Mowi ASA

The company has set a science-based target in which it commits to reducing absolute Scope 1 and 2 GHG emissions by 35% by 2030 and 72% by 2050 from a 2016 base year. It also commits to reducing total Scope 3 GHG emissions by 35% by 2030 and 72% by 2050 from a 2018 base year.

The company's Scope 1, 2 and 3 emissions reduction targets are validated by the SBTi and aligned with a well below 2C scenario by 2030.

The company's CDP Climate Change Report 2022 discloses that carbon and climate-related data is collected from its suppliers to monitor reductions in feed conversion ratios at the end of each production cycle, alongside yearly reductions in Scope 3 emissions from feed raw materials. Further, the supplier code of conduct discloses that suppliers should promote energy-efficient and environmentally friendly technologies to reduce emissions.

The company discloses various methods it has adopted to reduce emissions from feed farming, including conducting R&D to develop and test emerging feed raw materials with improved emissions profiles.

The company mentions that it aims to implement Smart Farming by 2025 in Norwegian farming, including next-generation underwater cameras to reduce fuel usage and Scope 1 emissions. It also has an energy management system to help farms be more energy efficient. However, those innovative projects only run in Norwegian farming, not all farms.

The company discloses disaggregated emissions data for 2022. These are 119,191 tonnes CO2e for Scope 1, 120,379 tonnes CO2e for Scope 2 and 1,774,230 tonnes CO2e for Scope 3.

In its CDP Climate Change 2022 report, the company discloses that 97,963.2 metric tons of CO2e are attributed to animal farming. As per its Integrated Report 2022, emissions from the company's farming business (Scope 1+2, market-based) reduced from 332 in 2021 to 302 kg CO2e/tonne biomass harvested in 2022. It discloses Scope 1 feed emissions of 15,454.7 metric tons CO2e (from feed processing) and lists feed sourcing as an emission source in Scope 3 agricultural emissions. Scope 3 agriculture-related emissions amount to 1,347,938 metric tons of CO2e. It states that the intensity of GHG emissions in the feed business area (including both the plants in Norway and Scotland) decreased between 2021 and 2022 from 78 to 58 kg CO2e/tonne of feed produced (25% reduction). It discloses emissions from land-use change related to sourcing feed raw materials was 193,314 tonnes CO2e. It also reports zero land-use change associated with the conversion of coastal wetlands (mangroves, seagrass and marshes), conversion/draining and burning of peatlands, and conversion of savannas and natural grasslands.

The company responded to the CDP Climate Change questionnaire in 2022. It discloses that its GHG emissions data is verified by a third party annually.

The company reports that its total GHG emissions (Scope 1, 2 and 3) have reduced by 3.61% YoY from 2,089,404 tonnes CO2e in 2021 to 2,013,800 tonnes CO2e in 2022. The GHG emissions (Scope 1 and 2) decreased by 9% YoY from 263,659 tonnes CO2e in 2021 to 239,570 tonnes CO2e in 2022 (Feed: 29,975 tonnes CO2e, Farming: 170,744 tonnes CO2e, Sales & Marketing: 38,851 tonnes CO2e). Scope 1 and 2 emissions were reduced in 2022 due to replacing emissions fuel types with more climate-friendly alternatives in the feed operations and an overall reduction in fuel use in the farming operations. Its CDP reporting also discloses that most emission reductions stem from switching to renewable energy sources and a change in GHG accounting methodology, and merely 1.6% of emission reduction stems from energy efficiency measures, which it needs to describe in detail. It needs to tell if any emissions reductions are due to better agricultural practices. Based on the evidence, it can be assumed that most emission reduction stems from a change in energy source, not agrarian use. Therefore, no points can be awarded.

The company discusses climate-related scenarios and low-carbon transition plans in its 2022 Integrated Annual Report and CDP responses. The analysis covers multiple scenarios, including RCP 8.5, 6.0, 4.5, and 2.6. It uses relevant IPCC reports and internal company data to analyse the consequences of predicted temperature rises with the identified climate risks and opportunities for the business. Following the analysis, the potential impact is assessed against TCFD guidelines. It performed climate-related scenario analysis for both short-term and long-term time horizons, and the outcomes have led it to develop science-based targets.

The company acknowledges the risk of feed raw materials availability due to weather events. It plans to adapt to such threats by improving the robustness of its farming equipment, adopting technical standards, and increasing monitoring and mitigation actions related to algae blooms. It also mentions sourcing from deforestation-free areas and working towards increasing the flexibility of feed raw material alternatives to reduce raw material risk. It discloses that in the four °C scenario, there is an increase in water temperature and a higher frequency of algae blooms that may result in increased mortality and escape events. It discusses monitoring and mitigation actions related to algae blooms. In addition, it has a mitigation plan for the depletion of fish stocks by environmental factors. The company mentions that the impact of heat stress/physical risks on the prevalence of disease and the resulting implications for veterinary and medicine costs is predicted to be below a significant financial impact. To mitigate this risk, the company invests in R&D on non-medicinal tools to manage sea lice and breeding and genetics to optimise the disease-resilience of fish. It addresses the increase in fuel taxation impacting day-to-day operational costs, as fuel is mainly used in farming operations and at sea sites. Therefore, to mitigate the high functional price, the company is transitioning to a low-carbon economy which utilises renewable electricity in processing plants. It discusses the risk of the Norwegian government implementing an increased carbon tax to meet its ambitious climate goals and its potential impacts on the company's operations. It plans to mitigate this by transitioning to a low-carbon operating model. It mentions no financial material events related to climate risks in the reporting period.

The company reports that as part of its Green Bond and Sustainability-linked loan, it has committed to aligning its capital expenditures with GHG targets. In 2022, the allocation of proceeds to green categories, including those related to GHG emissions (sustainable feed), was 164 million EUR. In addition, it invested approximately 1.5 million EUR in energy-saving initiatives in 2022.

The company discloses that 12.2% of the company's salmon feed is made up of soya products. It states that 100% of the soy it uses is either Proterra or Europe Soya Standard certified, and it only sources from deforestation-free areas. However, it lists the Mato Grosso region as an origin of soy, which includes high-risk biomes such as the Amazon and the Cerrado. The company discloses its Brazilian suppliers as Caramuru, CJ Selecta and Bunge/Imcopa, but it is unclear if this is an exhaustive list.

The company's Code of Conduct for suppliers promotes energy-efficient and environmentally friendly technologies and requires that all third-party suppliers take steps to minimise the negative impacts on surrounding biodiversity. In the Sustainable Feed Policy, the company mentions that all soya it purchases shall not originate from areas of deforestation. It has continued to work with its Soy Protein Concentrate (SPC) suppliers, ProTerra, and the other feed companies within the Aquaculture Dialogue on sustainable soy sourcing from Brazil. This dialogue aims to further develop sustainable sourcing from Brazil by achieving more transparency through traceability tools. In 2022, Traceability Certificates of Compliance (TCCs) were issued that provide documentation of the origin and other detailed information relating to soy sourced.

In 2022, Mowi's SPC suppliers from Brazil passed an MRV (Monitoring, reporting, and verification) audit on the Proterra Foundation Monitoring and Verification Guide. Mowi discloses that the soy it sources is either Proterra or Europe Soya Standard certified, which have their own processes and actions to deal with non-compliance. It mentions that all ingredients used in the production of feed is fully traceable. Soy purchased from Brazil was 100% ProTerra certified and originated from the states of Parana, Matto Grosso, Minas Gerais and Goiás.

The company discloses that it is working towards raw material innovation. It seeks to explore various alternative feed options and includes products derived from insects, alcohol fermentation, CO2 capture and forestry. In 2022, Mowi Feed included 2.5% emerging feed raw materials in its feed composition (which includes algal oils and pea protein concentrate).

In 2022, 99% of the harvested volume was certified by at least one Global Sustainable Seafood Initiative (GSSI)-recognised standard. In total, 120 sites are ASC-certified (47% of active seawater farming facilities). The number of certified sites in Scotland and Norway increased from 9 to 21 and 77 to 79, respectively. In Canada and Chile, the number of sites with ASC certification has reduced, from 20 to 4 and from 20 to 10, respectively, but harvested protein in both regions remains 100% certified by BAP. Certifications are disclosed at regional level.

The company discloses its feed ingredients by percentage, broken down into categories but not disaggregated by species. The company states that all sourced soy is certified by Pro-Terra or the European Soy Standard, 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 37.3% of fishmeal and 16.1% of fish oil included in feed was derived from fish trimmings. Additionally, FCR, FFDRm and FFDRo have decreased at aggregate level between reporting periods. The company also discloses a Protein Conversion Ratio of 2.2 and discloses the methodology used to calculate this.

The company discloses its efforts to identify and source alternative ingredients, including collaborative research with institutes, universities and industry partners. Additionally, the company conducted a risk assessment of the soy and marine ingredient supply chain which is available in the Sustainable Salmon Feed Policy. In regard to marine ingredients, the company discloses its strategy for the responsible integration of seafood trimmings going forward as well as its justification for this strategy.

The company discloses that between 2015 and 2021, it spent 4.98 million euros on research of emerging feed ingredients including insect meal, auto and heterotrophic algae, single-cell proteins, krill and pea protein concentrate. Specifically, Mowi Feed spent 1.51 million euros and 1.15 million euros in 2021 and 2022 respectively. The company aims to achieve the inclusion of 10-15% ingredients from alternative feeds and discloses its strategy for increasing uptake in subsequent reporting periods. In 2021 and 2022, the company's feed included 4% and 3% of emerging feed raw materials in its feed composition, respectively. The company reports that its finished salmon contains 1.2g/100g of EPA and DHA. However, the metrics are not reported individually.

The company discloses the historic average sea lice count for 2018-2022, disaggregated by region. The company publishes a graph that depicts the average monthly percentage of sites above national sea lice limits for each business unit. The company reports the % of sites above national sea lice limits from 2018 to 2022. The group had 6% above national limits in 2018, 2019 and 2020, 3% in 2021 and 5% in 2022. Values for Ireland and Canada West remained at zero in 2022, whereas an increase was observed in Norway and Chile and a decrease in Scotland.

The company discloses that it is actively using cleaner fish and non-medicinal treatment systems to manage sea lice. It also discloses that it used preventive management tools like skirts, deep lights, deep feeding and a combination of these to prevent sea lice infestation. The company discloses that it is conducting R&D into clear fish husbandry but does not disclose any specific projects and does not disclose cleaner fish mortality in the reporting period.

The company discloses data on the number of escapees across all sites for at least the last three years. It discloses 146,873 escapes in 2020, 20,600 escapes in 2021, 20,600 in 2021 and 50,138 in 2022. Escape events increased from 7 in 2021 to 11 in 2022. However, the company discusses responses to the escapes in detail. The company discloses strategies aimed at reducing escape events in their operations, including simplification of anti-fouling and sea lice treatment strategies to minimise the handling and, therefore, wear of nets, improving the quality of nets and mooring points above national standards and improved training focused on escape prevention and mitigation. The company indicates a commitment to reducing fish escapes and has a target to achieve zero escapes, but the target is not time-bound.

The company acknowledges that its activities could potentially impact biodiversity. It follows all applicable rules and regulations for its sites near critical, highly sensitive environmental areas, special areas of conservation (SAC) and/or specially protected areas (SPA). The company discloses that it runs 30 projects to reduce its biodiversity impacts and conducted studies on the reproductive success of wild Atlantic cod and the migration patterns of wild trout and salmon smolts in Norway. It also participated in a project to develop a new biodiversity index and classification system of macrofauna. The company does not have a formal policy to eliminate human-wildlife conflict. However, it mentions that its primary objective is to prevent attacks by using passive control methods, such as anti-predator nets and engaging with the stakeholders, such as equipment suppliers, and global partnerships to manage wildlife interactions in the best possible way.

The company discloses that it has plankton monitoring and mitigation practices to reduce losses associated with algal blooms. In Chile, Canada, Scotland, Ireland and at-risk regions in Norway, the company uses monitoring protocols adapted to seasonal risk, ensuring that surveillance is carried out frequently during high-risk periods. The response plan also includes aeration systems, stopping surface feeding and steering the fish to safer depths using deep lights.

The company has undertaken a water quality assessment and identified three processing plants located in China, Vietnam and France, that operate in medium-high water scarcity risk locations. This accounts for 0.1% of the water used by the group classified under medium-high water scarcity risk. However, the company does not state that it only operates in areas of low water stress. In 2022, a total of 346,149 m3 (all sourced from surface water) was withdrawn for processing plants in areas with a medium-high water scarcity risk, which means 0.01% of freshwater use originates from areas with a medium-high water scarcity risk. Mowi reports its water withdrawals by source in 2022 and reports its water consumption for the same period. The company highlights various water-saving initiatives that were implemented at its processing plants.

The company has a target to achieve a reduction of 10% in water intensity at its processing plants located in medium-high water scarcity risk by 2025, using 2018 as a reference year. However, the company states this is only applicable to water withdrawals. The company's intensity of freshwater withdrawal (m3/kg produced) also reduced in 2022. However, the company target is only valid for the three plants located in medium-high water scarcity risk areas.

The company discloses its water withdrawals and consumption from different freshwater sources. It has invested in recirculating aquaculture systems (RAS) to reduce its dependency on external freshwater resources as part of its green bond. The company states that 36 million euros was allocated to water efficiency improvements from its green bond. Mowi discloses that data on freshwater withdrawal and consumption is audited by an independent third party. It did not respond to the CDP Water Questionnaire in 2022. Mowi reports a reduction in water withdrawals and water consumption in 2022.

The company asks its suppliers of vegetable feed raw materials to complete a water risk assessment so that the company can determine their full risk profile and understand the actions needed to minimize risks linked with water use. The company asks its suppliers to have a water use reduction target and encourages them to work on implementing regenerative agriculture. It states that its work towards responsible freshwater use also extends to its vegetable raw material suppliers. For those suppliers located in regions rated as medium and high risk under Mowi's water risk assessment, the company initiates an engagement programme with those specific suppliers. However, the company does not disclose the support or guidance provided by these engagements. The company also states that it established a partnership, Aquaculture Dialogue on Sustainable Soy Sourcing from Brazil, to advance sustainable sourcing of soy using the Proterra standard (which includes water management requirements).

The company states that feed water intensity was negligible reporting an intensity of 0.0006 m3/kg for the feed produced. It discloses that 5% of its feed materials are sourced from countries classified as high or extremely high stressed-water areas such as India, Romania, and Ukraine. Of this 5%, 57%, of the risk exposure comes from the purchase of guar protein followed by 30%% from soy protein concentrate. The remaining 13% stems from the purchase of soybean oil (11.7%) and small amounts of organic whole grain wheat (0.8%) and sunflower meal (0.5%).

The company discloses that 99% of production in the initial life stages of Atlantic Salmon occurs in areas with no water scarcity risk. Mowi discloses that 98.9% of its freshwater withdrawal is used for smolt production in flow-through systems and RAS. The company invests in recirculating aquaculture systems (RAS) to reduce its dependency on external freshwater resources. The company also states that modern RAS technology typically accounts for water savings of 95-99.9%.

The company is a member of the Global Sustainable Seafood Initiative (GSSI) which has a framework of essential practices a company needs to undertake to be recognised by the initiative. Within this framework is guidance on water use in animal farming operations.

The company discloses zero penalties related to wastewater discharge volumes and states that the company follows wastewater discharge limits defined by national regulations. It discloses three of its processing plants (located in Shanghai, Vietnam and Boulogne) that were classified as a high or medium water stress risk from a quality perspective. Mowi discloses a target for 100% of the waste discharged to comply with volume and quality regulatory limits. The company mentions it follows the World Bank wastewater limits when discharging wastewater directly to freshwater environments, measuring the following metrics of water quality - Chemical Oxygen Demand (COD), Biological Oxygen Demand (BOD), total nitrogen (TN) and total phosphorus (TP), where the limit is applicable to the specific geography.

The company discloses the quality of the wastewater discharged for operations in water-stressed areas. It provides data on the BOD, total phosphorus, total nitrogen and COD for each of the three sites. Mowi discloses that all the wastewater from its processing plants (1,772,570 m3) was discharged to third parties. The company also discloses that it discharged 86,510,264 m3 back into freshwater environments from its smolt production units.

The company discloses that it utilises sludge from freshwater plants to be used in biogas production or compost for use in agriculture. It discloses wastewater quality for the current year. However, the company does not disclose wastewater quality for the previous year. Therefore, a comparison can not be made. Mowi reports a reduction in the volume of wastewater discharged in 2022.

The company discloses that it is conducting water risk assessment supplier surveys to understand suppliers' risk profile for water-related risks, including protecting water bodies from pollution by agricultural activity. The Supplier Code of Conduct states that suppliers should promote environmentally friendly technologies that reduce waste and emissions and minimise the impact on biodiversity. Further, the company's Policy on sustainable salmon feed states that suppliers should aim to ensure appropriate nutrient management and eliminate runoff linked with improper fertiliser usage and storage. Mowi states that its feed suppliers are engaging in projects to improve the sustainability of feed production, including a focus on nutrient management and improved farming techniques that ensure minimum land use and improved soil health. However, these projects seem to be undertaken solely by the suppliers, and it is unclear if the company provides direct guidance and support for these projects.

The company is running multiple projects to find alternative feed ingredients that are more sustainable than the current raw materials used. It mentions that the soy protein concentrate used in feed production adheres to several requirements, which include pesticide use. The company conducts a programme of pesticide rotation to minimise the development of pest resistance and implement proper handling, storage and disposal of pesticides according to manufacturers’ instructions and legal requirements. In addition, the company applies methods that minimise harm to human health, wildlife, plant biodiversity, and water and air quality.

The company conducts a risk assessment for potential new suppliers as part of its onboarding process. It reports that 2022 environmental surveys indicated that, on average, 92% of its sea sites surveyed have a minimal impact on faunal communities and/or sediment chemistry near the fish pens. In Norway and Canada West, 100% of the sites were classified as very good or good. The company states that it uses benthic assessment, which includes MOM-B analysis to measure pH and REDOX. However, this measurement focuses on organic loading, and whether the company conducts additional inorganic tests is unclear. The company has begun using environmental modelling to identify fish farming locations with a lower benthic impact and assess its current sites. In Norway, the company has started testing new technologies to minimise organic loading by directly collecting organic waste, which is then further processed and upcycled and in Scotland, the company has begun investigating the co-farming of salmon and shellfish to examine ways to improve the productivity and environmental sustainability of marine aquaculture practices alongside trailing sea cucumbers as a seabed bioremediation tool.

The company states that it engages with local communities and has inclusive dialogues. However, the company does not disclose an engagement strategy based on nutrient pollution and environmental impacts of farms in the communities where it operates.

The company commits to a comprehensive antibiotics policy, aligning with WHO guidelines to mitigate antimicrobial resistance risks. It fosters responsible antibiotic use in aquaculture, restricting usage to specific cases determined through sensitivity results and veterinary oversight, thereby eliminating routine use for growth promotion and disease prevention. This all-encompassing policy applies across all operations. In addition, the company implements measures to decrease disease incidence in farmed salmon through plankton monitoring, upholding optimal environmental conditions, and endorsing responsible medication use and preventative strategies, inclusive of vaccination against various infections.

The company discloses a decrease in antimicrobial use for bacterial infections, from 91g per tonne in 2021 to 76g per tonne in 2022, and provides a territorial breakdown. It used only two types of medically important antimicrobials: oxytetracycline and florfenicol, in the same year. A reduction in antibiotic use was observed in Scotland and Canada, and its antimicrobial data is third-party assured by EY. However, the company reports an increase in substances used for sea lice management, from 1.65 grams per tonne in 2021 to 2.58 grams per tonne in 2022.

The company provides a statement underscoring the importance of animal welfare. The company's policy on salmon welfare, covering all farmed Atlantic salmon across diverse farm sites and countries, adopts the Five Freedoms and the definition of animal welfare by the World Organisation for Animal Health (OIE). The company emphasises creating optimal environmental conditions for fish welfare and well-being, and protocols are in place to reduce stress during handling and transport. It also insists on stringent animal welfare practices amongst suppliers and provides regular welfare training for its international workforce. The company employs percussive stunning, recognised as a humane method, for all its salmon across their farm sites and countries.

The company has a group-wide policy to maintain stocking densities at or below 25kg/m3, above the RSCPA recommendation of 17kg/m3. As well as stocking densities, the company discloses the percentage of fish with sores, wounds or lesions and overall mortality.

The company discloses that the R&D spend on environmental enrichment in 2022 was zero.

The company provides detailed information on survival rates in both seawater and freshwater environments. It discloses a monthly survival rate of 99.2% for seawater operations and between 99.1% and 99.3% for freshwater operations in the reporting period. Specific rates are provided for each country. The company discloses its incident-based mortality rate for salmon across all owned operations. In 2022, the company's incident-based mortality in total mortality was 27.9%. The company has set a target of achieving 99.5% survival in seawater and freshwater by 2025.

The company reports that 49% of the total fish lost during the year was due to infectious diseases, while the remaining 51% were lost to non-infectious reasons. Data is included in the sustainability report for the past three reporting periods, but the metrics used are inconsistent. The company states that it has a fish welfare plan focusing on ensuring good welfare practices, including disease prevention. The company also mentions that apart from medicinal and chemical-based treatments like improved biosecurity and vaccination practices, it invested in R&D and good husbandry and management practices.

The company commits in writing to support human rights as articulated by the Universal Declaration of Human Rights and the International Labour Organisation’s Core Conventions.

The company reports a continuous human rights due diligence and risk management process in which it identifies, assesses and responds to risks in its operations and supply chain. The method includes evaluating potential human rights risks, tracking, communicating findings, collaborating for remediation, and establishing policy. The company states that all suppliers have been risk assessed through due diligence and given a risk rating in the Country Risk Assessment. All critical suppliers have also been evaluated in the Mowi Risk Assessment, based on principles concerning sustainability, human rights and decent working conditions. The company continuously takes measures to mitigate human rights risks in its supply chain and operations, including employee training, tracking, analysing and auditing information, working with suppliers to address and remedy identified issues and collaborating with industry groups and legislators.

The company conducts a due diligence process in its operations as well as its supply chain. As a result, it has rated all its suppliers regarding their risk of breaching human rights, stating that none of its suppliers were rated as 'high risk'. However, the company does not explicitly disclose whether it identified any human rights risks.

The company commits in writing to prohibit discrimination, forced labour, child labour and harassment in its operations and supply chain. The company also commits to paying its employees at least the national living wage, but this policy does not extend to suppliers. The company's own operations' compliance with these policies is monitored through audits conducted by certifying bodies such as ASC, and 47% of total sites are said to be ASC-certified. The company also discloses that employees are entitled to sick pay per local insurance schemes and local laws and regulations but does not if this sick pay meets the standard of the National Minimum Wage/National Living Wage as recommended by the CIPD.

The company discloses that suppliers rated as high or medium risk by its supply chain management platform undergo a human rights audit process. However, it does not be made clear how many of its suppliers are rated as medium or high risk. Therefore, the geographic scope of these audits cannot be estimated. The company has an anonymous whistleblowing channel managed by an independent third party, PWC. This channel is open to employees and external stakeholders. However, while the company consults employees and other stakeholders on working conditions, it is unstill being determinedf the grievance mechanism was designed in consultation with these groups. The company discloses that it received 21 complaints in 2022. Eight reported incidents were related to workplace harassment, including one related to sexual harassment. In addition, three incidents were related to breaches of internal policies, six were related to possible violations of law concerning discrimination, bribery, and work time regulation, and four were related to local community complaints. All notices have been investigated and resolved.

The company commits in writing to maintain a healthy and safe working environment for all employees, contractors, and visitors. The company's operations in Ireland have ISO 45001 certifications. Furthermore, the company's production chain is certified by the Global GAP Aquaculture Standard, which sets strict occupational health and safety criteria. The company also discloses that all business units have established Safety Committees and Health and Safety Representatives. The committees have participation from both management and employees, as well as from relevant labour unions. In addition, the company discusses that the risk of antimicrobial resistance among its workforce is negligible due to its limited use of antimicrobials.

The company reports long-term injury (LTI) data measured per million hours worked as 2.3 for the group in the current reporting year. It reports an LTI figure of 2.5 for the group in the previous reporting year, demonstrating a year-on-year improvement. The company also discloses that its fatality rate has remained zero across both 2021 and 2022. In addition, it reports an overall turnover rate of 15.5% in the reporting year, which has also been disaggregated by seniority level. Blue-collar employees comprised 82% of the turnover figure, and white-collar employees comprised 18%.

The company recognises and supports its employees' right to freedom of association and collective bargaining, disclosing an unionisation rate of 17%. The company is also committed to establishing constructive dialogues with labour unions. It engages in meetings on a regular and ongoing basis, discussing current issues, long-term direction and plans, and collective bargaining agreements. The company also requires its suppliers to have a freedom of association policy for their employees and expects its suppliers to recognise its employees' right to engage in collective bargaining.

The company states that in 19 of its business units, where 73% of employees are employed, all employees are covered by collective bargaining agreements, regardless of contract type. In addition, the company gives a breakdown of its employees across contract types. It employs 10,391 permanent, 1,160 temporary, and 2,184 3rd party workers. However, despite mentioning that it uses both full-time and part-time workers, it does not disclose the distribution of full-time versus part-time employees.

The company discloses that all its sites fully comply with GFSI standards. It also provides a detailed disclosure of all the certifications held by the company's various business units, such as GlobalGAP, ASC, BRC, BAP and SQF. It provides the number of plants certified to each scheme for all locations. It does not mention that suppliers must have a GFSI-recognised certification, but it has set a target that all suppliers will obtain this. Hence, it can be assumed that GFSI certification is expected. Further, it discloses that 98% of its seafood suppliers are certified to a GFSI-recognised standard.

2022, the company conducted 377 internal food safety audits and 263 external audits. Of the external audits, 33 were related to GFSI standards. It faced six major non-conformities reported in GFSI audits related to the labelling and calibration routines on weights, insufficient handling, and missing quality system management review. All of these were closed within 30 days after the audit. Therefore, it achieved a 100% closure of corrective actions. Further, it has launched a consumer-facing traceability tool called Robotics Process Automation. Customers can receive information about the product's origin by scanning a QR on the package.

The company describes the product recall system where each business unit has its crisis team, which handles the incidents locally. This includes having defined reporting and notification groups. Food safety incidents are reported internally using the company's global incident reporting tool, and adequate mitigation actions are taken according to the severity of the incident. It had nine food safety incidents, out of which one resulted in a recall and three in withdrawal. It disclosed that the cost of food safety incidents in 2022 was reported to be 1.2 EUR million. The one memory was due to unclear allergen labelling. It carried out appropriate corrective actions, including improved training of workers via new e-learning programs, new label control inspection, and updated typing of product allergens to improve clarity for the consumer.

The company discloses that it had no market bans in the reporting year.

The company reports that the board of directors takes overall accountability and oversight of all sustainability and ESG-related risks and opportunities. In addition, the company has conducted a materiality assessment and identified 21 issues that are most material to the company. The issues include preventing fish escapes, responsible and cost-efficient sea lice management, responsible use of medicines and chemicals, efficient and sustainable fish feed, climate-friendly food production, ensuring fish health and welfare, and responsible (plastic) waste management. The board has final approval of the assessment. The company has board-level expertise in sustainability, food safety and innovation.

The company reported that the management team receives incentives based on ESG performance. For example, the Chief Sustainability Officer has 10% of variable compensation for achieving energy efficiency targets. The company engages with governments, policy officials, and industry collectives on various ESG issues like climate resilience, reduction of plastic use, good animal welfare, and ocean pollution. For example, the company is a SeaBOS member, the Seafood Business for Ocean Stewardship. Some of the initiatives and commitments from this organisation include marine plastic problems, a reduction of antimicrobials used, and climate change. Furthermore, the company discloses it engages with public policy officials and trade associations on alternative proteins, working conditions and ESG disclosure regulation. The company also discloses a list of key industry partnerships and association memberships and that its policy engagement activities are aligned to restrict global temperature to 1.5°C.

The company has a strategic approach to innovation to improve its production of sustainable, healthy, and safe seafood. Its research and development program targets the areas of fish health and welfare, feed and fish performance, food safety and product quality, environment and sustainability, and farming and processing technology. The company also discusses multiple projects for innovative farming methods. In addition, the company discloses using the Coller FAIRR Protein Producer Index, the Seafood Stewardship Index, and the Food and Agriculture Benchmark to understand its benchmarking position regarding sustainability and innovation.

The company reports it is looking into meeting an increasing consumer demand for plant-based protein products. However, it does not explicitly acknowledge protein diversification as a risk mitigation tool to ensure the resilience of the business in the medium-long term. Further, it does not disclose a timebound target to diversify protein sources.

The company has had conversations with key customers on developing new products imitating different fish products using vegetable raw materials. Consequently, it reports that vegan options have become integral to its innovation agenda. So far, its success has been predominantly in sushi, where about 10% of products are vegetable-based. However, it has not established an alternative protein brand and does not disclose that it is investing in future growth.