Thai Union Group PCL

Thai Union acknowledges that the risks associated with Illegal, Unregulated, and Unreported (IUU) fishing, overfishing, habitat conversion, and human rights through various public disclosures, including its SeaChange 2030 Sustainability Strategy, its Materiality Assessment which was updated in 2024, Biodiversity Annual Progress Update (July 2025), and tailored group-level policies.

Thai Union’s SeaChange 2030 Sustainability Strategy: Through its SeaChange 2030 strategy, the company is committed to 11 interconnected goals, which include but are not limited to restoring ecosystems, safe, decent and equitable work, and responsible sourcing for wild-caught seafood, aquaculture, and agriculture. The company has mapped its goals within this strategy against the United Nations Sustainable Development Goals (UN SDGs). Importantly, the company underlines traceability within both wild catch and aquaculture, supported by quantified and time-bound targets. Furthermore, the company provides a tailored website for its SeaChange 2030 strategy which covers wild-caught seafood, aquaculture, tuna-specific traceability commitments, as well as further detail across all 11 interconnected goals.

Materiality Assessment: Thai Union discloses its approach to materiality, indicating that it conducts a double materiality assessment every two years to “identify and prioritise sustainability topics that have significant impacts”, this is supported by references to third parties such as (but not limited to) the World Economic Forum, World Business Council for Sustainable Development (WBCSD), and the UN SDGs. While the company mentions the Task Force on Climate-related Disclosure (TCFD), there is no mention of the Task Force on Nature-related Disclosure (TNFD).

The company shares its findings of this double materiality exercise within its 2024 update of the Materiality Assessment report: here, the company identifies “Supply Chain Traceability”, “Natural Ecosystem and Biodiversity Conversion”, “Responsible Sourcing”, “Human Rights, Diversity, and Land Rights” as material issues. The company highlights the significance of traceability in mitigating risks associated with human rights violations, environmental impacts, and legal non-compliance and its role in safeguarding the company's reputation, reducing legal risks, and maintaining sustainable operations. This includes details for each specific material issues that cover the “Business Case”, “Cause of Impact”, “Relevant Stakeholder”, “Positive or Negative Impact”, a ranking of identified issues, as well as “Corporate KPIs”, a timebound “Long Term Target”, and an assessment of performance against the target.

Biodiversity Annual Progress Update:
In this Annual Progress Update, Thai Union outlines its approach to assessing and mitigating biodiversity-related risks and dependencies, supporting its SeaChange® 2030 strategy and Tuna Commitment 2025. It details the company’s biodiversity assessment methodology, progress against targets, and implementation of mitigation plans, alongside collaboration with partners such as Key Traceability and the Sustainable Fisheries Partnership. The report also highlights Thai Union’s focus on traceability, including the adoption of the GDST standard across tuna and shrimp operations, and the piloting of satellite and remote sensing technologies to enhance data collection and transparency in shrimp supply chains.

The company also disclosed group-level policies that acknowledge the identified material risks. Such policies include, but are not limited to:

• The “Fishing Vessel Code of Conduct” which sets out working conditions onboard fishing vessels and the fact that they require special consideration.
• A “Policy on No Deforestation” which outlines a commitment to “zero gross deforestation” and highlights high-risk commodities such as soy and palm oil. This policy also states that all Aquaculture Stewardship Council (ASC) certified farms must conduct Biodiversity Environmental Impact Assessment and Participatory Social Impact Assessment to ensure that farm areas are not located in sensitive habitats or mangrove forests.
• A Global Ethical Recruitment Policy addressing high risk workforce employees and the “worst forms of child labor and human trafficking”.

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

Thai Union has a group-level commitment to traceability for both wild-caught and farmed seafood, disclosed in its SeaChange® 2030 strategy.

For wild-caught seafood, this commitment is:

• Sourcing 100% of its wild-caught seafood from fisheries that are demonstrably managed within biologically sustainable limits or are actively progressing through “credible improvement programmes”
• Thai Union adds that: “Full traceability, protection of endangered species and total transparency at sea are non-negotiable requirements, and we incentivize suppliers that embrace these standards”
• “100% of vessels in our supply chain to be applying best-practice measures that prevent illegal, unreported and unregulated (IUU) fishing and eliminate modern-day slavery”.

On its SeaChange website, Thai Union disclosed commitments to:

• 100% of wild-caught seafood comes from fisheries that are at sustainable levels or verifiably improving by 2030
• 100% of vessels that the company sources from will implement best practices to safeguard endangered, threatened and protected species by 2030. However, these two commitments apply to “species in Priority Group 1”, which represents “over 90%” of the total wild-capture volume of Thai Union.

For farmed seafood, Thai Union’s SeaChange commitment is:

• 100% of farmed shrimp can be traced back to the farm level (the company highlighted “Digital GDST Interoperable traceability”)

Thai Union also disclosed a species-specific commitment for tuna:

• Thai Union’s Tuna Commitment 2025 (henceforth, TC25) was first introduced in 2020, building on the 2016 pledge that at least 75% of Thai Union’s branded tuna would come from fisheries that are either Marine Stewardship Council (MSC) certified or engaged in credible Fishery Improvement Programmes (FIPs) by the end of 2020. TC25 is split into six commitments:

1. Fisheries are engaged in FIPs towards MSC certification, are in MSC assessment or are MSC certified.
2. For social responsibility, vessels meet the Thai Union Vessel Code of Conduct (VCOC) or equivalent, or are in a Vessel Improvement Plan (VIP).
3. Vessels are monitored at sea and have either human or electronic coverage.
4. Suppliers and Thai Union operations meet the International Seafood Sustainability Foundation (ISSF) conservation measures (CMs).
5. Vessels must report data, meet quota allocations and conservation measures according to Regional Fisheries Management Organizations (RFMO) resolutions.
6. Tuna is traceable to vessel (or a group of vessels) and the Global Dialogue on Seafood Traceability (GDST) Standard 1.0 is implementable

Further supporting the company’s work on tuna, Thai Union is as a signatory of The Nature Conservancy’s Tuna Transparency Pledge through which it commits to full supply-chain transparency and monitoring for tuna on vessels. This partnership entails to contribute towards electronic monitoring on vessels, supporting digital traceability and aligning with the company’s SeaChange 2030 commitment to address IUU practices.

With regards to feed ingredients for its aquaculture segment, Thai Union has a commitment to:

• 100% of shrimp feed used in shrimp products supplied to Thai Union is produced responsibly by 2030.
• Thai Union plans to publish an updated group-level deforestation policy in 2025. This will build upon Thai Union’s previous 2021 “Policy on No Deforestation” which formally commits Thai Union to zero gross deforestation and aims by 2030 to ensure no deforestation throughout its supply chain.

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

In the SeaChange® 2030 strategy, Thai Union outlines its commitment towards traceability for both wild-caught and farmed seafood to be achieved by 2030. Furthermore, the company reports on its Tuna Commitment 2025 in disclosures.

The traceability commitment contained in Thai Union’s SeaChange Strategy addressing wild-caught seafood:

• Scope: covers species in “priority group 1”, with no further information as to what the other priority groups may be.
• Depth: states “full traceability”, therefore it appears to be back to the vessel.
• Breadth: is not explicitly aligned with the GDST.
• Form: time-bound (2030), however, it is not digital nor interoperable.

The traceability commitment contained in Thai Union’s SeaChange Strategy addressing aquaculture:

• Scope: covers 100% of shrimp, which represents the main species farmed by Thai Union.
• Depth: states that shrimp can be traced back to the farm level.
• Breadth: explicitly references the GDST.
• Form: time-bound (2030), digital, and interoperable.

The company also has its Tuna Commitment 2025, which it highlighted as being achieved now:

• Scope: covers 100% of tuna.
• Depth: states that tuna must be traceable to the vessel.
• Breadth: indicated that the GDST Standard 1.0 is implementable.
• Form: time-bound, digital, and interoperable (GDST Standard 1.0 is implementable).

Overall, it is unclear whether Thai Union’s SeaChange® 2030 strategy commitments to traceability for all wild-caught and aquaculture seafood have been reduced to “priority species” and tuna for wild-caught seafood, and shrimp for aquaculture. Thai Union should consider disclosing a breakdown of its overall seafood business by species. Furthermore, there is a lack of clarity on whether Thai Union’s commitment to responsible sourcing of aquaculture feed ingredients has been reduced to shrimp feed only, or whether it still covers all aquaculture feed ingredients (marine and terrestrial).

The company has shared that it is “continuing to benchmark, standardize and integrate the required Key Data Elements (KDEs) for every Critical Tracking Event (CTE)” across the rest of its supply chain, so that “GDST compliant traceability becomes the operational norm for all Thai Union tuna products”. However, there is no disclosure explicitly linking the GDST with any species beyond tuna.

The company also has a specific code of conduct for its fishing vessels and an associated commitment to human or digital monitoring on all vessels by 2025. This includes disclosures indicating the percentage volume from suppliers covered either by Vessel Improvement Programme or TU Vessel Code of Conduct audit, or equivalent.

Regarding certifications, the company indicates that all processing facilities (for tuna) hold Marine Stewardship Council (MSC) Chain of Custody certification, and that it is progressing towards 100% tuna sourcing from MSC-certified or FIP-verified fisheries. Thai Union states that 99% of tuna fisheries that it sources from are engaged in FIPs towards MSC certification, are in MSC assessment or are MSC certified. The company also highlights that its subsidiary Thai Union Feed Mill obtained the ASC certification, though there is no formal quantified and timebound target to expand this.

For aquaculture, under its “Action Plan”, Thai Union highlights the use of certified feed (ASC / BAP / on the path to credible certification through an Aquaculture Improvement Project), ensuring marine feed ingredients are sourced from responsibly managed fisheries, and that terrestrial feed ingredients originate from deforestation- and conversion-free sources.

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

For its SeaChange® 2030 strategy commitments, Thai Union does not disclose the interim or key milestones to be achieved ahead of 2030. During the call with investors and FAIRR in Phase 1 of this engagement, Thai Union confirmed that it has internal milestones in place, and it will consider disclosing this information.

Thai Union outlined that it has pledged US $200 million to implement its SeaChange 2030 strategy, though there is limited public information breaking down this total budget.

In addition to this budget, in May 2025, Thai Union secured a US $150 million Blue Loan – a first-of-its-kind type of financing for the seafood sector in Thailand – provided by the Asian Development Bank, alongside commercial co-financiers. This Blue Loan is explicitly tied to Thai Union’s SeaChange® 2030 strategy, aimed at scaling sustainable shrimp procurement and advancing net zero greenhouse gas ambition. Publications from the Asian Development Bank note that the financing will contribute towards “working capital requirements for procurement, processing, and exports of sustainable shrimp and support operating expenses for extension services such as training, certification support, research and development, and sustainability pilot projects”.

For tuna, Thai Union has published a Tuna Commitment 2021 Progress Report, but this document does not disclose key milestones achieved on traceability. However, the company provides a progress update for Commitment 1 (“Fisheries are engaged in FIPs towards MSC certification, are in MSC assessment or are MSC certified”) on its SeaChange 2030 website platform.

Regarding its Tuna Commitment specifically, Thai Union highlights its willingness to align its traceability data to the GDST standards, however, work is still underway to do so: “The next step is full alignment with the Global Dialogue on Seafood Traceability (GDST) standard - an objective Thai Union actively champions as a member of the GDST Board of Directors. A second external audit completed in 2024 found that the key data we need to comply with GDST’s requirements are now available across our systems. The challenge ahead lies in mapping those data to the precise GDST format. Work is therefore continuing to benchmark, standardize and integrate the required Key Data Elements (KDEs) for every Critical Tracking Event (CTE) across the rest of our supply chain, so that GDST-compliant traceability becomes the operational norm for all Thai Union tuna products”.

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

Regarding wild-caught seafood, in its latest Sustainability Report, Thai Union discloses progress against the six commitments part of the company’s broader Tuna Commitment 2025. Regarding traceability specifically, the company states that “100% traceability” has been achieved. However, reading the report in more details, it appears that not all data is yet GDST-aligned: “The next step is full alignment with the Global Dialogue on Seafood Traceability (GDST) standard - an objective Thai Union actively champions as a member of the GDST Board of Directors. A second external audit completed in 2024 found that the key data we need to comply with GDST’s requirements are now available across our systems. The challenge ahead lies in mapping those data to the precise GDST format. Work is therefore continuing to benchmark, standardize and integrate the required Key Data Elements (KDEs) for every Critical Tracking Event (CTE) across the rest of our supply chain, so that GDST-compliant traceability becomes the operational norm for all Thai Union tuna products”.

Thai Union is a founding member of the International Seafood Sustainability Foundation. As part of the ISSF 2023–2027 Strategic Plan, Thai Union commits to sourcing only from fisheries that can meet and maintain the MSC standard by the end of 2027. The company has disclosed clear milestones for its purchasing of MSC-certified tuna from 2024 to 2027. In 2024, the company reported metrics on fisheries with MSC certification (92%), under FIPs (3.5%), under the MSC assessment (1.4%), and “none” (3.1%).

Regarding farmed seafood, Thai Union reports to have achieved 100% paper-based traceability for all farmed shrimp traced back to the farm level. However, 0% is achieved for GDST-aligned digital and interoperable traceability. This reporting is limited to farmed shrimp, and the company does not report progress on its wider commitment to traceability of all aquaculture and feed ingredients.

Regarding the wider commitments included in the SeaChange strategy, the overall scope of Thai Union’s seafood business covered by traceability systems, or its alignment with GDST standards is not yet disclosed.

During the call with investors and FAIRR in Phase 2 of this engagement, Thai Union shared that the company has traceability data for species in its Priority Group 1 (beyond tuna and shrimp) and that it will consider disclosing such data in the future.

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

While progress towards the TC25 tuna commitment is annually verified by the external consultancy Key Traceability, third-party verification is not discussed as part of the company’s wider SeaChange® 2030 strategy commitments, which cover other species and feed ingredients. While the company outlined measures in place to address non-compliance (as seen in the Code of Conduct) , cases of non-compliance are not disclosed.

Thai Union has obtained both MSC and ASC certification within its operations, requiring an audit from a third-party, though no detail on these audits are provided.

The company also highlighted that its tuna suppliers are subject to audits associated with International Seafood Sustainability Foundation (ISSF)’s Conservation Measures, adding that “in practice, this means giving preference to vessels listed on the ISSF Proactive Vessel Register (PVR) and improving transparency”. The company highlights that 94% of its tuna supply came from vessels listed on the PVR, with large-scale purse seiners all listed on the PVR and 94% of the tuna from longliners.

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