Maruha Nichiro Corporation

Maruha Nichiro (henceforth, Maruha) clearly acknowledges the material risks of Illegal, Unreported, and Unregulated (IUU) fishing, overfishing, habitat conversion, and human rights across its group-level integrated report, sustainability-related disclosure on its website, and the company’s group-level policies which include the Group’s Marine Products Procurement Policy, Human Rights Policy, and the Suppliers Guidelines. Furthermore, Maruha acknowledges the role of traceability in the marine products it procures, with a particular emphasis on IUU fishing, and some consideration of child labour and forced labour.

Maruha addresses material biodiversity risks to its operations within its 2025 update of its “For the Ocean, for Life Maruha Nichiro Value (MNV)” strategy, which equates to its integrated business and sustainability strategy, with associated KPIs. The company disclosed its “Action for preserving biodiversity and ecosystems” which aims to address resource depletion in its handled fish stocks through KPIs that cover electronic traceability, establishing fish handling policies, certification-level management on aquaculture farms, and TNFD-based risk assessment implementation.

Building on this, Maruha conducted a biodiversity risk assessment in 2025 in line with the recommendations of the Taskforce on Nature-related Financial Disclosures (TNFD). The company’s disclosures focus on its direct operations in the fisheries and aquaculture sectors, specifically targeting the most material species - Alaska pollock for wild fisheries, and yellowtail, amberjack, bluefin tuna for aquaculture. Following the completion of the “Locate” and “Evaluate” phases in 2024, the “Assess” and “Prepare” phases were implemented and disclosed in fiscal year 2025. In its feedback to this assessment, Maruha indicated that a summary of this TNFD assessment is included in its 2025 Integrated Report and website. To support this initiative, Maruha also established a dedicated risk management department and disclosed its fundamental approach to addressing the identified risks and opportunities, along with specific initiatives undertaken to mitigate and manage them.

Maruha has also set a target to achieve sustainable supply chains by 2030, measured by achieving a 100% rate of agreement with the Group Supplier Guidelines in the company’s supplier survey, in FY2024 it had achieved 83.1%. The Group Supplier Guidelines ask suppliers to eliminate any ties to IUU “through thorough traceability”, to respect human and labour rights and to reduce their environmental load, prevent environmental pollution, protect the global environment and consider biodiversity. Maruha Nichiro also disclosed its target to achieve 100% coverage rage for its Supplier Survey System by 2024, which it has achieved.

Maruha also disclosed a target to achieve zero human rights violations in its direct operations and supply chain by 2030. The company stated that it had not previously been able to carry out comprehensive identification and analysis of human rights risks. In the review of materiality for the fiscal year ended March 2025, Maruha defined Key Goal Indicators (KGIs) for the material issue of “Respect for human rights in business operations” as: “Implement initiatives to eliminate human rights violations in the company and across its supply chain, including within the company”. In its feedback to this assessment, Maruha acknowledged challenges in comprehensively identifying and analysing human rights risks – in response, during the 2023 fiscal year, the company conducted expert consultations, implemented human rights training, and mapped and prioritised human rights risks. Furthermore, the company highlights that it established Group Human Rights Guidelines (implementation began in FY2023) as a response to the material issue: “Forced labor and human trafficking of migrant workers within the Group’s domestic operations”. To address the identified issue of “Lack of multilingual consultation services”- revealed through surveys on compliance with these guidelines- the company participated in a program offered by a general incorporated association. The company is currently working to establish multilingual consultation windows at domestic sites, including fishing vessels, and plans to expand these services to key domestic suppliers as appropriate.

Maruha shared that it carries out marine resource surveys to confirm that there is no risk of resource depletion in the fish stocks that the company sources and has set a target to confirm 100% of the resources by 2030. The latest Marine Resources Survey, conducted in 2021-2022, confirmed the resource status of 81.8% of marine products handled as indicated by FY2023 results. The remaining circa 18% are “non-classifiable” (i.e. it is not known whether the fish originates from wild capture or aquaculture) or “not scored” (i.e. the company has insufficient data on the resource status). According to Maruha, the “non-classifiable” proportion of fish relates mainly to raw materials for feed. Maruha recognised this as a major issue that needs to be improved. The survey also evaluated that 44% of wild-caught fish handled is “well managed”: this corresponds to the fish sourced from fisheries that are certified, such as MSC-certified fisheries. The next survey results are scheduled for 2025. Maruha has now also set a target for increasing the sales ratio of sustainable certified products (including certified marine products defined as those approved by GSSI such as MSC, ASC, BAP and MEL) to 15% or more by 2030.

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

Since the first Phase of this engagement, Maruha has published a Marine Products Procurement Policy which contains a commitment for the company to “establish traceability for the marine products” it procures, including information on catch/harvest timings, areas, and fishing vessels.

Maruha does not have a time-bound target for the elimination of IUU fishing. However, as part of its Group Supplier Guidelines, the company asks all suppliers to eliminate any ties to IUU “through thorough traceability”. Maruha has also set a target to have sustainable supply chains by 2030, and is targeting a 100% rate of agreement with the Group Supplier Guidelines from its suppliers. According to the Integrated Report, this is assessed through compliance checks within a new supplier survey system.

In addition, Maruha’s SeaBOS membership suggests that the company will implement traceability systems aligned with the GDST, though this does not amount to a formal commitment to the GDST standard.

Regarding certifications, the company stated that it is committed to actively promote the handling of marine products procured by sustainable fisheries and aquaculture that have obtained internationally recognised certification approved by the Global Sustainable Seafood Initiative (GSSI) (detailing that this includes “MSC certification, ASC certification, BAP certification, MEL certification, etc”).

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

Since the first Phase of this engagement, Maruha has published a Marine Products Procurement Policy which contains a commitment for the company to “establish traceability for the marine products” it procures, including information on catch/harvest timings, areas, and fishing vessels.

This traceability commitment is assessed according to the following criteria:

• Scope: this commitment covers 100% of marine products handled by Maruha, and includes feed as confirmed by the company during dialogue and the company’s feedback to this assessment (though this scope is not specified in public disclosures).
• Depth: explicitly mentions that products will be traced back to the vessels.
• Breadth: is not explicitly aligned with the GDST.
• Form: not time-bound, nor digital nor interoperable. Rather than having a time-bound commitment to traceability, the company has a commitment to confirm the “resource status” of all of its marine products by 2030.

In addition to this traceability commitment, the company is committed to increasing certifications such as “MSC certification, ASC certification, BAP certification, MEL certification, etc” within its portfolio - linked with this, the company has a sales ratio target for at least 15% of certified sustainable products (including marine products) by 2030. Whilst it is good that this commitment is time-bound, it only covers up to 15% of Maruha’s seafood portfolio.

In Maruha’s Integrated Report, there is a mention of a roundtable discussion at which Director Yoshiko Tonoike said that Maruha aims to achieve “a 100% traceability rate for handled marine products by FY2030”. This is more precise than what is currently in Maruha’s Marine Products Procurement Policy.

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

Maruha does not have a specific implementation plan in place in relation to its new traceability commitment, however, the company disclosed KPIs based on assessed risks.

Maruha discloses progress on various environmental and social KPIs in a dedicated implementation plan “For the Ocean, For Life strategy”. This includes a time-bound KPI on “confirming the resource status of marine products handled” which is relevant to traceability (as of latest reporting in 2025, the company has confirmed the status of 81.8% of its marine products). Furthermore, the company has a qualitative target associated with its electronic traceability KPI, stating that it will “start operation with some fish species” by FY2027, though there are limited details around this in public disclosures. The company has confirmed during the investor dialogue and in the company’s feedback to this assessment that its electronic traceability KPI is aligned with the GDST standard.

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

Maruha’s traceability commitment within its Marine Products Procurement Policy addresses the depth of its traceability systems stating that the company will “establish traceability for the marine products” it procures, including information on catch/harvest timings, areas, and fishing vessels. However, it is not clear whether the company already has a traceability system in place currently that aligns to this commitment.

Regarding the use of certifications, Maruha has a target to increase the proportion of GSSI- certified seafood to 15% of total seafood product sales across all Maruha’s business divisions by FY2030. The company added in its response to the FAIRR investor letter and in its feedback to this assessment that this target is based on the understanding that MSC/ASC-certified seafood ensures traceability through Chain of Custody certification and that it has currently achieved 6.4% GSSI-recognised certified seafood sales. In its feedback on this assessment, the company noted that it recognises the importance of clearly communicating the value of sustainable seafood to customers through its business activities and that it is also committed to promoting broader societal awareness. To this end, it is actively engaging in initiatives such as publishing articles in newspapers and magazines and delivering presentations at lectures and public forums.

Regarding aquaculture certifications, Maruha states that, amongst the main farmed fish, yellowtail and amberjack have already obtained ASC accreditation at “some” farms. Since there is no ASC standard for tuna, the company also has established “voluntary management standards that align with ASC certification” and implemented this across the company’s 13 aquaculture farms. The company also highlights in its response to the investor letter that, although it has requested traceability information from feed companies, this has not yet been accomplished.

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

There is limited to no evidence to suggest a third party verifies the company's traceability commitment, nor is there any indication of how this may be assessed on an annual basis. Maruha discloses information about the resource management status of the species it handles annually, but not about the level of traceability across its supply chains.

The company indicates in its 2025 update for its Medium-Term Management Plan (For the Ocean, For Life 2027) that under the materiality "Development of a sustainable supply chains", it has set 2030 targets of 100% agreement rate with supplier guidelines and rate of improvement in key items (Entire Group) - which includes confirmed status through third-party audits. Despite this, there is no clear link between the rate of agreement of suppliers to the Supplier Guidelines, and the company’s traceability systems or commitment.

Furthermore, while the company requests suppliers to address IUU fishing through traceability, there is no disclosed information covering how this is assessed and how non-compliance is addressed. In its Medium-Term Management Plan (For the Ocean, For Life 2027) the company discloses a main KPI to establish “CSR audit methods” and to establish “standards and audit methods to avoid procurement of marine products originating from IUU fisheries”, stating that it aims to achieve this across all consolidated companies by 2030. While this is positive, it is unclear whether audits cover GDST-aligned traceability data, or if these will be implemented by third parties.

In its response to the investor letter, Maruha addresses this topic of supplier surveys further and discloses that it is conducting surveys of its primary suppliers using Self-Assessment Questionnaires (SAQs) to assess their compliance with the company’s guidelines. The company is also working with suppliers who have issues in particularly important areas to encourage improvements. Going forward, the company states it will conduct SAQs once every two years, follow up on improvement progress while maintaining communications with suppliers, and consider providing support as needed. For suppliers who show no intention to improve, Maruha will consider reviewing its business relationship with these suppliers.

In relation to certifications, the company disclosed that it has obtained ASC certification for certain species, as well as MSC certification for certain fisheries. While the acquisition of these certifications indicates third-party verification, there is limited disclosure on this process nor is there any information on cases of non-compliance. The company indicated it conducts internal audits to establish its voluntary standards for species not yet included within the ASC standard.

The company has also implemented surveys linked with the ASC, utilising results to inform voluntary standards measures - adding that it aims to expand audits relating to its remaining nine fishing grounds in FY2024 and complete audits of all the fishing grounds in its Aquaculture Business Unit. The company also discloses that it has, in combination with MSC Japan, conducted a seminar on fishery challenges, and will share related findings through "umito.", its owned media company.

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