Nomad Foods Ltd

Nomad Foods (henceforth, Nomad) clearly acknowledges the material risks associated with Illegal, Unregulated and Unreported (IUU) fishing, overfishing, habitat conversion, and human rights, including modern slavery. The company covers this in its materiality assessment and sourcing strategy in its Sustainability Report 2024, as well as key policies such as the Supplier Code of Conduct, Human Rights Policy, and Policy on Fish and Seafood Sourcing.

Material assessment and sourcing strategy: In 2024, Nomad conducted a double materiality assessment covering impact and financial materiality in line with the European Sustainability Reporting Standards (ESRS). Within this, the company identified key impacts, risks, and opportunities across water and marine resources, biodiversity and ecosystems, workforce and supply chain working conditions, and responsible sourcing. The latter covers enhanced supply chain traceability, overfishing, bycatch, fishing methods, diversification of fish species, and human rights and labour issues.

As part of its Appetite for a Better World Sustainability Strategy, Nomad also disclosed two time-bound targets for “Better Sourcing”:

• 1. to source 100% of its fish and seafood from sustainable fishing or responsible farming, and
• 2. to source 100% of its vegetables, potatoes, fruit and herbs from sustainable agricultural practices. Nomad has reported progress against these two targets. Furthermore, within its Policy on Fish and Seafood Sourcing, Nomad underlined its use of third-party certifications (such as MSC and ASC) to validate the sustainable fisheries and seafood sourcing credentials of its supply chain.

Supplier Code of Conduct and risk monitoring: Nomad outlines its risk-based monitoring programme using the Sedex platform – this includes a requirement for all suppliers to comply with the company’s Supplier Code of Conduct. This Code of Conduct sets out the company's expectations on human rights, environmental impacts, supply chain responsibility and traceability. Nomad underlines the importance of traceability within its supply chain audits, adding that it carries out traceability exercises annually. Nomad also stated that it works actively with its suppliers to exclude any fish originating from IUU fishing, or from fish stocks that are depleted or recovering, from any of its markets.

As part of this risk-based monitoring and the Supplier Code of Conduct, suppliers are required to:

• Have fully mapped their supply chains and to be able to evidence the origin of their products.
• Register, link, and complete self-assessment questionnaires (SAQs). This information, along with country/sector data, feeds into a risk score for the supplier. This is reviewed through by Sedex “periodically” to ensure information is up-to-date.
• For sites determined as “high risk” based on previous audit results and responses within the SAQs, on-site risk assessments are conducted.
• Nomad also conducts third-party ethical audits on high-risk suppliers to ensure compliance with the company’s Supplier Code of Conduct and local laws.

In its 2024 Sustainability report, Nomad discloses an update to its audit approach from a two-year schedule to a risk-based cycle. This meant the company was able to “significantly increase” the number of audits conducted. The company also disclosed its supplier coverage:

• 95% of its tier one direct suppliers are registered and have completed the Sedex SAQ.
• 100% of its new tier one direct suppliers were screened using social criteria in 2024.
• 70% of tier one direct suppliers in the Adriatic region are registered on the Sedex platform (minimum target for project met)

Human rights: The company indicates it completed in 2024 its strategic review of its human rights programme which was initiated in 2023. This included:

• Drafting its human rights policies and standards
• Improving risk assessment processes
• Expanding its audit programme
• Exploring ways to strengthen due diligence in its upstream fish supply chain
• Scaled engagement with collaborative initiatives, such as the Seafood Ethics Action Alliance – SEAA (a human rights and ethics association focused on the seafood supply chain) to address systemic industry-wide issues.

This work is supported by the company’s prior disclosure in its Code of Business Principles (commitment to act fairly, ethically, and in line with the company’s purpose) and Statement on Modern Slavery (sets out the actions taken to evaluate, understand, and mitigate potential modern slavery risks and other risks of human rights violations).

The company also indicates its 2025 plans to roll out updated policies, standards and procedures, and pilot a human rights due diligence system and alternative human rights due-diligence processes in our upstream fish supply chain.

Palm oil and soy policies: Nomad discloses policies on palm oil and soy, linking these with feed inputs. These policies address identified material risks tied with deforestation of primary forests and associated biodiversity impacts.

Regulation: In its Annual Report 2024, Nomad underlines that “More recent sustainability regulations will require stronger links in the total supply chain on traceability”. In Europe, this may refer to the “EU Common Fisheries Policy”, updated by the revised “EU Fisheries Control Regulation” which entered into force 9 January 2024. These policies mandate digital traceability for fisheries and aquaculture through enhanced traceability tools and data reporting. These policies also align with broader food policies addressing traceability such as the EU Food Safety Regulation.

TCFD report: In 2024, Nomad released its first TCFD-aligned statement informed by a “detailed assessment engaging stakeholders to identify physical and transition risks and opportunities relevant to them”. This was conducted in partnership with South Pole, a climate consultancy. There is no evidence of an assessment aligned with the Taskforce on Nature-related Financial Disclosure (TNFD) in Nomad’s disclosures.

Overall, Nomad acknowledges the risk of IUU, overfishing, habitat conversion and human rights issues in its supply chains and has put some policies in place to address these risks, namely sourcing certified products and surveying/auditing suppliers. Nomad also requires its suppliers to have mapped their supply chains, but does not explicitly clarify the company’s integration of traceability within its policies and how it is used to identify these risks in its supply chains.

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

Nomad does not have an explicit quantitative commitment to traceability, though the company has time-bound targets linked with sustainable fishing and responsible farming. The company also discloses qualitative commitments to supplier traceability within its Code of Conduct.

In its Sustainability Report 2024, the company provides details on its target for 100% fish and seafood to come from sustainable fishing or responsible farming by the end of 2025. The company discloses its progress against this target as “on track” at 99.6%. To achieve this target, the company’s approach focuses on certifications. Within its Policy on Fish and Seafood Sourcing, the company stated that “wherever practicable and possible we only source sustainably sourced fish and seafood products captured and processed under the Marine Stewardship Council (MSC) certification and standards”. Similarly, for aquaculture sourcing, the company “expects one or more” of Global Aquaculture Alliance (GAA BAP), GLOBAL G.A.P. or Aquaculture Stewardship Council (ASC) certifications.

Furthermore, regarding feed ingredients for aquaculture products, Nomad has commitments on soy and palm oil:

• Nomad's Palm Oil Policy states that it will only purchase palm oil from sources certified by the Roundtable for Sustainable Palm Oil, which can be traced back to RSPO-certified mills.
• Nomad's Soy Policy commits the company to verifying that the soy in its supply chain (including soy used in feed) is not from deforested land (legally or illegally). The policy also states that soy should be sourced from “relevant certification schemes wherever possible". Where this is not yet possible, and soy is not 100% sustainably certified, Nomad compensates through the Roundtable on Responsible Soy credit scheme.

Furthermore, Nomad outlines its commitment to traceability for suppliers within its Supplier Code of Conduct. This Code:

• Requires suppliers of food ingredients, finished food goods, primary or secondary packaging, transport, storage and distribution services to map out their supply chains and be able to provide full details including the name and description of the party, location and country of origin/manufacture of the product for both their supplier and their supplier’s supplier(s) (if any)
• Ensures full traceability and that this material is available for inspection at any time.

In its 2024 Annual Report, the company also underlines that its facilities and suppliers’ facilities are subject to regular inspections by authorities for compliance including the traceability of genetically modified organisms, meats and other raw materials. In certain jurisdictions, food business operators, including those in the food storage, processing and distribution sectors, are required to trace all food, animal feed, and food-producing animals under their control using registration systems that track the source of the products through the supply chain.

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

Nomad does not have a stand-alone commitment to full chain, digital, and interoperable traceability, but has a commitment to sourcing certified seafood, which provides elements of traceability.

Nomad’s commitment to sourcing sustainable seafood:

• Scope: target covers 100% of seafood, including wild-caught and farmed seafood. It is not clear if the commitment covers all feed ingredients for aquaculture products.
• Depth: it is back to the fishery or farms since the commitment mandates implementing full Chain of Custody through certifications (e.g., MSC ecolabel)
• Breadth: certifications utilised by the company are complementary to the Global Dialogue on Seafood Traceability (GDST).
• Form: There is no disclosure indicating data digital and interoperable (GDST-capable).

Within its Code of Conduct, Nomad has a qualitative commitment for its suppliers to “ensure full traceability” of materials.

• Scope: qualitatively coverage of “all suppliers”.
• Depth: requests “full details” for both the supplier’s supplier, and their supplier’s supplier.
• Breadth: no mention of alignment with the GDST.
• Form: No disclosure indicating digital, or interoperable data (GDST-capable).

In 2024, Nomad shared that it maintained that 100% of its purchased volume of palm oil for in-house production was RSPO-Certified segregated.

The company also states that 100% of soy volumes (direct and indirect) are covered by Round Table of Responsible Soy (RTRS) credits. Nomad focuses its efforts on developing a holistic view of risk of forest commodities within the scope of the upcoming EU Deforestation Regulation. This includes mapping the tonnage of indirect soy within its supply chain, which was determined at 87%.

Overall, Nomad currently relies on external certifications and does not yet have a stand-alone traceability commitment for seafood or feed ingredients. While MSC- and ASC-certified seafood are verified to ensure that products from certified sources are separated from non-certified products and come from a specified fishery, this does not amount to full-chain, digital and interoperable traceability: Nomad does not have access to this traceability data (only the auditor of these certification programme has) and the data collected does not directly align with the GDST’s universal list of Key Data Elements (KDEs).

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

Given Nomad Foods does not have a commitment to traceability specifically, there is no implementation plan related to traceability. However, the company has a strategy focused on increasing the coverage of its seafood products by certifications, which provide partial traceability data.

In its 2024 Sustainability Report, Nomad disclosed its overall percentage certification coverage of purchased and sold seafood for both MSC and ASC certification, adding that, in 2025, the focus was on transitioning its remaining non-certified products to MSC- or ASC-certified alternatives.
To support its target to achieve a 100% seafood certification rate by the end of 2025, the company relies on its fish diversification strategy which focuses on three areas:

• Continuing to source wild-caught fish and seafood certified to the MSC standard
• Increasing the range of species and sourcing regions within Nomad’s portfolio,
• Increasing the use of aquaculture to enable fish and seafood to be farmed under controlled conditions in line with the ASC Farm Standard

The company is also exploring innovation partnerships aimed at developing and scaling emerging food technologies in areas including cell-cultured fish and seafood and alternative proteins such as bivalves.

Nomad shared that 10 of its markets are now 100% MSC or ASC certified, with only five (Italy, Spain, France, Switzerland and Austria) not yet at 100% as of 2024. Across these five markets, Nomad stated it has robust plans in place for the 15 products that remain to be relaunched or replaced before full certification is achieved.

Nomad also explains that squid and seafood mixes remain “the most challenging to certify“ as only three MSC-certified squid fisheries exist globally, covering just 2-3% of commercially used squid supply, but that the company will continue working to achieve its 100% certification target.

Nomad also plans “to collaborate with the MSC and other partners to encourage more fisheries and species to join the MSC programme” increasing the availability of sustainably sourced fish and seafood in the future.

Nomad also notes that, in 2024, it mapped its Adriatic supplier base to assess compliance to the company’s sustainability requirements. Since then, it launched its first MSC- and ASC-certified fish and seafood products within the company’s Adriatic Cluster, with 3.7% of its fish and seafood sales volumes now carrying either the MSC- or ASC- ecolabel. This is an improvement from previous disclosures which excluded the Adriatic business, previously noted as representing 5.5% of the total fish and seafood volume procured across the Nomad Foods’s group. While the company stated it procures around 30 species of seafood, it does not disclose which fish species sourced are from the Adriatic region.

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

Nomad’s primary efforts tied to traceability are linked with its certification strategy with time-bound and quantified commitments. Additional disclosures related to traceability exist within Nomad’s Supplier Code of Conduct and its Annual Report 2024.

Nomad reports its coverage of certifications in its 2024 Sustainability Report. Specifically, 99.6% of purchased fish and seafood volumes were MSC- or ASC-certified in 2024, and 99.3% of sales volumes were MSC or ASC eco-labelled in 2024. The company also discloses the coverage of certified products in 2022 and 2023:

• Purchased fish (MSC- or ASC-certified): 2023 – 99.5%, 2022 – 98.9%
• Sales volume (MSC or ASC eco-labelled): 2023 – 98.2% , 2022 – 96.5%

Nomad is the largest branded producer of MSC-certified and labelled fish and seafood globally.

Nomad’s Supplier Code of Conduct outlined that suppliers of food ingredients, finished food goods, primary or secondary packaging, transport, storage and distribution services are requested to map out their supply chains and be able to provide full details including name and description of the party, location and country of origin/manufacture of the product for both their supplier and their supplier’s supplier(s) (if any) to ensure full traceability and that this material is available for inspection at any time. Beyond this, there is limited disclosure on supplier traceability, nor are any specific examples provided.

Similarly, Nomad states in its 2024 Annual Report that it requires the traceability of genetically modified organisms, meats and other raw materials – however, this is linked with hygiene regulations. There is no disclosure linking this with seafood traceability.

The company highlights its “Captain’s Fish Finder Tool” which allows consumers in 11 markets to track the specific geographic regions where eight fish species were sourced. This is available in the website of its BirdsEye (UK), Findus (France), and Iglo (Germany) brands.

Beyond certifications, there is limited disclosure to provide contextual detail on Nomad’s traceability systems, nor is there evidence to suggest the company aspires to collate and disclose traceability data.

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

In its 2024 Sustainability Report, Nomad shares that it “regularly audits its supply chain to ensure high standards are upheld”. These audits assess food safety systems, hygiene standards, traceability, operational procedures, maintenance, security, training, and food fraud prevention. The company underlines traceability as an important component of its audit process, and that it carries out internal exercises on this annually. No further detail is provided on these audits, and rather than audits of existing digital traceability systems, FAIRR understands these are periodic checks on the authenticity of traceability documentation the suppliers hold in their records.

The company also provides more details on its auditing process within its Supplier Code of Conduct; specifically, the company uses a third-party ethical audits (through Sedex) based on assessment of “high-risk” suppliers identified through self-assessment questionnaires (SAQs).

Nomad highlights that all parties across its supply chain linked with its MSC or ASC certification are audited by a third-party. These certification audits are carried out by auditors approved by the Assurance Services International (ASI) accreditation body.

Nomad also provided detailed disclosure on non-compliance with its operations – this included 13 cases of non compliance with “Environment”, 30 with “Management systems”, and 5 with “Business ethics”. Despite this disclosure, there is no evidence of non-compliance explicitly linked with traceability.

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