Marubeni Corporation

Group level:

Marubeni clearly acknowledges the material risks of Illegal, Unreported, and Unregulated (IUU) fishing, overfishing, habitat conversion, and human rights issues within its group-level policies. The identified risks are covered in Marubeni Group's “Basic Policy on Human Rights” and the “Basic Supply Chain Sustainability Policy”, and further individual procurement policies based on the “Basic Supply Chain Sustainability Policy” enabling a more specific commodity focus, such as the “Marubeni Group Seafood Products Procurement Policy”.

While Marubeni Group acknowledges the role of traceability in directly addressing IUU risks within its seafood procurement policy, stating that it will “strive to eliminate IUU, ensuring traceability of the origin of seafood products”, the company does not explicitly link traceability with other identified material risks.

However, the company highlights Recirculating Aquaculture Systems (linked with Danish Salmon A/S) and its role as a farming method supporting traceability. Furthermore, the company has underlined an aim to expand sales of “sustainable seafood products” via seafood that has obtained Global Seafood Sustainability Initiative (GSSI) certification (which includes “MSC/ASC/BAP, etc”).

Marubeni is a TNFD adopter since January 2024 and has published its first TNFD disclosures in 2025.

For suppliers, Marubeni highlights that it conducts on-site surveys for suppliers at their manufacturing and production sites to see their initiatives in accordance with the company’s Sustainability Guidelines of the Basic Supply Chain Sustainability Policy. Furthermore, in response to FAIRR’s investor letter and assessment, Marubeni indicates that starting this fiscal year, it is planning to incorporate traceability-related questions aligned with GDST standards into its written supplier survey draft. Specifically, Key Data Elements: W3 (weight quantity), W10 (gear type), W14 (catch area), W15 (species), W16 (product form), W21 (landing location), and W25 (product origin).

Marubeni also indicates that it conducted sustainability surveys for its consolidated subsidiaries between from FYE 3/2020 to FYE 3/2021. Around 200 subsidiaries were surveyed out of approximately 400. The company it continues to monitor risk factors in its subsidiaries businesses, and indicates that the latest survey was conducted in FYE 3/2024.

More generally, Marubeni's highlights that its “Green Strategy” involves strengthening business areas which are considered “green businesses” and “greening” the company’s operations, with the overall aim to make a “nature positive” contribution. This includes sustainability initiatives such as “decarbonisation, transitioning to a circular economy, respect for human rights, and building sustainable supply chains”. Marubeni's disclosure around its Green Strategy outline how it developed an assessment framework to support a multifaceted analysis of “27 items across three risk categories of environmental, health and safety, and social”. This approach to risk management is also used for assessing sustainability risks in subsidiary and supplier surveys. Through its risk assessments, the company has identified “Human Rights & Co-Development With Communities” and “Sustainable & Resilient Value Chains” as two of its “Environmental and Social Materiality Issues” , and, from this, sets out its expectations from suppliers on issues such as “Respect for Human Rights” and “Conservation of the Environment'' in its “Basic Supply Chain Sustainability Policy” and “Basic Human Rights Policy”.

These policies have been communicated to Marubeni’s approximately 23,000 Tier 1 suppliers. The company has an internal framework for assessing sustainability risks, which is used in subsidiary and suppliers surveys. All suppliers of critical commodities, which the company has assessed as having relatively high sustainability-related risks, have now completed either a written or on-site survey to check compliance with these policies and identify sustainability risks. After the current year, Marubeni plans to expand the surveys from head office Tier 1 suppliers to Tier 1 suppliers of its consolidated subsidiaries. Marubeni also conducts human rights due diligence focusing on the elimination of forced and child labour. This due diligence applies to all new projects and those suppliers where the company has identified higher risk of forced or child labour based on industries, products, and regions.
Despite disclosing information on its approach to risk assessments, the company shares limited information on how it assesses the specific material risks to its seafood business associated with Illegal, Unreported, and Unregulated (IUU) fishing, overfishing, habitat conversion, and human rights, nor does it disclose how successful it is at mitigating these risks. As an example, Marubeni discloses the certification rate for Eastern Fish (89% MSC/ASC/BAP) and Danish Salmon (100 % ASC), but not for Marubeni Seafoods Corporation. Disclosing the group-level certification rate for seafood procured would give shareholders a better idea on how certifications are used to mitigate seafood supply chain risks. The company also does not set any time-bound targets to eliminate these risks from its supply chains.

Subsidiary level:

Marubeni Seafoods: Marubeni Seafoods acknowledges the limited availability of marine resources, further stating that marine pollution and the depletion of marine resources have become global issues and that there is a need to protect the marine environment.

The company also highlights its acquisition of MSC/ASC and Marine Eco-Label (MEL) Chain of Custody certification that take environmental and marine sustainability into consideration, though the amount of seafood handled in relation to this is not disclosed.

Marubeni Seafoods refers to Marubeni Corporation group-level policies on human rights and sustainable supply chains. Despite this, there is limited disclosure that explicitly underline the material risks, mitigation efforts, or the role of traceability associated with IUU fishing, overfishing, habitat conversion, and human rights.

Eastern Fish: Eastern Fish has committed to “habitat protection” as part of its “obligation to environmental leadership” and pledged to protect the marine environment which “goes beyond simply obeying all of the environmental laws and regulations. Alongside this, the company outlines its aim to source 100% of seafood responsibly by 2025, defined by the company as products that are certified by an eco-certification recognised by the Global Sustainable Seafood Initiative (GSSI), or originating from Fishery Improvement Projects (FIPs), Aquaculture Improvement Projects (AIPs), or that are OceanWise recommended or rated Best Choice or Good Alternative by Seafood Watch.

Eastern Fish highlights that it has MSC Chain of Custody, which is presented as a way of reversing overfishing and combating illegal fishing.

The company refers to its Supplier Code of Conduct that commits its suppliers to respect internationally recognised human rights standards, though this document is not available to view. While there is evidence the company acknowledges certain risks such as IUU, overfishing, wider environmental issues and human rights issues within seafood supply chains, it does not explain how it assesses these risks or how, beyond aiming to source certified seafood, it mitigates them.

Danish Salmon: Danish Salmon does not address risks of IUU fishing, habitat conversion, or human rights and their link to traceability - however, it highlights overfishing and describes Recirculating Aquaculture Systems (RAS) farming as a sustainable alternative to prevent risk of traditional fish farming and wild catch.

The company also highlights that both its seafood and feed are fully traceable. Given Danish Salmon is certified by the Aquaculture Stewardship Council (ASC) Farm Standard, this means that the company will have to abide by the ASC Feed Standard by October 2025.

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

Group level:

In June 2024, Marubeni published a new Seafood Products Procurement Policy, which states that the company will “strive to eliminate IUU, ensuring traceability of the origin of seafood products”. The company also discloses a traceability commitment for certain other products, such as forest-derived products, beef and cotton. Marubeni also states that it aims to develop sustainable supply chains and traceability as a component of its business strategy.

The only other group-level mention of seafood traceability in the company’s disclosure is in relation to the Danish Salmon acquisition - Marubeni describes RAS farming as a method that supports traceability.

Regarding certifications, in its Seafood Products Procurement Policy, Marubeni Group states that in cooperation with suppliers, it "aims to expand the sales of sustainable seafood products" which includes seafood products certified by a certification scheme recognised by the Global Seafood Sustainability Initiative (GSSI), such as MSC/ASC/BAP.

While the company has considered traceability within its disclosures, it is not sufficient to indicate a commitment to full-chain, digital and interoperable traceability systems across its seafood and feed portfolio.

Subsidiary level:

Marubeni Seafoods: There is no explicit mention of traceability by Marubeni Seafoods corporation. The company has shared that it "connects disparate information to create outlines" by using its "antennas daily" to transmit information on catch and to "connect the information held by each department, and move onto the next step", indicating that there is some traceability data collected in practice. Marubeni Seafoods Corporation had previously mentioned traceability in relation to “laws and regulations” and to “prevent food accidents” on its website, though this is no longer available publicly.

Eastern Fish: Eastern Fish states that all its products are fully traceable from “farm to packaging” , emphasising a commitment to food safety and quality control - though there is limited information on how this applies to its business (import of wild-caught seafood or farmed seafood, with associated feed inputs).

The company also highlights that it is "supporting best practices within our supply chain" which includes its MSC chain of custody. The company adds that it is a certified member of Sedex, and committed its business to achieving and maintaining "transparency" from raw material harvesting and transport of goods and finalised products. However, this disclosure is not explicitly tied to a traceability commitment covering the company’s seafood and feed operations.

Danish Salmon: Danish Salmon discloses a commitment to traceability in seafood and feed - however, there is limited information on whether the feed that is certified comes from terrestrial or marine sources, and measures taken to assess or achieve traceability.

Overall, FAIRR sees no evidence of a commitment to full-chain, digital, and interoperable traceability for seafood and/or feed ingredients for Marubeni Corporation (at the group level), though, the company indicated a qualitative commitment in its Seafood Products Procurement Policy. While Eastern Fish and Danish Salmon have high-level individual commitments to traceability, it is not clear whether these cover all seafood and feed ingredients. As Marubeni does not disclose its seafood revenues by subsidiary, it is also not possible to establish whether these commitments might cover “materially all” seafood business of Marubeni (95% of the company’s total seafood revenues).

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

Group level:

Marubeni Corporation states that it aims to develop sustainable supply chains and traceability as a component of its business strategy – this remains a very broad commitment. Additionally, the company has a seafood-specific traceability commitment to “ensuring traceability of the origin of seafood products” in its Seafood Procurement Policy.

The traceability commitment contained in the Seafood Procurement Policy:

• Scope: appears to apply to all “seafood products”, though this is not explicitly defined.
• Depth: does not explicitly state that seafood can be traced back to the farm/vessel/feed source.
• Breadth: no reference to alignment with GDST or other leading certification standards within this traceability commitment.
• Form: not timebound, nor any reference to digital or interoperability.

The company also has a broad statement within its “Marubeni Group Seafood Products Procurement Policy” to expand the sales of products that are certified by a certification recognised by the GSSI, such as MSC/ ASC/ BAP. While the company's 2024 Sustainability Report reflects this qualitative commitment to certifications, the company does not disclose a quantified or time-bound target to increase the coverage of its certifications.

Subsidiary level:

Marubeni Seafoods: Marubeni Seafoods does not have a commitment to traceability.

Eastern Fish: Eastern Fish discloses that all products are traceable from farm to packaging.

• Scope: appears to apply to “all product” though, it this is not explicitly defined. In particular, it is not clear whether this applies to feed and wild-caught seafood.
• Depth: explicitly states that seafood can be traced from “farm to packaging”. However, for wild-caught seafood, it is not clear whether seafood can be traced back to the vessel.
• Breadth: no reference to aligning with the GDST, however, the company highlights a food safety certification (International Featured Standards – IFS) with associated Chain of Custody certification.
• Form: not timebound, nor any reference to digital or interoperability.

Danish Salmon: Danish Salmon discloses that both its seafood and feed is fully traceable. , Danish Salmon is ASC-certified, and therefore relies on a Chain of Custody system to claim that its products are traceable. ,

• Form: not time-bound, nor any reference to digital or interoperability.
• Scope: seafood and feed are fully traceable.
• Depth: does not explicitly state that feed can be traced back to the source, though suppliers are required to demonstrate third-party compliance.
• Breadth: no explicit reference to aligning with the GDST or other leading certification standards within this traceability commitment.

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

Marubeni does not have a traceability implementation plan at the group or subsidiary level to achieve its traceability commitment. While the company outlines its aim to expand sales for “sustainable seafood products” and reported the “Seafood Procurement Performance Data” which covered certifications (ASC/MSC/BAP) for its subsidiaries, this does not constitute an implementation plan.

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

Group level:

Marubeni does not disclose whether it has operational traceability systems at the group level. In response to FAIRR’s investor letter, the company stated that it will evaluate opportunities to expand its public disclosures on topics including its “seafood traceability review, preliminary risk assessment, supplier visits from the previous fiscal year, and the written supplier surveys planned for the current fiscal year”.

The company discloses its subsidiaries' progress on certifications (ASC/MSC/BAP), which is reported on an annual basis in its sustainability report.

Subsidiary level:

Marubeni Seafoods: Marubeni Seafoods Corporation does not disclose whether it has operational traceability systems in place. Marubeni Seafoods mentions that it has acquired MSC/ASC and MEL certifications, but does not specify the proportion of its seafood portfolio that is certified.

Eastern Fish: Eastern Fish indicates that “all products are fully traceable from farm to packaging” , which implies the existence of a full-chain operational traceability system, but no further information is disclosed. Eastern Fish’s certification rate is 89% for FY2023 (across MSC/ASC/BAP), however, there is limited information on this beyond this statement.

Danish Salmon A/S: Danish Salmon states that its traceability systems fully cover its seafood and feed, and the company is also certified to ASC. However, there is limited detail on terrestrial and marine feed, and how its traceability measures are implemented for feed inputs.

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

Group level:

Marubeni Corporation does not disclose any third-party verification of its traceability systems, nor does it report on non-compliance with these systems. In relation to its supplier surveys, the company indicates measures in place for handling non-compliance – stating that it addresses this through “actions for improvement towards the supplier” which includes “training, enlightenment activities, support, and corrective instructions to promote environmental and social countermeasures”. If no improvement is made, the company may cease operations with the supplier.

Subsidiary level:

Marubeni Seafoods: Marubeni Seafoods mentions that it has acquired MSC/ASC and MEL certifications, which implies third-party audits. However, no further information is disclosed regarding these audits, or cases of non-compliance.

Eastern Fish: Eastern Fish also mentions certifications (MSC/ASC/BAP). However, no further information is disclosed regarding the audits associated with these certification schemes, or cases of non-compliance.

Danish Salmon A/S: Danish Salmon is ASC-certified. However, no further information is disclosed regarding the audits associated with these certification schemes, or cases of non-compliance.