon, and climate-resilient development. However, whether there is a specific commitment to align capital expenditure with the company's GHG targets remains unclear.

The company discloses that it requires raw materials to be ProTerra/Eurosoy certified and sourced from deforestation-free value chains. It also states that it exclusively uses certified soy protein. The company acknowledges its dependence on soy, wheat, rapeseed oil, and corn as feed ingredients. It reports that soy protein concentrate constitutes 20-30% of the total input in aquaculture feed. Lerøy discloses that 100% of the sourced soy is Pro Terra certified, traceable, and comes from deforestation-free soy protein concentrate from Brazil with traceability. In a press release, the company states that three companies – Caramuru, CJ Selecta, and Cervejaria Petropolis-Imcopa – deliver 100% deforestation-free feed to the Norwegian salmon industry. However, it is worth noting that the company also sources feed from Cargill, which is not a deforestation-free supplier. Lerøy completed a full risk assessment related to all macro feed ingredients, including soy, in collaboration with the independent research institution SINTEF. However, the company does not disclose high-risk locations.

The company had set a target in 2018 to achieve zero deforestation or a 100% deforestation-free value chain for soy by 2020, which has been successfully achieved by the company.

The company states that all soy used in the company's feed, regardless of region, is certified by ProTerra or a similar certification that it sources from a 100% deforestation-free value chain.

The company verifies all ProTerra certified soy through a third party, DNV. It also responded to the CDP Forests questionnaire in 2022.

Lerøy states that sustainability is a crucial aspect of its procurement processes. The company seeks suppliers who can create the greatest value while minimising environmental impact. Lerøy emphasises that all delivered soy has been deforestation-free for many years, and it expects all suppliers to maintain the same standard. If a feed producer purchases uncertified soy, the supplier must demonstrate that it meets the same criteria as soy certified by a sustainability standard. Lerøy actively participates in 'the Aquaculture Dialogue on Sustainable Soy Sourcing in Brazil' and has played a significant role in ensuring that its three suppliers of soy protein concentrate are 100% free of deforestation and land alteration activities (DCF) since August 2020. These three suppliers have also committed to implementing a monitoring, reporting, and verification system (MRV) to ensure full traceability throughout the value chain. The company explicitly notified feed suppliers that continue to sell soy sourced from deforested areas, expressing its expectation for them to change their operations in Brazil. The company emphasises that maintaining a 'business as usual' approach is unacceptable.

The company states that if soy is used in the feed, it must come from producers who ensure full traceability throughout the value chain and have specified a cut-off date for deforestation in Brazil. All soy sourced from Brazil must have ProTerra certification. The company maintains close dialogue and follow-up with suppliers, conducts third-party audits, and utilises a traceability system to ensure compliance. Lerøy discloses that it exclusively purchases ProTerra-certified soy, which has its processes and actions in cases of non-compliance. The company further states that in 2021, 24 suppliers were blocked due to their failure to meet the required criteria. Lerøy has mapped its soy supply chain to Tier 4+ suppliers, covering 100% of its supply chain.

The company discloses its determination to reduce its use of soy over time significantly and is involved in multiple projects focused on developing alternative feed ingredients. It has already implemented new raw materials in its feed, such as insect meal and microalgae. Additionally, the company conducts research and development (R&D) focused on exploring new raw materials for feed, including blue mussels. The company also highlights the progress of innovative feed in its ESG report.

The company discloses that 100% of its locations are certified by GLOBAL G.A.P or ASC. Certifications are disclosed at lcoation level.

The company discloses the feed ingredients by percentage, categorizing them as vegetable and marine ingredients, and provides the percentages of different species within each category. The company reports that 100% of the soy used in its fish feed is ProTerra certified, and that 92.5% of the marine raw material used is certified by MSC. The company discloses its forage fish dependency ratio for both fishmeal and fish oil over the past three reporting periods, calculated using the ASC formula. However, the company does not disclose this data by operating region.

The FFDRm figures showed an increase from 0.37 in 2019 to 0.39 in 2020, further increasing to 0.45 in 2021, and reaching a higher level of 0.53 in 2022. The FFDRo figures showed a decrease from 2.09 in 2019 to 1.70 in 2020, further declining to 1.65 in 2021, and reaching a lower level of 1.60 in 2022. The company discloses the absolute volumes of FMFO (Fishmeal and Fish Oil) sourced, providing a breakdown of whole fish and by-products. Forage fish make up 67% of the marine raw materials, while trimmings constitute 33% of the marine raw materials.

The company has an ongoing programme for developing novel fish feed ingredients. In a joint venture with the NGO Bellona, Leroy shares ownership of Ocean Forest A.S., an R&D company that is currently at the forefront of efforts to reduce nutrient pollution and produce innovative feed ingredients. The company is investigating species such as blue mussels and their potential as a marine raw material in feed. It also emphasises close communication with its feed providers to drive feed development. However, it does not disclose any form of risk assessment covering feed availability. The company has already established a minimum ratio of cuttings in feed, ensuring that it exceeds 5% of the marine raw material. However, while the company has provided high-level information on practices to reduce wastage from its wild catch segment, it has not disclosed a full strategy to responsibly increase trimming useage.

The company discloses that it has invested a significant amount in the development of new raw materials for fish feed. An estimate based on 2022 averages indicates that Lerøy's investment in novel feed ingredients amounts to approximately NOK 350 million over the past four years. However, it has not set a quantiative target for alternative ingredient inclusion. The company reports that the salmon produced by them contains 7.5% EPA and DHA.

The company discloses the average level of adult female lice in each reporting period since 2019, but data is not disaggregated by operating region. The company discloses its performance against the target of zero exceedances of limits set by the authorities. The company has been under the regulatory limit since 2019, including FY2022. The company also reports the number of cages treated and the volume of treatment agents used.

The company describes targeted measures to reduce the number of lice, such as producing larger smolt using RAS technology to achieve shorter production periods at sea. Additionally, the company's efforts to control sea lice adhere to the principles of an Integrated Pest Management (IPM) strategy. This includes implementing preventive measures, utilising biological control methods (such as cleaner fish), and employing non-medicinal approaches. The company uses non-medicinal methods within the categories of fresh water, flushing, and temperate water. The company discusses several measures to enhance cleaner fish husbandry but does not disclose cleaner fish mortality rates for the reporting period.

The company reports that in 2022, it experienced up to 10,544 fish escapes from its fish farms. This represents an increase compared to the four fish escapes in 2021 and 208 in 2019, indicating an upward trend. The company states it has contingency plans for actual and predicted escape events. The company discloses that it is compliant with its operating region's minimum technical standard for on-site equipment use and is working with suppliers to improve their technology further to reduce the frequency of escape events. However, it does not provide details of the escapement prevention techniques it develops or employs or discloses the financial cost of global escape events. The company has set a target to achieve zero fish escapes by 2023.

The company discusses several projects and initiatives aimed at reducing its biodiversity impacts. These initiatives include following sites every two months to allow for recovery, reducing the use of plastic to mitigate ghost fishing, implementing feed control measures to prevent overload, and practising responsible trawling techniques. The company also has allocated quotas for various species to prevent overfishing. Additionally, it is actively involved in the 'Fishing for Litter' project, which aims to remove man-made waste from the oceans and contribute to environmental cleanliness. However, the company has not set a time-bound target to reduce human-wildlife contact in its operations.

The company's disclosed algae monitoring plan is designed around risk periods and observations suggesting algal blooms. In the event of a suspected algal bloom, all relevant stakeholders in the area are promptly notified, and a range of measures is implemented to minimise the impact on fish. Personnel responsible for fish health and production within the company are assigned to assess the level of monitoring required and determine potential measures to address algal blooms affecting specific localities.

The company reports conducting a water-related risk assessment and states that 98% of the group's water usage occurs in Norway, where there are no areas of water stress. However, the company acknowledges that it also operates in areas of high and medium water stress. Specifically, the company operates in areas of high water stress in Turkey, France, and Spain (specifically, the Madrid, Alicante, and Canary regions). Lerøy reports its water consumption in production facilities for 2022, and also company discloses its commitment to reduce freshwater withdrawals through initiatives such as investing in water-saving equipment and technology, conducting employee training on water management, and exploring water purification technology.

Although the company has set a goal to reduce freshwater use by 5% by 2025, it does not have a specific target for water consumption. It acknowledges that in 2021, it did not meet this target, achieving only 38% of the goal set by the company. Since the company has not yet achieved the target by 2022, we consider 2025 as the target year based on the information provided in the sustainability reports.

The company discloses its water withdrawals by source for 2022 and also discloses total water consumption for the same period. It discloses water consumption and water withdrawal by water stress level for all operating regions. The company reports water-related CAPEX and OPEX in 2022. It discloses that a third party has audited fresh water-related data. The company disclosed data to CDP Water in 2022. Overall, the company reports an increase in water consumption and a decrease in water withdrawals in 2022.

The company states it has an increased focus on supplier management to ensure the proper use of fresh water when producing raw materials. It has made a water conservation and efficiency plan for each supplier, including risk assessments based on WRI Aqueduct tools, monitoring water stress, setting KPIs to reduce withdrawals and improve water quality, and implementing preventive actions. Lerøy discloses that it has partnered with its feed producers and an independent research institute, Sintef, to complete a raw material climate risk analysis. The company investigates the availability, CO2, pricing, climate risk, and water usage for various feed ingredients as part of this analysis.

The company discloses that its feed water intensity is 0.052 m3/kg. It also provides the WRI scarcity score for each region where it sources feed ingredients. Soy from Brazil is sourced from an area of low water stress. Soy and wheat in Europe are sourced from regions of low to medium water stress, and rapeseed from Europe are sourced from regions with medium-high water stress. The company discloses the percentage of feed commodities sourced from each region.

All water-related non-conformities are reported, handled, and stored in the company's Quality Management system. The company had no significant incidents regarding wastewater spills or unwanted/unplanned discharge in 2022 and has not registered any violations of regulations related to the use of and discharge of water. It identified four facilities operating in areas with low-medium and medium to high risk from a water quality perspective, and the company discloses these locations. It states that it targets 100% of the wastewater discharged to comply with National regulations and discharge limits in the country of operations. The company says that, at a minimum, it follows the World Bank standard for waste limits where applicable to the specific geography. This included limits for Chemical Oxygen Demand (COD), Biological Oxygen Demand (BOD), Total Nitrogen (TN) and Total Phosphorus (TP). Lerøy has not set any wastewater volume target.

The company discloses the discharge limits in low, medium, and high water stress areas where various processing facilities operate. However, it does not disclose the quality of wastewater actually discharged in the reporting period across all operations. The company reported wastewater discharge in 2022 and that a third party, PWC, audits its selected ESG indicators. It discloses that a third-party company audits its water-related data but does not provide the name.

The company converts sludge from fish pens into biogas. However, it is unclear if processing waste and effluents are treated in the same manner. Lerøy discloses that wastewater discharge increased in 2022.

The company does not address nutrient management plans in its code of conduct or supplier code of conduct.

The company is investing in new raw materials for fish feed, such as microalgae, with the algae used in the feed being grown or cultivated on land in fermentation tanks. The production of microalgae has low carbon, water, and land use impacts. The company is also exploring using seaweed, kelp, and mussels for fish feed. Lerøy also states that it is investing in regenerative agriculture and new sources of soy produced with less fertiliser. It discloses that it is in the process of finalising a risk assessment survey to fully understand its supplier's risk profile and which actions can be taken to mitigate this risk. The company states that this also includes the use of pesticides in agriculture. However, no further information is provided regarding steps taken to reduce usage or replace harmful pesticides.

The company states that before approving a site for operations, a third-party body conducts a MOM-B analysis to determine site sensitivity and uses the same method to monitor ongoing organic loading. It discloses that the average MOM-B score is 1.38 and aims to achieve an average MOM-B per location of 1.5%. However, it does not disclose equivalent data for its farming operations in Scotland. The company has an ambition that all non-organic waste is reused or material recovered. All companies in the group report all generated waste by fraction and disposal method every month. However, the actual data-collection methods are missing from the disclosure.

The company does not disclose the treatment or metrics of effluent pond water. It does not disclose a neutral impact on water, or provide evidence of a community engagement plan.

The company commits to a stringent antibiotics policy, utilising them solely as a last resort for confirmed disease instances and under the prescription of authorized fish health personnel, thereby prohibiting their routine use across all operations. It also commits to comprehensive vaccination of its fish to prevent antibiotic overuse, complemented by risk management and structural measures for disease control.

The company states that zero antibiotics were used in 2022, and this data is audited by PWC.

The company acknowledges its responsibility to ensure fish welfare, stating that fish undergo continuous monitoring throughout the farming value chain, including monthly control visits. The company discusses aquatic animal welfare in detail, including handling, thermal comfort, and health and pain monitoring, and has made fish welfare and handling training mandatory for all staff. The company also holds several international standards relating to fish welfare and biosafety. The company uses electrical or mechanical stunning methods approved by the Norwegian Food Authorities.

The company reports an average density of 8kg/m3 during the reporting period. Still, the group policy is to maintain a density lower than 25 kg/m3, which is above the levels recommended by the RSCPA. There is evidence that additional welfare metrics are collected, but this data is missing from the disclosure.

The company is planning investments (in the range of 500 - 1,000 MNOK) in the coming years in sea-based production technologies to protect salmon from sea lice and adopting new and improved production technologies within coastal aquaculture. These technologies aim to protect the growth environment and ensure more sustainable production. The company is also involved in developing and testing new conceptual solutions to protect the biomass towards lice and safeguard the environment. However, the company does not disclose the stage of these projects or the invested amount in the current reporting period.

The company discloses that the survival rate at sea in 2022 was 92.5%, whereas the survival rate in freshwater was 91.4%. Incident-based mortality related to various factors such as disease, treatments, bacterial wounds, pasteurellosis, mechanical injuries, loss of circulation, gill infection, Tenacibaculum and unspecified causes is reported. Data covers the 2020, 2021 and 2022 reporting periods. The company had set a target to achieve a 2022 target of 89% survival in sea for harvested groups and 92% survival in freshwater and discloses that it achieved a rate of 85% survival in sea for harvested groups and 91.4% survival in freshwater in 2022, both below the set target rate.

The company discloses the number of disease outbreaks for diseases caused by bacterial wounds for the past three years. The ratio of the number of million fish/biomass tonnes affected by bacterial wounds fluctuated over the three years, with values of approximately 0.0375% in 2022, 0.0468% in 2021 and 0.0653% in 2020. There is no clear, consistent downward trend observed in this category. The company undertakes several steps to reduce fish losses until slaughtering, such as selective breeding programmes, screening of brood stock, risk assessment and biosafety, vaccination and sorting.

The company commits in writing to uphold human rights per conventions adopted by the UN and the International Labour Organisation (ILO).

The company has conducted a due diligence approach to assess human rights risks across its operations. This involved risk mapping focussing on industrial, geographical, product/service, and company risk. Based on this mapping, the company has prioritised risks according to severity and probability, with the prioritised risks being further assessed. Furthermore, the company conducts regular physical audits of larger suppliers and performs risk-based assessments of its supply chain. When identifying follow-up measures to identified risks, the company considers its involvement and responsibility and the nature of the negative impact. Risks will be allocated to a responsible person, and a deadline will be set should any risk-reducing measures be required. The company manages identified risks by updating guidelines for both its operations and suppliers. It also offers e-learning courses for its employees and states that it continuously trains managers to identify and handle unwanted incidents regarding human rights.

The company discovered no human rights abuses or significant risks during its due diligence process. Furthermore, despite identifying no considerable risk in its operations, the company has implemented preventative measures targeting areas it has prioritised based on the due diligence process. For example, to reduce the risk of discrimination and workplace harassment, the company has set a target to increase the proportion of women in management positions, entered into an agreement with Norweigan fishing organisations to prevent all forms of harassment and stated that it conducts a regular employee survey to assess employees experience of the workplace.

The company prohibits child labour, forced labour, abuse, discrimination and harassment in its operations and supply chain. However, it does not commit to promoting fair wages or provide a policy on paid sick leave. The company states that all its farms are Global Gap or ASC-certified and are audited annually by a third party in subjects connected to human rights. However, this disclosure cannot explicitly determine whether the policy areas of child labour, forced labour, abuse, discrimination and harassment have undergone audits by third parties or by Global Gap and ASC.

The company reports that it has established a system to ensure systematic audits and follow-up of suppliers to ensure compliance with the Code of Conduct, which includes policies concerning child labour, forced labour, abuse, discrimination and harassment. The company has an anonymous whistleblowing mechanism for all of its employees. Staff can report grievances via a digital channel, which a third party, EY, processes. The company's whistleblowing committee then conducts follow-ups. It also has an external whistleblowing channel that provides complainants with anonymity. However, the company must disclose whether its grievance channels were designed in consultation with stakeholders. The company reports that it received 17 internal whistleblowing cases in 2022, with 13 related to workplace harassment, two about sexual harassment and two about breaches of the Code of Conduct. Three external whistleblowing cases were reported but are left uncategorised.

The company commits in writing to providing safe and healthy workplaces, preventing work-related injuries and ill health, and proactively improving its health and safety performance. It states that all companies in the group comply with the ISO 45001:2018 Occupational Health and Safety: Basic Principles. However, the company does not explicitly disclose certification according to ISO 45001 standards. In addition, the company announces that 83% of companies in the group have a formal joint management-worker health and safety committee/safety representative. Safety representatives are said to be present in smaller companies where safety committees are not required. The company also states that in 2022, it completed a risk assessment concerning the risk of employees developing antibiotic resistance.

The company reported a lost time injury frequency (LTI) of 13.31 in 2022, demonstrating an improvement from the LTI figure 15.33 reported in 2021. Also, the company discloses that it had zero fatalities during the reporting year and one fatality in the previous year, showing a year-on-year improvement in the fatality rate. The company reports that in 2022 the turnover rate was 9.54%, but it does not disaggregate it by seniority level.

The company discloses that all employees shall be entitled to join or establish trade unions according to their free will acollectively bargainely. In 2022, 1,664 company employees were members of trade unions. The company also provides evidence of measures to support collective bargaining and freedom of association. For example, union representatives can inform employees about both subjects at the company's annual new employee kick-off. In addition, contact information for employee representatives is available on the company website, in the employee handbook and in bulletin boards. Moreover, union representatives have their notice boards where they share information. In addition, the company expects its suppliers, subcontractors, and business partners to support freedom of association and collective bargaining agreements.

The company reports that 65% of its employees in Norway and 47% of its employees abroad are covered by collective bargaining agreements. The company also discloses the total number of employees, contract staff and part-time employees.

The company discloses that 92% of processing plants have GFSI certification, and 100% of localities hold GlobalGAP or ASC certification, both of which are GFSI-recognised. It aims to reach 100% certification of processing plants by 2025. Further, it requires suppliers to have 100% GFSI certification. However, it does not explicitly disclose the proportion of certified suppliers.

The company states that in 2022, it conducted 921 documented audits and inspection events in total. These included 363 inspections related to food safety audits and 558 audits and assessments performed by a third party. It disclosed that no facilities received GFSI fundamental, critical, or significant non-conformities, resulting in a corrective action rate of zero. Further, it discloses an in-house tracking system called Fishtrack, which offers customers a complete online traceability system for all products from parent fish to processing. Additionally, it has established a traceability portal using Blockchain technology (IBM) with direct access for consumers in Norway, allowing them to access complete traceability information specific to the salmon they have bought.

The company provides a detailed description of the product recall system it has in place, outlining many phases. It also discusses its annual preparedness plans, which ensure the efficient functioning of the recall system. All parties must submit correct and documented information as part of the emergency preparedness test. The test also involves checking whether relevant key contact persons and contact information outside of opening hours have been updated and are accurate. Following a recall test, a summary is prepared, and improvements are identified and implemented. The quality manager at the production facility and the sales department are jointly responsible for the recall system. In 2022, the group had 11 product recalls related to minor batches of sushi products. Of these, two were associated with the detection of listeria, two were due to an on-label error, one was expected to insufficient packaging, and six were due to the detection of bones/foreign objects. In response, it has implemented a digital food safety surveillance program focused on actions and trends,

The company reports that it had one market ban in 2022 in Russia, albeit unrelated to food safety issues. Russia decided to ban the import of Norwegian seafood in response to sanctions imposed by the US, the EU, and other countries following the annexation of Crimea.

The board has the overall responsibility for sustainability work within the compprimary The CEO has the main responsibility related to sustainability, and the group management approves these responsibilities before they are sent to the audit committee/board. In addition, the company carried out an updated materiality assessment in 2022, which was approved by the board of directors. The various material topics identified in 2022 include biodiversity, water and effluents, waste, fish health and welfare, climate emissions, raw materials used in fish feed, health, safety, and environment, food safety and security, supplier management, etc. The company discusses board-level expertise in sustainability and innovation but not food safety.

The company reports that managers at different levels of the organisation are assigned job descriptions that contain other goals, including goals for sustainability. However, the company does not disclose the percentage of variable compensation linked to such purposes. The company engages with various interest groups and associations, such as The Norwegian Innovation Cluster and The Norwegian Seafood Federation, on ESG issues. The company is also a member of UN Global Compact, Cerrado Manifesto, Global Sustainable Seafood Initiative, Miljøstiftelsen Bellona, and Amnesty International. Additionally, the company collaborates with NIFES, the National Institute of Nutrition and Seafood Research, to investigate whether naturally occurring algal toxins could harm the fish or the consumer. The company provides details of its trade association and coalition memberships. Also, the company discloses that it has a public commitment or position statement to conduct its engagement activities in line with the goals of the Paris Agreement.

The company aims to lead in product development to ensure customer satisfaction. It has a product development department that works through the entire value chain, from raw materials to finished products in stores, constantly developing new products and improving the quality of existing ones. It strongly focuses on utilising the whole fish for human consumption to avoid wastage. Additionally, the company has a joint venture with Ocean Forest AS, a company focused on innovation in producing low-trophic species such as macroalgae, blue mussels, and polychaeta. The company also discusses using the Coller FAIRR Protein Producer Index and the UN SDGs as benchmarks to assess its sustainability performance against its peers.

The company acknowledges that consumer interest in plant-based fish alternatives is growing, and the vegan market is expanding due to the growing demand for sustainable food. It attributes this to young consumers, who will have future purchasing power, changing their eating habits and focusing more on climate issues and the carbon footprint of the food they purchase. It acknowledges that the emerging markets for alternative plant-based protein sources may impact the competitive environment and potentially reduce demand for its products, potentially directly impacting profitability. It states it is exploring potential technological developments in alternative protein production. However, it does not disclose a timebound target to diversify protein sources or report sales/revenue linked to alternative protein sources.

The company aims to be a part of the alternative protein trend by offering a wide range of products in the future, including plant-based fish. In 2021, it initiated an R&D project to explore diversifying into plant-based protein products. The goal was to find a partner that could assist in identifying suitable replacements for fish proteins in a range of "fish-like products", such as Vegan Maki with salmon and shrimp, Vegan Salmon burger, Key West Crab cake, and more. The project is still ongoing, and results still need to be published. The trials and tests conducted with its partners in 2022 yielded different results than the expected texture, taste, and appearance outcomes. Therefore, this testing will continue in 2023. It aims to have plant-based protein products ready for the market by 2024.