Tuna in theBlack Box
Human rights risks hidden in the opaque tuna supply chain
from Korean fishing vessels to the Japanese market

1List of Contents
Executive Summary

5

IV.

Efforts in Japan, and Their Limitations

49

1. Government: tuna import procedures

I.

Introduction

II.

Tuna Supply Chain: from the Pacific Ocean to Japan’sMarket9V.
11

2. Corporations: voluntary efforts

53

3. Limitations of government and corporate actions

62

Recommendations: To prevent human rights violations
in DWF and to provide remedies for victims
65
1. To the Korean government

1. Tuna, the star of Korean DWF

11

2. To the Japanese government

66

a. How tuna is harvested by South Korea’s DWF

14

3. For Japanese corporations importing seafood

67

b. Tuna exports to Japan18

4. To the Regional Fisheries Management Organizations

68

2. Japan, the world’s largest tuna market

20

a. Tuna production and consumption trends in Japan
3. Supply chain from South Korea to Japan22

a. From the Pacifics to Japan, and transhipment in between

III.

b. Major Korean corporations in tuna export

29c. Major corporations in Japanese tuna distribution

32

Human Rights Risks in South Korea’s DWF Industry

35

1. Defining of forced labor and human trafficking

35

a. Forced laborb. Human trafficking

37

2. Forced labor and human trafficking on South Korea’s DWF vessels

38

3. Limitations of the government’s actions

44

a. 2021 Ministry of Ocean and Fisheries “Implementation Plan”
b. 2022 Act on Prevention of Human Trafficking, etc., and Protection of Victims

2

47

3

Executive SummarySouth Korea's distant water fishing is the fourth largest in the world, operating primarily in the Pacific.
More than half of these vessels are tuna longliners, which catch tuna by having hooks to long lines
and letting them hang over the surface of the water. Tuna longliners mainly catch yellowfin, bigeye
and bluefin tuna, which are mainly supplied to the market as "sashimi tuna". Japan is the largest
importer of tuna caught by Korean longline vessels. Japan's dependence on imported seafood has
been steadily increasing as the number of workers on fishing vessels has been decreasing due to a
declining labor force and shunning of the fishing industry. In addition to South Korea, Japan imports
sashimi tuna from Taiwan, China and Australia.
However, the supply chain for tuna caught by Korean longliners reaching the Japanese market ishighly complicated and lacks transparency. Korean longliners operate on the high seas and in the
EEZs of Pacific Island countries, where more than half of the tuna harvested is transhipped directlyfrom the sea to carrier vessels for export to Japan. This practice is prohibited in principle by the
Regional Fisheries Management Organizations for tuna due to the high likelihood of mixing catchesfrom different vessels on board and the near-impossibility of inspection. However, in the Pacifics,
where Korean tuna longliners primarily fish, transhipment at sea is a common practice. The Regional
Fisheries Management Organizations are to receive and manage information on transhipment,
but such information is not disclosed to the public. The Korean government has also refused todisclose the relevant information upon request by the civil society. Hence, the supply chain of tunatranshipped at sea to the Japanese market remains opaque.
The already opaque and complex supply chain of tuna continues to be so within the domestic market
in Japan. Trading companies play an increasingly important role in the import and distribution of tuna
non-transparently in Japan, yet they process, transport, and distribute tuna using their own carrier
vessels and domestic and international processing facilities, which are not publicly recorded, making
it difficult to access relevant information or ensure that labor-safe and labor-risky tuna are not mixed.
On the other hand, Japan requires importers of tuna to submit a certificate that guarantees thatno illegal fishing has occurred during fishing based on the law for implementing Conservation andManagement Measures of Regional Fisheries Management Organizations. Nonetheless, this does notinclude information related to human rights violations such as forced labor and human trafficking.

Tsukiji FIsh Market in Tokyo, Japan © Shutterstock

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The risk of forced labor and human trafficking is significantly high on Korean longline vessels, which is

Meanwhile, the Japanese government released the Supply Chain Human Rights Due Diligencethe main source of sashimi tuna for Japan. Most of the workers on Korean longline vessels are migrant

Guidelines in 2022, encouraging companies to voluntarily identify, and take measures to address

workers, who seek employment amidst vulnerabilities such as poverty and lack of education in their

human rights risks in their supply chains. However, when analyzing the human rights due diligence

home countries. Hence, migrant workers easily become targets of manipulation and exploitation. With

policies and practices of major companies that import and distribute tuna in Japan, the results

no or very little income in their home countries, they rely on promises of brokers to find them goodwere discouraging. None of the companies involved in the distribution of tuna in Japan disclosed

jobs. They are subject to labor exploitation on distant water fishing vessels with no regulation on

their supply chains, and while some have fisheries-specific human rights due diligence policies andworking hours, working longer than 12 hours yet earning one-tenth of the wages of Korean fishers. In

tuna-related procurement guidelines, there was no available information on how such policies wereaddition to the excessively long working hours, underpayment of wages and physical and verbal abuse

implemented in practice. For example, a leading Japanese trading company stated that it ensures

are also prevalent. However, they are unable to leave their jobs due to passport confiscation andhuman rights protection through "dialogues" in its supply chain, but failed to identify and address

deposits that cannot be returned unless their contracts are fulfilled, rendering their circumstancesin advance human rights abuses on the distant water fishing vessels from which it sourced its fish,

equivalent to forced labor or trafficking. In particular, tuna longliners are at greater risk of forced laborhighlighting the limitation of its systems and policies. The human rights due diligence policies ofand human trafficking than other distant water fishing vessels because they work and sail for longer

companies in Japan's tuna supply chain are insufficient to identify and address the risks of humanperiods.

trafficking and forced labor in the supply chain.

To address the issues of forced labor and human trafficking in South Korea's distant water fisheries,

The complex supply chain that stretches from the Pacific to South Korean fishing vessels and then to

the South Korean government announced a plan in 2020 which entailed paying migrant workers

Japanese ports and markets conceal human trafficking and forced labor in the fishing of tuna. States,

at least the minimum wages set by the International Transport Workers' Federation, ensuring thatinternational organizations, and corporations all have a role to play in addressing such transnational

they receive their full wages without any deduction, establishing minimum rest periods, preventing

human rights abuses. The South Korean government should ratify the Work in Fishing Convention

excessively long sail without entering port, and distributing bottled water without discrimination.

(2007) C188, and take steps to combat human trafficking and forced labor in the distant water fishing

However, interviews with migrant workers who worked on Korean distant water fishing vessels

industry by adopting measures such as correcting the customary practice of illegal wage deduction

revealed that the government's measures have not been fully implemented. On the other hand,

and recruitment fees by ensuring public entities' management over the recruitment process. The

although South Korea has enacted the "Act on Protection of Victims and Prevention of Human

Japanese government should ensure traceability and transparency in the supply chain of tuna, asTrafficking, etc.", its practical value appears dire as there is no system in place to identify and support

well as seafood at large, and establish a legal framework for companies to proactively establish andthe migrant workers in the distant water fisheries as victims of human trafficking. Therefore, tuna

implement human rights due diligence policies in their chains and publicly release their results. In

caught by Korean longline vessels entails high risk of human trafficking and forced labor.

particular, imports of seafood should be banned not only in case of illegal fishing, but also in casesof human rights violations against fishers in the supply chain. Japanese seafood importers should
also be required to disclose their supply chains transparently, and enable fishers to access effective
grievance mechanisms and remedy measures. Finally, to address labor and human rights violations
against fishers which occur transnationally, the Regional Fisheries Management Organizations needto establish binding measures on labor standards, and increase the transparency of transhipment at
sea which complicates and covers up the supply chain by closely monitoring and publicly disclosing
transhipment occurrences. Only when various stakeholders work together will the tuna supply chain
be free of human rights abuses and illegal fishing.

67

I. Introduction

According to the International Labor Organization (ILO), fishing is a classic 3D (Dirty, Dangerous,and Difficult) industry, and one of the most dangerous in the world. This is particularly true whenit comes to distant water fishing (“DWF”), which is not only far from land but also crosses multiple
jurisdictions on the high seas and in exclusive economic zones (“EEZ”), making it extremely difficult
to regulate. Meanwhile, the vast majority of workers on DWF vessels are not nationals, but migrants
who are seeking labor due to difficulties in finding jobs in their home countries. Migrants, alreadyvulnerable due to poverty in their countries of origin, have no choice but to accept the unreasonableconditions offered to them during the recruitment process, and are exploited on the fishing boats formeager wage in harsh working conditions. This puts migrant workers on these boats in a situation of
not only labor exploitation, but also forced labor and human trafficking. The seafood produced is thenprocessed and distributed across borders to reach consumer countries, spreading the risk of forcedlabor and human trafficking throughout the supply chain.
However, the supply chain for seafood harvested from DWF vessels is complicated and challenging
to trace, making it difficult for consumers to determine the exact "country of origin”. Complex andopaque supply chains act as a veil to hide human rights abuses in the supply chain. While many
countries have laws in place to combat forced labor and human trafficking, no country has shown
the will to properly investigate and prosecute human rights abuses that occur on the high seas andin and out of coastal states. Corporations also have a responsibility to identify and address humanrights abuses that occur beyond their own operations and throughout their supply chains, but these
responsibilities remain as declaratory guidelines in most countries. As a result, consumers who buy
cleanly packaged, wild-caught seafood at the supermarket are likely to be buying seafood tainted byforced labor and human trafficking.

Auction in Tsukiji fish Market in Tokyo, Japan © Shutterstock

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Tuna is the largest harvest and export product of the Korean DWF industry. Vast majority of the tuna,especially high-grade tuna for sashimi, is mainly exported to Japan. This report aims to highlight 1)
the significant human rights risks in the supply chain of Korean tuna exported to Japan, and 2) the
responsibilities of the Korean and Japanese governments and companies involved in the supply

II. Tuna Supply Chain:from the Pacific Ocean to Japan’s Market

chain. Chapter 2 analyzes the characteristics and scale of the tuna industry in South Korea andJapan, as well as the supply chain of Korean tuna in the Japanese market. Chapter 3 reveals thatlabor exploitation against migrant workers in the Korean DWF industry constitutes human trafficking
and forced labor, and that these abuses continue to occur despite government measures. Chapter
4 examines the efforts and limitations of transparency measures in seafood supply chains in Japanas a consumer-country. Lastly, Chapter 5 concludes with recommendations for governments,

1. Tuna, the star of Korean DWF

corporations and the Regional Fisheries Management Organizations to ensure the human rights to be

The DWF industry is concentrated in a handful of countries around the world. With a total of 209

respected throughout the supply chain of the tuna.

vessels, the number of South Korea's DWF vessels is the fourth largest in the world.1 Their main fishingareas are the East Central Pacific (73 vessels), West Central Pacific (52), Atlantic Ocean (51), NorthWest Pacific (18), and other waters (15). As of the end of 2021, the Korean DWF vessels consist oftuna longliners, low longliners, tuna purse seine, DWF net, DWF trawl, and squid jig vessels, with tuna
longliners accounting for 52.2% (109 vessels) of the total 209 vessels.2 Tuna longliners mainly catchyellowfin tuna, bigeye tuna, and bluefin tuna, which are distributed as sashimi-grade tuna.

Pacific fresh tuna in a fishing storage facility in Osaka, Japan © Shutterstock

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11

Figure 1. Fishing methods of DWF vessels
Tuna longline

Type of tuna caught in DWF
Thunnini, widely referred to as tuna, is an ectomorphic species in the mackerel family. Tuna is widelydistributed throughout the five oceans in subtropical and temperate waters south and north of the

In order to catch multiple fish at once, several fishing lines areequator. Because they migrate to higher latitudes in early summer and return to lower latitudes in lateattached to the main line at regular intervals, with one hookfall, their fishing grounds are widely distributed throughout the Pacific and Atlantic oceans. There

attached to each line and placed horizontally.

are mainly seven species of commercial tuna that are harvested by Korean DWF: skipjack, albacore,bigeye, yellowfin, Atlantic bluefin, Southern bluefin, and Pacific bluefin. Skipjack, albacore, andTuna purse seine

yellowfin tuna are primarily processed into canned tuna, while bigeye and bluefin tuna are primarily

A long, square net is used to surround and trap fish, then tighten

supplied as premium tuna for sashimi.

the straps across the footrope to prevent the fish from escaping
under the net and narrow the envelope to capture the target
creature.
Squid jigs

Table 1: Types of commercial tuna4
No

A multi-hook composite fishing line is dropped vertically into
the water floor where squids are distributed, and then quickly1

reeled upward to catch the squids.

Trawl

2

A pouch-shaped net is dragged horizontally for an arbitraryamount of time to catch the target.
3

Stick-held deep net
A fishing gear with a moxibustion or stretching rod attached4

to one chord of the boat is placed. Fish are drawn between theboat and the gear, and the line is pulled to catch them.
5

Photo

Japanese
クロマグロ
Kuro maguro
ミナミマグロ
Minami maguro
メバチマグロMebachi maguro
キハダマグロKihada maguro
ビンナガ
Binnaga

KoreanEnglish참다랑어

Bluefin tuna남방참다랑어Southern bluefin tuna눈다랑어

Bigeye tuna황다랑어Yellowfin tuna날개다랑어

Albacore가다랑어

Skipjack

Source: National Institute of Fisheries Science3
6

12

カツオ
Katsuo13

a. How tuna is harvested by South Korea’s DWF

Figure 2: Characteristics of tuna longline vessels

Premium tuna caught by tuna longliners in the Pacifics
By the end of 2021, there were 109 tuna longline fleets in South Korea, primarily fishing in the Pacific
Ocean for bluefin tuna, bigeye tuna, and some yellowfin tuna for export as high-end sashimi tuna. The
main operators are Sajo Industries (40 vessels), Dongwon Industries (16 vessels), Dongwon Fisheries(14 vessels), and Silla Trading (9 vessels), accounting for 72% of the South Korean tuna longline
fleets.

Table 2 : Major tuna longliner operation companies in Korea
Company Fleets

Sajo5

40

Fishing Waters

Catch Species

Central Pacific Ocean, Indian Ocean,

Sashimi tuna

Atlantic Ocean, Southern Indian Ocean(bluefin, bigeye, yellowfin, etc.)

Source: International Seafood Sustainability Foundation10

Tuna longline fishing is accomplished by attaching thousands of hooks and baits to a single long line,
DongwonIndustries

6

16

South Pacific Ocean, Indian Ocean

Sashimi tuna

as shown above, and releasing it on the surface of the water to attract fish to the bait. The longlines(bluefin, yellowfin)

on the surface inevitably catch other sea creatures in addition to the target species, resulting in
bycatch. Longline fishing is known to be one of the most bycatch-prone commercial fishing methods

DongwonFisheries

Silla87

14

9

Pacific Ocean, Southern Indian Ocean

South Pacific Ocean

Sashimi tuna
(bluefin tuna, bigeye tuna, etc.)
Sashimi tuna
(bluefin, bigeye, yellowfin)

in existence.11 Sharks are a common bycatch from longline vessels, and it has been reported that
separate fishing gear is sometimes used to intentionally catch sharks on tuna longlines.12 Fishing lines
on longliners can be as long as 150 kilometers and contain more than 3,000 hooks, which has also
been criticized for encouraging bycatch and overfishing.13
Human rights of the workers on longline vessels are also vulnerable due to their prolonged stays atsea. While DWF vessels make periodic stops to refuel and store their catch, longliners have been

As of 2021, all 209 metric tons of bluefin tuna caught by Korean DWF vessels were caught by longline

known to sail for as long as two years without stopping at port. Long voyages without port entry leave

vessels, and 18,216 metric tons, or 79%, of the 23,066 metric tons of bigeye tuna were caught byfishers physically isolated at sea, and increase the risk of illegal fishing and forced labor due to a lack

longline vessels. In addition, a total of 60,237 tons of yellowfin tuna were caught, of which 10,945

of oversight.14

tons, or 18%, are estimated to have been caught by longline vessels and used as sashimi-grade tuna.9
As of 2021, the number of fishers working on tuna longliners was 2,500. Given that 78%, or 2,797 of the
3,578 fishers on South Korean DWF vessels in 2021, were migrant fishers from Indonesia and Vietnam,15
it is likely that a significant number of workers on tuna longliners are also migrant workers.

14

15

IUU, forced labor, and human trafficking
IUU fishing refers to illegal, unreported and unregulated fishing. In Korea, IUU fishing isdefined as unauthorized fishing or fishing activities conducted in violation of relevant
domestic and international laws and obligations, fishing activities that are not reported
or falsely reported to the relevant country or the regional fisheries management
organizations (“RFMOs”), and fishing activities using stateless fishing vessels on the highseas or in waters under the jurisdiction of RFMOs.16
South Korea has a history of being designated as an IUU fishing country by the UnitedStates and the European Union. In 2013, South Korea was designated as an IUU fishingstate by the U.S because the government refused to designate a DWF vessel as an IUUvessel in violation of a RFMO’s Conservation and Management Measure (“CMM”), and also
opposed the RFMO’s designation of the said vessel as an IUU vessel.17 South Korea has also
been designated as a prospective-IUU fishing state by the EU for failing to take adequate
measures against IUU fishing by South Korean DWF vessels in the West African region
between 2010 and 2012, despite multiple detections of IUU fishing.18
The definition of IUU fishing includes activities that violate national laws or international
obligations. Therefore, forced labor and human trafficking, prohibited by international
conventions, can be considered IUU fishing by themselves. In addition, the prevalenceof at-sea transhipment and “flags of convenience” in DWF undermines traceability andtransparency, increasing the likelihood of IUU fishing and human rights violations. Atsea transhipment allows vessels to stay at sea longer and fish without port calls, which
effectively prevents labor authorities from intervening.19
On the other hand, the depletion of fish stocks due to the proliferation of IUU fishing is
forcing the fishing industry to work harder than ever before in order to secure similar or
lower levels of catch. For example, the number of longline hooks set in WCPF Convention
waters increased from approximately 500 million in the early 2000s to approximately 800
million in the 2010s, indicating a significant increase in fishing effort. 20 The increased
operational costs associated with this heightened fishing effort leads to exploitation of
low-wage workers.21

Japanese longliner © Shutterstock

16

17

b. Tuna exports to Japan

Sashimi tuna is of particular importance among the types of tuna exported to Japan. As of 2021, ofJapan is the largest importer of sashimi-grade tuna caught by Korean tuna longliners. According to
the most recent data, 41 percent of all sashimi-grade tuna from Korean vessels is exported to Japan,
and 87 percent of the value of sashimi-grade tuna exports is generated from the Japanese market.22

the 7,600 tons of tuna exported to Japan, 2,354 tons were sashimi-grade tuna, accounting for 31% of
the total, and sashimi-grade tuna’s export value was KRW 306.72 million out of KRW 923.63 million,
accounting for 33%. According to the KOFA (Korea Overseas Fisheries Association), Japan is thelargest importer of Korean sashimi-grade tuna, with 40 percent of the total export volume going toJapan.24

Figure 3: Sashimi tuna exports from South Korea in 2021 (per country ratio)
Figure 5: Tuna export from South Korea to Japan in 2021 (per species ratio)
Skipjack
Misc.

Yellowfin

BigeyeAtlantic bluefin
Japanphilippines

AlbacoreSouthern bluefin

Thailand
MexicoChina

VietnamEquador

Spain

Misc.

Sashimi tuna exports from South Korea

Tuna export from South Korea to Japan

Figure 4: Export value of sashimi tuna from South Korea in 2021 (per country ratio)

Figure 6: Export value of tuna from South Korea to Japan in 2021

Misc.

Skipjack

Thailand

BigeyeChina

Atlantic bluefin

Yellowfin
Albacore

VietnamSouthern bluefin

Misc.

Japan

Export value of sashimi tuna from South Korea

Source: Korean Overseas Fisheries Association (KOSFA), Exports by Type 23

18

Export value of tuna from South Korea to Japan

Source: KOSFA, Exports by Country 25

19

2. Japan, the world's largest tuna market
a. Tuna production and consumption trends in Japan
Since 1961, Japan has been one of the top five seafood consuming-states in the world.26 In 2018,
Japan was the largest consumer of seafood after China, Myanmar, and Vietnam, and ranked sixth in
the world in per capita seafood consumption in 2020.27 In the case of bluefin tuna, which Japanese
consumers eat for sushi and sashimi, Japan consumes more than 80% of the global catch.28
However, due to a declining labor force and a shunning of the fishing industry, the number of Japanese
workers in fisheries has continued to decline, resulting in a significant drop in domestic production.
The total number of fishing vessels in Japan fell from 213,000 in 2003 to 132,000 in 2018. The numberof fishers has also decreased by 53.3% over the past 25 years to 151,701 in 2018,29 with the proportionof elderly and migrant workers increasing, which raised concerns about labor exploitation.30 Japan's
tuna production has long been one of the highest in the world, reaching 209,000 tons in 2012, but
by 2021, production had dropped by 32% to 142,000 tons.31 However, bluefin tuna production isincreasing through aquaculture.32
As a result, Japan's dependence on imports of bluefin and bigeye tuna for sushi and sashimi has
been steadily increasing. According to one statistic, import dependence for sashimi tuna is as highas 60%.33 As of 2021, Taiwan accounted for 19.5% of Japan's tuna imports, followed by China at 13%
and South Korea at 10.7%. Of these, imports of bluefin tuna and bigeye tuna, both of which are used
for sashimi, were from the following countries: Taiwan (47%), China (14%), Australia (13%), theSeychelles (11%), and South Korea (6%).

Sea food shop at Tsukiji market, Tokyo, Japan © Shutterstock20

21

3. Supply chain from South Korea to JapanFor sashimi tuna for which freshness is critical, it is common for the fish to be transhipped at-sea by
carrier vessels from the fishing vessels, and then directly exported to Japan.35 As of 2021, 1,964 tons,
or 55%, of South Korea's 3,563 tons of sashimi-grade tuna exports to Japan were reported to havea. From the Pacifics to Japan, and transhipment in between

been exported directly from the high seas.36 For bluefin tuna in particular, all of the 1,246 tons caught
in the Indian Ocean in 2021 were exported to Japan,37 of which 1,078 tons, or 86%, were transhipped

Figure 7: Supply chain of sashimi tuna from Korean DWF to Japanese market

EEZ/
High SeaKR

in the high seas. Meanwhile, only 0.02% of non-sashimi tuna (total 738 tons), such as skipjack andalbacore, were directly exported from the high seas.

JP

When directly exported upon high sea transhipment, the export of sashimi tuna is declared
through the KOFA to the Seoul customs only upon the fact of export. As such, it is difficult toverify the declared export volume and products. For example, according to the Commission for theConservation of Southern Bluefin Tuna (CCSBT), of the 1,226 tons of southern bluefin tuna caught

Transshipby Korean longliners in 2020-2021, 725 tons, or 59%, were caught on the high seas, but only 4% of thetotal export volume of southern bluefin tuna was subject to export inspection.38

DWF (KR-flagged)

Processing
Transship

Buyer(Trading companies)

MarketIn general, tuna is fished on the high seas and their neighboring countries’ EEZs(Exclusive EconomicZone). After harvesting, it is processed and frozen on board of the vessel before being transshipped toa carrier, or entering Korea through the fishing vessel. If the catch is to be transhipped, an application
for a transhipment permit must be made to the head of the East Sea Fisheries Management Service,upon which the head of the Service will first review the legality of the vessels’ fishing, as well as
relevant transhipment measures within the RFMOs’ CMMs, and then issue a transhipment permit.34
Transhipped products are either carried into Korean ports, or directly exported from the high seas todesignated destinations. If the products enter Korean ports, then inspection on legality of the fishing
can occur via port control upon arrival declaration. However, if the products are exported directly fromthe high seas, then no port control or inspection can occur.

Transhipment of tuna © Shutterstock

22

23
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The dangers of transhipment in DWF

Under the regulations of RFMOs, longliners are required to report to the flag state information on

Transhipment refers to the transfer of catch or marine life from a fishing vessel to a carrier vessel.

the catch they intend to tranship (fishing location, species, quantity, etc.) and information on theTranshipment can take place at sea or at port. Each year, thousands of fishing vessels transhiptranshipment (date, time, location, carrier vessel information, etc.) before and after the transhipment.

tuna, mackerel, squid, crab, and other fish caught in the distant waters to refrigerated cargo ships

The flag state of the longline vessel is obliged to submit the collected information to the secretariat ofcalled "carrier vessels" or "reefers," which then transport the catch to ports for processing. Shipping

the concerned RFMOs annually, but it is difficult to review the accuracy of the collected information.

companies prefer transhipment at sea to save time and money that would be incurred from trips to

In practice, there have been reports of discrepancies between the location data of fishing vessels

39

port, and to increase the freshness and value of their catch. However, transhipment increases thesuspected to have transhipped at-sea and the information disclosed by the RFMOs.44 The CCSBT has

number of actors involved in the supply chain, convoluting the supply chain. It also increases thealso noted that a significant number of at-sea transhipments are unreported and illegal.45

likelihood of catch from different vessels being mixed within the carrier vessels, which makes theverification of legality much more difficult.40

In addition, the RFMOs do not disclose all the information related to transhipment at-sea, so it is very
difficult to obtain information on the occurrence. APIL has made a Freedom of Information request

Particularly in the case of transhipment at sea, difficulties in monitoring frequently lead to non- or

to the South Korean government for information on reports of transhipment by species submittedfalse reporting of catches. It has also been criticized for allowing fishing vessels to stay at sea longer,

to the RFMOs, but the The Korean government refused to disclose the information on reports ofincreasing the risk of illegal fishing and human rights abuses. This has led to campaigns calling fortranshipment by species submitted to the RFMOs.46 Hence, there is a concerning lack of transparency

retailers to ban transhipment as a rule within their seafood supply chain policies.41

in information related to transhipment that occurs in the high seas.

In response to these issues, RFMOs have regulations prohibiting, or requiring prior notification

In addition to the uncertainty of publicly available information, the failure of the RFMO’s in disclosingof, transhipment at sea. The tuna RFMOs that Korea has joined all prohibit at-sea transhipment

information related to transhipment at-sea has been widely challenged.47 Hence, there is a severe

in principle and require transhipment at-port, but each organization makes exceptions to allow

lack of transparency in the supply chain of tuna transhipped at-sea, which further prevents tracing

transhipment at-sea when it is unavoidable. Tuna longliners are the vessels that are most often

through the supply chain.

42

allowed to transship at-sea. In the Western and Central Pacific Fisheries Commission (WCPFC) in
particular, transhipments on the high seas by tuna longliners are the norm rather than the exception.43

24

25

From Korean tuna boats to Japanese carriers - the great migration of tuna
Global Fishing Watch's Carrier Vessel Portal (CVP) uses Automatic Identification System (AIS) location

Figure 9: Meita Maru's sea route (yellow: transhipment at-sea / blue: port / purple: standby)

48

data from fishing vessels and RFMO databases to monitor transhipment at-sea. The portal can beused to track where and with which carrier vessels South Korean tuna longliners tranship, and also
where the carrier vessels head to after the transhipment.
Oryong 371 is a tuna longliner owned and operated by the Sajo Group. Between 2017 and August 2023,
Oryong 371 made a total of nine transhipments at-sea, all with Panama- or Singapore-flagged carriers.
However, these carriers were all operated by Japanese shipping companies (Toei Reefer and MRS
Corporation).

Figure 8: Oryong 371's maritime route (yellow: transhipment at-sea)

Source: Global Fishing Watch, Carrier Vessel Portal

The Korean tuna longliners that Meita Maru conducted transhipment at-sea is as follows:- Dongwon Fisheries: Dongwon 617, 637, 638, 639- Sajo Industries: Oryong 305, 325, 371, 375, 721, 722, 731, 801, Oyang 355, 372- Sea Sky Mulsan: Hae Cheon 11, 77, 88, 202, 303- Dae Hae Fisheries: Daehwa 201, 313
According to information from the CVP, Korean tuna longliners make prolonged voyages on the highseas, conducting transhipments with carrier vessels flagged with Panama but operated by Japanesecompanies in reality. These carrier vessels then deliver the sashimi-grade tuna to ports in Japan,
Source: Global Fishing Watch, Carrier Vessel Portal

South Korea, China, and Taiwan.
However, because it is difficult to identify what types of tuna were transhipped in what quantities, it is

In particular, Oryong 371 transhipped 3 times with a carrier vessel called Meita Maru49(Panama-flagged
and operated by Toei Reefer of Japan), which made 149 transhipments during the same period. Of

impossible to track how a tuna from a certain longliner got transhipped by what carrier vessel, at what
point in time, to which port in which country.

these 149 transhipments, 26 were with 21 Korean tuna longliners, and the Meita Maru subsequently
visited ports in Japan, South Korea, China, Taiwan, and Singapore.50

26

27

Japanese transhipment (refrigerated transport, or "reefer") companies
51

Japanese companies have been operating carrier vessels by flag of convenience recently. For
example, Toei Reefer Line Ltd is known as the largest carrier company in the world, and its main
business is the frozen transportation of sashimi tuna. It is also a multinational corporation withsubsidiaries Toei Kaisho Co., Ltd in Panama and Toei Marine Enterprise Co., Ltd in the Netherlands.52
Toei Reefer Line Ltd has five vessels listed on its website: Kenta Maru53 and Gouta Maru54 are flagged
to Japan, while Kurikoma,55 Meita Maru,56 and Genta Maru57 are registered as Panama-flagged in the
RFMO databases. Although the three Panama-flagged carriers are owned and operated by Japanesecompanies, they are required to report their records of transhipments to Panama, not Japan, in
accordance with RFMO regulations. These carrier vessels conduct frequent at-sea transhipmentswith South Korean tuna longliners, and supply sashimi tuna to Japanese ports. However, theinformation available through the RFMO is limited, and neither Japan nor South Korea has oversightover the activities of Panama-flagged carrier vessels.

b. Major Korean companies in tuna export
South Korea's tuna longline industry is led by Sajo Group, Dongwon Industries, Dongwon Fisheries,
and Silla.
Sajo GroupThe Sajo Group started its DWF business as Sajo Industry in 1973, and later incorporated Sajo Daelim
and Sajo Ocean to lead a fleet of more than 80 vessels. About half of the vessels are tuna longliners,
and they mainly fish for sashimi tuna such as bluefin, bigeye, and yellowfin tuna in the Central
Pacific, Indian Ocean, Atlantic Ocean, and Southern Indian Ocean.60 One of the central businessesof Sajo Group is processing and distribution of seafood, which Sajo Seafood mainly carries. Sashimi
tuna is its main product; as of 2021, processing and distribution of sashimi tuna accounted for 67%
of Sajo Seafood’s total sales, which was then mostly exported to Japan.61 For the export of sashimi
tuna, Sajo Seafoods disclosed that its overseas business team "negotiates the quantity, unit price,specifications, and payment terms of the supplied products with Japanese and overseas buyers"

Carrier vessels to Japanese ports
Sashimi tuna caught by Korean tuna longliners arrive at Japanese ports either through transhipment
at-sea or Korean ports. Once in Japan, the tuna is distributed by large trading companies with fisheryand directly exports them through 20-foot containers after order production.62 Sajo Seafood also
operates a 60,000-ton cold storage warehouse at Gamcheon Port in Busan to handle export, and themain item in the warehouse is sashimi tuna.63

divisions. The distribution of tuna in Japan used to be dominated by the "traditional distribution route"
through fishery cooperatives and wholesale markets, but with the emergence of trading companies,
the proportion of tuna imported and distributed directly to consumers is increasing. The market
share of trading companies has steadily increased over the past decade, with 70-80% of frozen tunain 2016 being distributed by four large trading companies, Toyo Reizo, Try Sangyou, and Fukuichi and58

Yamafuku. One reason is the trend of consolidating and decreasing numbers of fishery coops since
the early 2000s in line with the tightening seafood market, and with them a decreasing number ofwholesale markets, as many markets are administered by fishery coops.59
The emergence of trading companies has reduced transparency in the tuna supply chain. In the past,

Dongwon Industries
Founded in 1969 by a former captain of a DWF vessel,64 Dongwon Industries has been engaged in DWF
on tuna as its main business, and is by far the number one DWF company in Korea with a 43% share of
the market.65 Although canned tuna is its flagship product, the largest number of Dongwon's vessels
are tuna longliners, with a total of 12 vessels catching 5,000 to 6,000 tons of bluefin, bigeye, andyellowfin tuna annually in the South Pacific and Indian Oceans. In addition, Dongwon Industries, like
Sajo, operates a 100,000-ton logistics center complex at Gamcheon Port in Busan, where it freezes
sashimi tuna and distributes it via trucks for domestic orders and special containers for exports.66

statistics on tuna distribution in fishery cooperatives and wholesale markets were publicly recorded
and managed; however, information on tuna distribution by trading companies are not published
due to being a “trade secret”. Furthermore, the trading companies process, carry, and distribute tuna
through their own carrier vessels and processing facilities, yet do not disclose relevant informationsuch as suppliers and traceability to the public. Hence, it is difficult to identify stakeholders involvedin the supply chain and obtain relevant information. Even industry experts within Japan have reported
that they cannot adequately understand the details of distribution by trading companies.

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Dongwon Fisheries

Table 3: Major tuna longliner companies’ operations in South Korea

Dongwon Fisheries is a completely independent company from Dongwon Industries and has beenin the tuna fishing business since its establishment in 1970. It operates a fleet of 16 DWF vessels,
14 of which are tuna longliners, and primarily catches Southern bluefin tuna and yellowfin tuna in

Company# of Tunalongliners

Fishing waters

Catch Species

Annual catch of
sashimi tuna (tons)

Distribution and export routes

the Pacifics and Indian Oceans, which culminates to 3-4,000 tons of sashimi tuna each year. On its
website, Dongwon Fisheries discloses that its tuna longliners “leave Busan port and fish for about 2
67

years until return.” In addition to operating two freezing plants and a 20,000-ton freezing warehouse

Central Pacific,
Sajo Group40

in Busan to store and export sashimi tuna to Japan, Dongwon Fisheries expanded its export channels

Indian Ocean, Atlantic

Sashimi tuna (bluefin,

Ocean, Southern Indianbigeye, yellowfin, etc.)

Not disclosed

Stores in warehouse and exports
directly to Japanese buyers

Ocean

to Japan in 2020 by incorporating You Wang, a company specializing in sashimi tuna processing anddistribution, as a subsidiary.68 You Wang operates its own 3,000-ton freezer and 20-ton factory tostore, process, and distribute sashimi tuna from Dongwon Fisheries.69

DongwonIndustries

16

South Pacific Ocean, Indian

Sashimi tuna (bluefin,

Oceanyellowfin)

Pacific Ocean, Southern

Sashimi tuna (bluefin

Indian Oceantuna, bigeye tuna, etc.)

5-6 thousand

Stores in warehouse and exports
directly via special containers

Silla
Silla, which started as a trading company in 1967, has been operating six tuna purse seiners and nine
tuna longliners independently since 1972. The tuna longliners catch about 3,000 tons of yellowfin
and bigeye tuna for sashimi in the South Pacific every year.70 Silla says it exports sashimi tuna directly

DongwonFisheries14

3-4 thousand

Stores in warehouse and exports via
You Wang subsidiary

to foreign sellers once it enters the domestic port.71 Although its subsidiary Shilla SG is in chargeof distribution and processing and operates a factory in Busan, the majority of its products are
sausages and canned goods, and it does not appear to distribute and process sashimi tuna itself.72
In addition, Silla operates 11 “overseas joint venture vessels” to fish and distribute tuna and pollock

Silla

9

South Pacific

Sashimi tuna (bluefin,bigeye, yellowfin, etc.)

3-4 thousand

Exports directly to Japanese buyers

for processing.73 In 2014, Silla established a subsidiary called “Green Marine Total Services” in thePhilippines, but its business details are not disclosed.74

Various ships in Busan port, Busan, Korea © Shutterstock

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c. Major corporations in Japanese tuna distribution

Fishery and food companies

Figure 10: Distribution channels of tuna in Japanfood processing company. With overwhelming strength in procurement, distribution, and overseas

The largest player in the Japanese seafood industry is Maruha Nichiro Corporation, a fishery andnetworks, Maruha Nichiro handles over 0.2 million tons of seafood volume out of the total of theOverseas Processing

Tuna Distribution in Japan

2.2 million tons of seafood annually imported by Japan.75 Maruha Nichiro Corporation is a pioneer inaquaculture for bluefin tuna, and it has established a seedling cultivation facility for fully cultivatedbluefin tuna in Oita Prefecture. Following Maruha Nichiro Corporation, Nissui Corporation (foodcompany) develops, produces, and imports about 0.11 million tons of seafood, and Kyokuyo Co., Ltd.
(food company) develops, produces, and imports about 0.1 million tons.76

Indirect
ImportIntegrated
Processing

Domestically Produced Tuna

Imported Tuna

Longline

FarmedPurse

Trading companies
Japanese trading companies such as Mitsubishi Corporation, Sojitz Corporation, Marubeni
Corporation, Mitsui & Co., Ltd., Toyota Tsusho Corporation are also key actors in the seafood market in

Trading Company

Japan. Focusing especially on tuna, Toyo Reizo Co., Ltd., the seafood arm of Mitsubishi Corporation, is

Direct Import

Fish Carriers

the largest domestic handler in terms of volume. Sojitz Corporation has been a very large player in theimportation of tuna, importing 30,000 tons of tuna in 2010, the latest date found with statistics, which

Fish market at landing ports(e.g., Yaizu) Auction

To buyers/ processors

Wholesale markets (e.g., Tsukiji)
Primary & Intermeiary wholesalers
AuctionIntegrated
Processing

Retail storesis around 15% of Japan's total tuna import at the time. In 2008, they also entered the tuna aquaculture
sector, administering domestic tuna farming currently producing about 10,000 tuna per year.77

Tuna buyers(Processors)
Traditional
Distribution
ChannelsSupermarket chains

TradingCompany
Distribution

Seafood wholesale company
Distributors

The major seafood wholesale companies in Japan are OUG Holdings Inc., Chuo Gyorui Co., Ltd., Daisui
Co., Ltd., Tohto Suisan Co., Ltd., Daito Gyorui Co. Ltd., Tsukiji Uoichiba Co., Ltd., Yonkyu Co., Ltd. inFood service
Restaurants

descending order of revenue confirmed in 2022. Daito Gyorui Co., Ltd. is a wholly-owned subsidiary ofMaruha Nichiro.78

Consumers

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III. Human Rights Risks in South
Korea's DWF Industry

1. Defining forced labor and human trafficking
a. Forced labor
The ILO Forced Labor Convention No. 29 defines "forced labor" as “all work or service which is exacted
from any person under the menace of any penalty and for which the said person has not offeredhimself voluntarily.”79 The ILO provides 11 indicators to better describe the real-life manifestations offorced labor, including 1) abuse of vulnerability, 2) deception, 3) restriction of movement, 4) isolation,5) physical and sexual violence, 6) intimidation and threats, 7) retention of identification documents,
8) withholding of wages, 9) debt bondage, 10) abusive working and living conditions, and 11) excessive
overtime. The ILO notes that all 11 indicators do not have to be present, and the presence of only one
indicator can raise suspicions of forced labor.80

Red tuna auction sale at Fish Market © Shutterstock

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Table 4: Explanation of the ILO's 11 forced labor indicators
Metrics

Abuse of vulnerability

Deception

Description.
Exploitation of workers' vulnerabilities, such as lack of knowledge of language
or local rules, minority status, or limited employment opportunities.

Failure to honor promises made to workers, such as wages or working
conditions.

b. Human trafficking
Human trafficking is an important legal framework that can take into account the fragility andvulnerability of migrants who end up working on DWF vessels. The Protocol to Prevent, Suppress andPunish Trafficking in Persons, Especially against Women and Children (the Palermo Protocol) defines
human trafficking as "the recruitment, transportation, transfer, harboring or receipt of persons, bymeans of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception,of the abuse of power or of a position of vulnerability, or of the giving or receiving of payments or
benefits to achieve the consent of a person having power or control over another person, for the
purpose of exploitation". The Palermo Protocol makes it clear that the victim’s consent does notprevent the establishment of human trafficking (Article 3).81

Restriction of

Failure to provide freedom of entry and exit in hazardous workplaces beyond

movement

those associated with reasonable restrictions on safety and security, etc.

Table 5: Components of human trafficking
Isolation

Geographic isolation of the workplace or lack of communication methods

Physical and sexual

Use of violence against workers, for reasons such as coercing work notviolence

included in the original agreement

Intimidation andIntimidation and threats such as reporting to immigration authorities, cutting

threats

wages, or exacerbating working conditions.

Element

PurposeContents

Exploitation(forced labor, forced employment, slavery or similar practices, servitude, etc.)

Threats or use of force
Retention ofConfiscating identification documents or other valuables, making them

identification

inaccessible to the worker, and making the worker feel unable to leave thedocuments

workplace without losing them.

Withholding of wages

Debt bondage

36

Means

Abuse of power or exploitation of a vulnerable position
Offering or receiving remuneration or benefits to obtain the consent of someone who
has control over another person

Organized and intentional withholding of wages as a means of preventing
workers from leaving their jobs.

Acts

Recruitment, transportation, transfer, harboring, or receipt

Working to repay debts incurred as a condition of employment, such as
brokerage fees or prepayment of wages.

Abusive working andDangerous or poor working conditions, or substandard living conditions

living conditions

related to labor.

Excessive overtime

Coercion, abduction, fraud, deception

Working hours that exceed the limits set by national laws or collective
bargaining agreements, or refusing to allow breaks or leaves.

372. Forced labor and human trafficking on South Korea’s DWF
vessels
As mentioned earlier, about 80% of workers on DWF vessels are migrant workers who suffer frompoverty, lack of education, and unemployment in their home countries. This renders the migrant
workers susceptible to manipulation and exploitation in their employment. With no or very little
income in their countries of origin, they readily accept the working conditions and salaries of DWF

Due to the absence of regulations on working hours on DWF vessels, migrant workers are exploited byworking long hours, often more than 12 hours a day, for a discriminatory minimum wage that is much
lower than that of Korean fishers. They are also frequently exposed to violence, hazardous living
environments, and dangerous working conditions; nonetheless, they are unable to leave due to thevarious factors such as deposit money and unpaid wages as well as physical isolation in the middleof the high seas. Hence, the migrant fishers on DWF vessels are subject to forced labor and humantrafficking.82

vessels. During the migration process, under the guise of finding them work, brokers collect various
training and transaction fees, as well as deposits which act as constraints that prevent them fromleaving the job for a promised period. In addition, migrant workers start their work mostly without
understanding the contents of their work agreements.

Manning agency in Indonesia © APIL

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Table 6: Types of human rights violations on Korean DWF vessels

Since the plight of migrant workers on Korean DWF vessels gained international attention, thegovernment and industries have claimed that they have resolved the issue by taking some steps.

Type

Factors

Abuse of vulnerability

Description
Vulnerabilities such as physical and psychological isolation, lack ofunderstanding of language and culture, etc.

However, investigations by civil society organizations have made it clear that the patterns of forcedlabor and human trafficking have been persisting without significant change. The Environmental
Justice Foundation (EJF)83 and the Advocates for Public Interest Law84(APIL) surveyed 74 migrant
workers who worked on Korea-flagged DWF vessels between 2021 and 2022, and found that 60
percent of them had to work more than 14 hours a day without a break during busy periods. However,Deception

Restriction of movement

Failure to honor commitment to legally disclosed minimum wages

Long voyages without a port call, ranging from 12 to 24 months, andthe resulting restrictions on escape or pursuing grievances

they were paid less than one-tenth of the average Korean fisher's salary; about half of them were paidless than the designated minimum wage; and it was a common practice for recruitment agencies tomake deductions from their wages for the sake of broker fees and exchange rates. 83% of migrant
workers reported experiencing threats of forced disembarkation or denial of wages, as well as verbal
abuse. 24% of migrant workers said they had been physically assaulted, or witnessed a coworker

Isolation

Restricted usage of cell phone and internet

being assaulted. In addition, all of the migrant workers surveyed reported that their passports wereconfiscated by the captins or the owners of the vessels.

Physical and sexual violence

Physical and sexual harassment and abuse

Of the 74 who were surveyed, 30 were migrant fishers who had worked on longliners. Without
exception, all 30 reported being subject to exploitation in poor working conditions. 53% of migrant

Forced Labor

Intimidation and threats

Threats to cut or not pay wages, and on forced disembarkation

fishers who worked on longliners were unpaid or had their wages deducted; 80% experienced abuse;and 100% had their passports confiscated. Migrant fishers on longliners were found to be particularly

Retention of identification
documents

Confiscation of passports to prevent escapevulnerable to forced labor and human trafficking due to longer working hours and periods at sea. 77%of those on longliners worked for more than 14 hours, and 30% worked for more than 18 hours–marking
much longer labor without rest compared to those on other vessels. In addition, 83% of migrant

Withholding of wages

Deductions from wages for recruitment fees

fishers had to sail for more than a year without entry to port, while 17% had sailed for more than 2
years, which is double the rate for DWF vessels at large.85

Debt bondage

Abusive working and living
conditions

Human Trafficking

Not paying wages for the first 3 months until end of contract, or
imposing escape deposits, for the purpose of preventing escapeInsufficient food and water, unsanitary living conditions, etc.

Excessive overtime

12 or more consecutive hours of work without a guaranteed rest period

PurposeForced labor

Acts

Crew recruitment and transportation

Abuse of power and exploitation of vulnerability, including but not
Meanslimited to deception, threats, physical and verbal violence, withholdingof wages, discrimination, and coercion of debt

40

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Testimonies from migrant fishers who worked on Korean tuna longliners"As soon as we got on the boat, we started working. We worked until 9 pm, but there were
no breaks, no holidays, no overtime pay... If someone gets tired and leans (on the wall) fora second, the captain would hit them on the head."(Indonesian worker who worked on tuna longliner D from 2019 to 2021)

Table 7: Labor conditions of migrant fishers working on DWF vessels and tuna longliners
Work without rest

DWF vessels in general

Tuna longliners

14 hours or more

60%

77%

18 hours or more

26%

30%

Sailing without entry to port

DWF vessels in general

Tuna longliners

1 year or more

40%

83%

2 years or more

7%

17%

"I was abused on a daily basis. My eyes were injured and I had to get surgery, but I had topay for it on my own."(Indonesian worker who worked on tuna longliner D from 2020 to 2021)"My seniors sexually harassed me every time I sat down, claiming it was Korean culture. I
worked for 48 hours straight, but was forced to lie about it when I was later surveyed."(Indonesian worker who worked on tuna longliner S from 2019 to 2021)

The problem of prolonged voyages of Korean tuna longliners has been exposed before. A 2018 study
by the University of California, Santa Barbara (UCSB) analyzed tuna longliners from the top 25 fishingnations and found that Korea-flagged vessels ranked first in sailing distance, sailing time, and fishingtime, as well as second in maximum distance from port–all indicating poor fishing conditions. 86
In addition, the South Pacific Fisheries Forum Agency stated in a 2017 report that South Korean
longliners rely on carriers to go on voyages of between 1.5 and 2 years without an entry to port.

"I paid around 500 USD to get my passport back, but I still don't have it. I also had to pay
the broker around 120 USD every month as fees."(Indonesian worker who worked on tuna longliner K from 2020 to 2022)

These long voyages increase the period of time fishers are physically isolated, which thereby
increases the risks of IUU fishing and human rights abuses. The prolonged physical isolation of tuna
longliners at sea makes it difficult to monitor labor exploitation and illegal activities, and also prevents
fishers from escaping, reporting, or seeking remedies. Likewise, all respondents from tuna longliners
in the above investigation testified that they were unaware of, and unable to access, any mechanisms"I had a two-year contract, but I was forced to work longer. I remained on the ship for
more than two years without entering any port."

for remedy or grievance. In addition, as all 109 of Korean tuna longliners were built before 1991,
concerns on their deterioration and safety have been raised.87(Indonesian worker who worked on tuna longliner D from 2019 to 2021)

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3. Limitations of the government’s actions
a. 2021 Ministry of Ocean and Fisheries “Implementation Plan”
In July 2020, the Ministry of Oceans and Fisheries (MOF) announced a policy to establish an

Table 8: MOF’s implementation plan and its corresponding investigation results on migrant
fishers
Implementation Plan

Fulfillment status

Investigation result

implementation plan to improve the working conditions of migrant fishers working on DWF vessels,
to be implemented from 2021.88 The main goals of the policy were: 1) for migrant fishers to receive full

Wage without reductions such as

wages without deductions due to recruitment or transaction fees; 2) for the minimum wage to be atrecruitment fees

X

Reduced wages under pretext of recruitment fees andexchange rates (64%)

least 540 USD by 2021 based on the International Transport Workers' Federation (ITF) standards; 3)
for rest hours to be guaranteed for at least 10 hours daily, or flexibly at least 308 hours monthly; 4)
for those wishing to disembark be regularly surveyed in order to prevent prolonged sailing; and 5) for
bottled-water to be fairly distributed by the employer companies, without regard to nationality.

Minimum wage of 540 USD per ITF
standard

X

However, the MOF’s policy is limited in several ways.89 First of all, aligning minimum wage with the ITF
standard does not address the problem of wage discrimination based on nationality, which already

Minimum 10 hours of rest each day

Xviolates the Labor Standards Act and the Seafarers Act. In addition, although minimum rest periods

Less than 540 USD (48%),
less than minimum wage for Korean fishers (100%)Rest of less than 6 hours (23%),
rest of less than 12 hours (76%)

are guaranteed, the provision of flexible operation on a one-month basis rather than a daily basis
means that fishers are not guaranteed continuous rest periods. Furthermore, even if the recruitment

Prevention of prolonged voyage via

fees are paid by the employers rather than the fishers, there has been no measure on fees charged

survey on will to disembark

X

Prolonged voyage of 12 months or more,irrespective of will to disembark (42%)

prior to embarkation, such as escape deposits. In other words, even if the recruitment fees are notdeducted from wages as before, migrant fishers are still imposed with debt bondage as fees are now
charged prior to embarkation, not after.

Fair distribution of bottled water

X

Experienced discrimination in purchasing bottled water due tosignificantly lower wages compared to Korean fishers (42%)

While the plan aimed to survey those wishing to disembark to prevent prolonged fishing, the upper
limit for sailing still remains at 15 months. There has also been no guarantee that one will be able tore-embark after landing, which prevents the migrant fishers from expressing their will to disembark.
Moreover, there has been no additional measure to address confiscation of passports, which has
persisted as a common practice despite being a forced labor indicator.
The investigation above confirms that the MOF’s implementation plan has failed to combat humantrafficking and forced labor.90

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b. 2022 Act on Prevention of Human Trafficking, etc., and Protectionof Victim (PTPV Act)In 2022, seven years after ratifying the Palermo Protocol, the South Korean government enacted the
PTPV Act to identify, protect, and punish human trafficking, which took effect in 2023.91 However,many concerns were raised about the law even before its implementation92, the biggest of which was
the absence of penalty provision. First of all, the PTPV Act failed to follow the definition of humantrafficking within the international standards, and instead created an ambiguous category of “humantrafficking, etc.” Not only that, it also failed to establish a penalty provision, which rendered adequate
punishment on human trafficking impossible. Furthermore, while the Act required human trafficking
identification index to be developed, it did not mandate the usage of the index, which led to concernsthat victim identification will not be carried out in practice.
As nearly a year has passed since the Act’s implementation, all of the above concerns have cometo reality. Due to the contradicting definitions of “human trafficking”, “crime of human trafficking”,“human trafficking, etc.”, and “crimes of human trafficking, etc.”, there is no shared understanding ofwhat human trafficking really is among government ministries and officials. As a result, identificationof human trafficking has been absent in labor inspections and crackdowns against migrants, and thevictims have been blocked from accessing remedy. In order to receive official support and protection
as a "victim of trafficking," one must be recognized as a victim of a "crime of human trafficking, etc.."
or be identified as a victim of “human trafficking, etc.” by the official bureau. In the absence of criminal
penalties and victim identification procedures, however, the likelihood of a victim receiving state
protection is minimal.93

2023. 3. 27. The Committee on Prevention of Human Trafficking etc. © Ministry of Education

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In addition, the PTPV Act entrusts the entire process of victim identification and support to “regional
support agencies”, but after failing to recruit such organizations for the entire year, the government
has recently cut the budget for the regional support agencies to zero in 2024.94 The budget for
40 migrant worker support centers, on which countless migrant workers including fishers rely to
pursue grievances and receive withheld wages, has also been cut from 7 billion KRW to zero.95 Not
only that, the government also announced a 44.5% cut in the entire budget to support victims of

IV. Government and Corporate Policies
on Seafood Imports in Japan and Their
Limitations

human trafficking in 2024. Therefore, the effectiveness of the current system on human trafficking
identification and protection remains opaque.
Human trafficking against migrant fishers has been poorly addressed in particular. Migrant workers
on DWF vessels have been identified as one of the most common types of trafficking victims in South
Korea,96 yet nowhere in the PTPV Act or its comprehensive plan includes measures on fishers.97 The
vulnerabilities of migrant fishers, including physical isolation, language barriers, lack of immigration
status, and debt due to the involvement of brokers, are characteristics of their victimhood. As
such, support measures ought to be tailored to these characteristics, e.g. ensuring public andgovernmental oversight on recruitment procedures which give rise to forced labor. Nonetheless, thegovernment has responded only with temporary measures, devoid of enforcement and practicality.

1. Government: tuna import procedures
In order to implement Conservation and Management Measures (CMMs) of RFMOs, Japan manages
imported tuna in accordance with the Special Law for Strengthening Conservation and Managementof Tuna Resources (the Tuna Management Law).98 The Tuna Management Law seeks to prevent theimportation of IUU-caught tuna by requiring importers of tuna species such as bluefin tuna, southern
bluefin tuna, bigeye tuna, yellowfin tuna, other tuna species (excluding albacore tuna), swordfish,and marlin to submit a certificate from the vessel's country of origin stating that IUU fishing did notoccur. In other words, the Tuna Management Law allows the Japanese government to enforce theRFMOs’ CMMs, but there is no mechanism to review human rights violations such as forced labor andhuman trafficking that occur during the fishing process.
The law involves certifications of vessels' catches by their flag states and confirmation of thecertifications by Japan. The South Korean certifying organization under RFMOs like the WCPFC, theprocedures of which the Tuna Management Law implement, is the National Fishery Products Quality
Management Service, 99 and the Japanese agency confirming the certifications is the Fisheries
Agency, a division of the Ministry of Agriculture, Forestry and Fisheries (MAFF) as described below.100
The law requires different certifications and procedures depending on the tuna species, state of thetuna (frozen or chilled/fresh), and shipping method (vessel or aircraft), the two basic proceduresfor covered species being (1) certification confirmation prior to import declaration by the Fisheries
Agency (pink box below), and (2) certification confirmation at customs at the time of importdeclaration (orange box below). This leads to a somewhat complicated arrangement summarized by
the following charts.101

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Figure 11: Flowchart of certification for tuna import

As sashimi tuna mostly consists of frozen bigeye and bluefin tuna, they require the advanceconfirmation by the Fisheries Agency, as well as submission of forms such as invoice/contract,transhipment declaration, specified catch documentation (for bluefin tuna) and specified statistical

METI
No Procedurerequired

Albacoretuna

Importing
Tuna / Swordfish / Marlin?

data (for frozen bigeye tuna). Direct importers of bluefin tuna from South Korea to Japan in the period2022 to 2024 are also required to give additional information, which is also to be provided to the
WCPFC, although this data may not be publicly available on the WCPFC’s site until after 2024.

Yellowfin tuna
MarlinOther tuna(excluding albacore)

Bigeye tuna

Shipping method?

Bluefin tuna, Southern bluefin
tuna,
Swordfish

Product state?

Product state?

Aquatic Products Act adopted to combat IUU seafood import and distribution.
While the Tuna Management Law addresses the importation of tuna, it is worth briefly discussing
the new law in Japan to prevent the importation and distribution of IUU seafood generally: "Act on

Sea vessel

AircraftFresh/chilled

FrozenFrozenFresh/chilled

Ensuring the Proper Domestic Distribution and Importation of Specified Aquatic Animals and Plants(Act No. 79 of December 11, 2020)" (“Aquatic Products Act”).102 Note, however, that the technical

Advance confirmation
by Fisheries Agency
required

METI
No procedurerequired

Advance confirmation
by Fisheries Agency
required

document on the Tuna Management Law has clarified that "tunas and other fish species for which
Necessary to confirm
at time of customs

import regulations with a view to prevent IUU fishing are already in place under other programs are
excluded from Japan's catch documentation scheme" under this law.103 The law came into effect inDecember 2022, and it currently targets only the following species: Pacific saury, squid, mackerel, andFlowchart of advance confirmation
system for frozen tuna
List of officially licensed
vessels

Flag state/State of origin
Issues certificate
based on RFMO
procedure after
confirming catch
information.

Bluefin tuna, Southern
bluefin tuna, Bigeye tuna,
Swordfish
Matchingwith list

If in doubt, refer toissuing state of clearing

Apply to Fisheries
Agency for issuance ofconfirmation

Application
Confirmation
IssuedTo very briefly summarize the law, it divides the distribution of seafood in Japan into two classes:
Class I seafood caught by Japan flag vessels in Japan and Class II seafood imported into Japan orcaught by foreign vessels (non-Japanese-flag-state vessels). For Class I seafood, the law requires
government notification and submission requirements covering relevant information (catch number,

List of regular farms

product information, transaction records, etc.) which must follow the product through distribution.

Bluefin tuna, Southern
bluefin tuna

For Class II seafood, the subject of this report, there is a Catch Documentation Scheme (CDS)
requiring certification from the authorized agency of the catching vessel's flag state that the seafood
was legally caught, and including product information as described below before it can be imported

Matching with list
Fisheries Agency(International Div.)

Importersardine.

Issues confirmation letter
after confirming request
according to RFMO CMM(regular list, etc.)

into Japan, along with any other documentation required by the Fisheries Agency.104 Finally, Article 12
also allows on-site inspections of any business importing Class II seafood. Under Article 15, a violationof Article 11 entails punishment of imprisonment and a 1 million yen fine. Like the Tuna Management
Law, the Aquatic Products Act requires the state responsible for exports to provide certification whichis confirmed by Japan as the state of import. The relevant ministries are listed as the National Fishery
Products Quality Management Service for Korean certification and MAFF for Japanese confirmation.105alignment

Import/ Customs clearance (customs)

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2. Corporations: voluntary efforts

Figure 12: Chart of Certification Scheme Procedure
Foreign Country

Japan

Exporter

Attachment of certificate

Application ofcertificate

Document
check at Japan
CustomsCatchcertificate

Importertheir supply chains, and in 2022, it released guidelines for supply chain human rights due diligence.107
In response, many companies have adopted policies to implement human rights due diligence, andHuman Rights Now analyzed the human rights due diligence policies of major companies involved in
the import and distribution of sashimi tuna.108
The following section reviews publicly available information on six Japanese trading companies thatimport and distributeseafood according to the methodology explained below: Toyo Reizo Co., Ltd.,Catchcertificate
Validation and issuanceof certificate

The Japanese government is encouraging companies to implement human rights due diligence in

Mitsubishi Corporation, Try Sangyo Co., Ltd., Sojitz Corporation, AEON Co., Ltd. and Seven & i Holdings
Co., Ltd. The first four companies were selected because they were listed in a report as dominantDistributed into
Japanese Market

Foreign government agency, etc.
Note : There are penalties against violation of the obligations of notification, communication, transaction record,
attachment of certificate for import, export, and others.

Source: Japan Fisheries Agency106

sashimi trading companies and as their parent companies, which South Korea exports to,109 and thelast two companies were selected because they are the largest retailers and because the majorityof Japanese individuals purchase sashimi tuna for home use at supermarkets, which, in turn, source
their products from trading companies.110 It focuses on their human rights policies, and transparency
and due diligence practices to identify and prevent labor rights violations among their seafood
suppliers.
In general, it was found that there were insufficient measures observed to protect the labor andhuman rights of fishers in the supplying end. While the large participants: Mitsubishi, Sojitz, AEON and

In importing seafood where the law is applicable, the catch certification must include informationon the certifying authority, its certification, vessel, product, stock management, transshipment(if applicable), exporter, importer, and import control authority. A processing declaration form if
applicable must include the following information: vessel, flag state, certification, catch description
and weight landed, processed, and after processing, the name of the processing plant andadministrator, exporter (if different than the plant), and certifying authority.

Seven & i seemed to have future plans to take responsibility for their human rights due diligence, Toyo
Reizo and especially Try Sangyo have less information available about their human rights policies.
Behind this gap in what information the two types of companies make public are ostensibly limitationsof human resources working on rights protection issues in the more specialized companies, aswell as a low penetration rate of the Guiding Principles on Business and Human Rights and similarinternational standards in Japan. Also, even if large companies publish their policies and plans, theyoften end up with few details or explanations regarding their results, or how they manage PDCA
cycles for human rights due diligence. The next section explains each company's relevant policies andmeasures related to human rights which are made available to the public.

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TOYO REIZO Co., Ltd.

Mitsubishi Corporationa. Company Profile111

a. Company Profile114

TOYO REIZO Co., Ltd, was established in October 1948 and reorganized in 1971. The company has

Mitsubishi Corporation was officially registered on April 1, 1950 and established as a legal

a capital of 2,121,452,637 yen and employs a workforce of 827 individuals.

entity on July 1, 1954. The company has a capital of 204,446,667,326 yen (JPY) and has issued
1,458,302,351 shares of common stock.

The core business of TOYO REIZO revolves around various sectors, including sales, trading,
processing, and refrigeration of marine products, agricultural products, livestock products,

With a large and diverse network, Mitsubishi Corporation operates through a significant number

dairy products, feed, and chemical products. Additionally, they are involved in the transportationof offices and subsidiaries. It has 1,321 subsidiaries and 416 affiliates, resulting in a total of 1,737

industry, warehouse operations, aquaculture, ranching of fish and shellfish, as well as relevant

entities under its umbrella.

research. Moreover, the company actively engages in other ancillary businesses.

In terms of human resources, the parent company employs 5,448 individuals. However, when

TOYO REIZO maintains strong relationships with major banks, including the Shizuoka Bank, The

considering both the parent company and all of its consolidated subsidiaries, the total number

Norinchukin Bank, Mitsubishi UFJ Bank, and Mitsubishi UFJ Trust and Banking.Additionally, theyof employees reaches 79,706, showing the global reach of the company's operations.

have notable partnerships with suppliers, such as Mitsubishi Corporation, and others.

Mitsubishi Corporation is organized into several business groups, each focusing on specific

The company's main sales destinations encompass wholesale markets, mass retailers,industries and areas of expertise. These groups include the Industry Digital Transformation

restaurants, and other related establishments. Demonstrating its success, TOYO REIZO

Group, Next-Generation Energy Business Group, Natural Gas Group, Industrial Material

recorded an amount of sales, reaching 171.5 billion yen in the fiscal year 2022.

Group, Chemicals Solution Group, Mineral Resources Group, Industrial Infrastructure Group,
Automotive & Mobility Group, Food Industry Group, Consumer Industry Group, Power Solutionb. Analysis

Group, and Urban Development Group.

On Toyo Reizo's website, a general human rights policy was not made available.112(*This was asof the time of the investigation. Subsequently, it was disclosed to be the same as Mitsubishi

b. Analysis

Corporation’s.) However, it has a CSR (Corporate Social Responsibility) page on which "Tuna

Mitsubishi Corporation has a Human Rights Policy and it has expressed support for theProcurement Guidelines" (2022.08) was found.113 This guideline seems to be the same as

International Bill of Human Rights, Guiding Principles on Business and Human Rights, ILO

Mitsubishi's "Tuna Procurement Guidelines" (2022.08) except one additional commitment inInternational Labor Standards, and Voluntary Principles on Security and Human Rights.115

which Toyo Reizo declares the objective "To establish interoperable traceability that includes

Mitsubishi Corporation also seemed to include a "Sustainable Supply Chain Action Guideline" inthe major data elements recommended by GDST (Global Dialogue for Seafood Traceability)

its contracts with its suppliers.116 However, from the publicly available information, there is only ain order to avoid the risk of sourcing tuna through IUU (Illegal, Unreported and Unregulated)

mention of "suppliers”, and the extent of dissemination is unclear.

fishing as defined by the Food and Agriculture Organization of the United Nations (FAO)".

In addition, significantly different from the other following companies, it has established

While the guidelines acknowledge commitments that meet Global Sustainable Seafood

an individual guideline for tuna, the "Tuna Procurement Guidelines" noted in the previous

Initiative standards, there were no concrete results nor process information shown on thesection, as well as guidelines for timber and palm oil. The details written in these guidelines

website. Also note that Mitsubishi is the parent company of Toyo Reizo, although it is not

are described above. Overall, Mitsubishi Corporation seems to aim to deal with IUU fishing andmade explicitly clear on Toyo Reizo's website that or how all of Mitsubishi's relevant policies

human rights violations in the Tuna industry with specific policies made through dialogue withand practices (see below) apply to Toyo Reizo.(*This was as of the time of the investigation.

multiple stakeholders; however, concrete supply chain information, progress, and results wereSubsequently, some links and information guiding to Mitsubishi Corporation's website were

not made fully available.

made public.)

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Try Sangyo Co.

Sojitz Corporationa. Company Profile117

a. Company Profile118

Try Sangyo Co., Ltd. is a company based in Shizuoka Prefecture, Japan. Founded in July

Sojitz Corporation was established on April 1, 2003. The company has a capitalization of

1988, the company has a capital of 67 million yen. The company operates as a wholly-owned

160,339,000,000 yen, and it operates a global business with a presence in 5 domestic branches,

subsidiary of Sojitz Corporation, holding 100% of the shares. Try Sangyo employs a total ofincluding the Head Office, and 87 overseas offices. It also manages 131 domestic subsidiaries

119 individuals, comprising 79 male and 40 female employees as of June 30, 2022. Try Sangyo

and 291 affiliates overseas. The company has a workforce of 2,523 employees on a non-Co., Ltd. maintains a relationship with an affiliated company known as Try Tuna Product Co.,

consolidated basis, and on a consolidated basis, it employs 20,669 individuals.

Ltd. Additionally, the company engages in cooperation with CAS Co., Ltd., and Create Co., Ltd.,
which are identified as its cooperative partners.

Sojitz Group is involved in a diverse array of global businesses, engaging in manufacturing,b. Analysis

Japan and overseas. To manage its diverse operations, Sojitz Corporation follows a 7-division

For Try Sangyo, unfortunately, there was no information related to human rights protection in

structure, which includes the Automotive Division, Aerospace & Transportation Project Division,

its business made available.

Infrastructure & Healthcare Division, Metals, Mineral Resources & Recycling Division, Chemicals

sales, import, export, provision of services, and investments across various industries in

Division, Consumer Industry & Agriculture Business Division, and Retail & Consumer Service
Division.
b. Analysis
As with Mitsubishi Corporation, Sojitz also has a Human Rights Policy which was establishedin June 2017.119 The principles to which it expresses its support also seem to be the same as
Mitsubishi's. It has "Sojitz Group CSR Action Guidelines for Supply Chains" established in2014 and revised in 2017,120 as well as "Sojitz Group Sustainability Handbook" for Sojitz groupmembers issued in 2019.121 There was no information that Sojitz requires its suppliers to commit
to these measures in its contracts with them, but it does ask all consolidated subsidiaries(although not all suppliers) to send "confirmation letters" on the measures. However, from thepublicly available information, there is only a mention of disseminating the policy with “suppliersin high-risk industries”, and the extent of dissemination is unclear. Also, compared to Mitsubishi,
which has guidelines specifically targeting tuna, Sojitz seems to have only two individualized
guidelines on timber and palm oil. To conclude, there was less information disclosed related toits measures, progress, and results to deal with human rights risks in its value chain.

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AEON Co., Ltd.

Seven & i Holdings Co., Ltd.

a. Company Profile122

a. Company Profile125

AEON Co., Ltd. (pure holding company) was established in September 1926. The company
operates with a capital of 220,007 million yen and primarily functions as a pure holding
company, managing its business activities by holding stocks or shares of companies engaged
in retail businesses, shopping mall development businesses, financial service businesses,
services businesses, and related ventures. AEON has a total of 2,400,000,000 available shares,
and the total number of issued shares, including treasury stock, amounts to 871,924,572 shares.
Listed on the Tokyo Stock Exchange, Inc., AEON Co., Ltd. conducts financial transactions withmajor institutions such as Mizuho Bank, Ltd., Norin Central Safe, Sumitomo Mitsui Banking
Corporation, Resona Bank, Ltd. and Mitsubishi UFJ Bank Ltd. The audit corporation for AEON Co.,
Ltd. is Deloitte Touche Tohmatsu LLC.
b. Analysis
Aeon established its Human Rights Policy in 2008, and revised it in 2018, expanding its coverage
to human rights among its suppliers. It expresses support for all of the principles as Mitsubishi
and Sojitz supported except for one: Voluntary Principles on Security and Human Rights. It
has also established "AEON Supplier Code of Conduct (CoC)."123 While this policy includes"AEON Sustainable Seafood Procurement Policy" in one of its appendices, the policy is written
only from a perspective of resource depletion prevention and biodiversity conservation.124
Furthermore, mandatory measures related to human rights tend to focus as their target only on

Seven & i Holdings Co., Ltd. was established on September 1, 2005, with a capital of 50 billion
yen. As of the end of February 2023, the company has issued 886,441,983 shares, with one
share unit equivalent to 100 shares. Seven & i Holdings primarily engages in the planning,
management, and operation of Group companies, focusing on a diverse range of business
operations. These include convenience stores, superstores, department stores, supermarkets,
specialty stores, food services, financial services, and IT services. The company operates as apure holding company, overseeing and coordinating the activities of its Group entities.
b. Analysis
Similar to Mitsubishi, Sojitz, and Aeon, Seven & i also has a Human Rights Policy available withsupport expressed on its website for the international principles listed above (OECD Guidelines
for Multinational Enterprises, Ten Principles of the UN Global Compact, Children's Rights andBusiness Principles, and Japan's National Action Plan on Business and Human Rights in addition
to what Aeon expresses its support). Under the policy, it also has "SEVEN & i Group Business
Partner Sustainable Action Guidelines."126 Suppliers of private brand products are required tomake an MOU (Memorandum of Understanding) when they make a contract with Seven & i.127 It
also has a similar issue as Aeon. While in its "Sector-specific Policies" in "Sustainable Sourcing
Principles," there is a section highlighted on marine products, it seems to only address thepreservation of natural resources.

its private brand, "Top Value."

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Table 9: Analysis of Human Rights Policies and Systems of Japanese Tuna-related Companies(Based on publicly available information on the official website)

1. Human Rights Policy

2. Formulation of Action
Guidelines for Suppliers and
its Promotion

3. Procurement Policy,
Guidelines regarding Fishery
Industry

4. Implementation of HRDD for
the tuna supply chain basedon the above-mentioned "1,""2," "3."TOYO REIZO Co., Ltd.

Mitsubishi Corporation

Try Sangyo Co.

Sojitz Corporation

AEON Co., Ltd.

Seven & i Holdings Co., Ltd.

Unavailable*As of the time of the investigation.
Subsequently, it was disclosed
to beas the same as Mitsubishi
Corporation’s

Available

Unavailable

Available

Available

Available

Unavailable

Available (Sojitz Group CSR Action Guidelines for
Supply Chains)* From publicly available information, there is
only a mention of disseminating the policy with“suppliers in high-risk industries”, and the extent ofdissemination is unclear.
[Features]•
None in particular.

Available (AEON Supplier Code of Conduct(CoC))* From publicly available information, there is only a mention of"suppliers," and the extent of dissemination is unclear.
[Features]•
External audits etc. conducted to assess compliancewith the CoC, for private brand products suppliers.

Available (Seven & i Group Business Partner Sustainable
Action Guidelines)* From publicly available information, there is only amention of "business partners," and the extent ofdissemination is unclear.
[Features]
MOU (Memorandum of Understanding) on SCR is required
only for private brand products suppliers.
•
Guidelines are available in 21 languages on its
website.

Unavailable

Available (“Aeon Sustainable Procurement Principles” which
includes fishery products)*No reference to human rights risks.

Available ( “Seven & i Group Sustainable Sourcing
Principles and Policies” and “Sustainable Procurement of
Raw Materials” which includes fishery products)* No reference to human rights risks.

Available (Policy for Sustainable Supply Chain Management)* From publicly available information, there is only a mention of "suppliers," and the extent of disseminationis unclear.
[Features]•
Sharing of this Policy in its contracts with suppliers. Ability to request supplier corrections.Contract
termination option for non-compliance.

Available (Tuna Procurement Guidelines)*References to human rights risks. However, the effectiveness in preventing or mitigating negative
impacts on human rights remains unclear.
Partially implemented[Features]
HRDD method: Disclosed somewhat concretely, but the actual details are unclear.
•
Conducting a risk assessment for tuna suppliers → Disclosed as "conducting" without further
details.
•
External Audits to tunas suppliers → Disclosed as “scheduled to start from 2022 and make it aregular measure byl 2025.”•
Improvement of monitoring on boats → Disclosed as “under consideration since 2022.”

Unavailable

Unavailable

Results of HRDD:
Partially disclosed. Only the implementation status and outcomes of the action plan from the 2017
"Bluefin Tuna Sustainable Sourcing Policy," are provided.

Grievance Mechanism for thetuna supply chain

Available (Grievance Mechanism as a point of contact for external stakeholders)* The governance mechanism includes tuna but is limited to specific product categories.
* The target companies are limited to self-owned, group companies, and suppliers covered by the“Sustainable Supply Chain Survey.”* Supported languages are limited to Japanese, English, and Chinese.

Unavailable

Participation in multi-stakeholder platforms on labor rights issues in the fisheries industry (UN Global
Compact Sustainable Ocean Principles (SOP) Action Platform, SeaBOS, etc.)

Suppliers List Open to the
Public for the tuna supply
chain

60

Unavailable

Unavailable

Available (External Hotline)*Product and company specifics are unclear.
*Supported languages: Japanese and English only.

No specific information available regarding the tuna supply
chain.
*Information is available regarding the general supply chain.
*The construction of the HRDD cycle is scheduled to becompleted in FY2025.

Available (Supplier Hotline)*Targeted products: Private label items only (uncertain if tuna is
included).
*Targeted companies: Only those in the supply chain of a private
label products.
*Supported languages: Japanese, English, Chinese, Vietnamese.
Other languages such as Burmese, Khmer, Thai, Tagalog,
Indonesian, Bengali, Malay are in preparation.
*Operated by a third-party organization (ASSC).

Unavailable

Unavailable*Stakeholder dialogue is ongoing, but details on theframework and practices, especially for tuna, remain
unclear.

Conducting
Participation in Global Sustainable Seafood Initiative(GSSI)

Unavailable

Unavailable

Unavailable

Conducting
Dialogue with Stakeholders forthe tuna supply chain

No specific information available regarding thetuna supply chain.
* Information is available regarding the general
supply chain.
[Features]•
In FY 2019, third-party assessments wereconducted for timber suppliers' forest
management practices. Implementation
status for other suppliers remains unclear.

No specific information available regarding the tuna
supply chain.
* Information is available regarding the general supply
chain.
[Features]•
Third-party audits of private label manufacturing
facilities in China and Southeast Asia are
conducted based on internally created criteria (16categories, 117 check items).
•
Pre-notified factory visits involve on-site
inspections, document/data verification, andinterviews with managers and workers to assess
CSR compliance.

Available (Seven & i HLDGS. Helpline for Suppliers)*Product and company specifics are unclear.
*Supported language: Japanese only.
*Operated by a third-party organization (IntegreX Inc.)

Unavailable*Stakeholder dialogue is ongoing, but details on theframework and practices, especially for tuna, remain
unclear.

Unavailable

The color-coding criteria for Table 9 are as follows. It's important to note that even if a category is

Green: Items that can be evaluated to a certain degree, but there is still room for improvement.

labeled as green, it doesn't mean that the practice is both necessary and sufficient; there is room for

Yellow: Insufficient, but some action is being taken.

further improvement.

Red: Urgent action is required.

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3. Limitations in government and corporate actions

Case Study - How Human Rights Violating Seafood Was Distributed in Japan Without Any
Problem - The Longxing Case128

To combat forced labor and human trafficking in tuna fishing, Japanese companies thatimport, distribute, and sell tuna need to identify and respond to human rights abuses in their

The Longxing 629 operated in WCPFC waters from March 2019 to April 2020. Of the 24 Indonesian

supply chains. However, as discussed above, the supply chain for tuna in the Japanese market

fishers who sailed on the vessel, four died of unknown causes. The bodies of the three fishers who

is so complex and opaque that it is nearly impossible to determine the exact country of origin.

died at sea were dumped at sea.

Meanwhile, the Japanese government is unable to identify and respond to forced labor and

The surviving fishers recounted horrific events of being subject to human trafficking. The fishers

human trafficking during the fishing process because it only checks for compliance with theworked 18 hours a day for 13 months and were paid, on average, a total of 500 USD. Five of the

CMMs of RFMOs when importing tuna. In the event of forced labor and human trafficking, it

victims were paid only 120 USD, which is only 3.1% of the wages they were promised. While thewould be difficult for migrant fishers to seek redress against Japanese companies, as there

Chinese fishers were drinking bottled water, the Indonesian fishers were forced to drink poorly

is no system in place to hold them accountable for human rights issues in their supply chains

purified seawater. The crew was stuck on the ship for 13 months, as the vessel was not required toacross borders. As a result, complex and opaque supply chains conceal the risks of forced

make any port calls due to multiple transhipments.

labor and human trafficking that are prevalent in the tuna fishery and allow the system tooperate with no one held accountable for human rights violations.

The Longxing 629 is suspected of having engaged in IUU fishing, including shark finning andcatching protected species. Photographs taken by the crew showed Shortfin Mako Sharks,
Scalloped Hammerhead Sharks, and White Sharks, all of which are protected as endangered
species under the Convention on International Trade in Endangered Species of Wild Fauna andFlora (CITES).
The Longxing 629 was owned by Dalian Ocean Fishing ("DOF") of China, and one of DOF's largest
customers was Mitsubishi of Japan. In addition, on at least two occasions while the Longxing 629
was fishing without a port of call, Japanese carriers transhipped its catch to Japanese ports. After
witnessing the death of a colleague onboard the Longxing 629, one fisher expressed a desire toterminate his contract and return to Indonesia, and attempted to return home via the carrier, but
was refused.
Notably, Mitsubishi has claimed that it ensures human rights are protected in its supply chainsthrough "dialogue sessions" and, since 2017, "an annual questionnaire" with its suppliers. However,it also reported that it "remained unaware" of labor abuses on DOF vessels until the reported
deaths of the four fishers in 2020, demonstrating that its dialogue and questionnaire failed in
identifying the reported labor and human rights abuses involved in the incident and reported inother interviews. Given that DOF is not the only fishing company likely involved in labor and humanrights abuses and that Mitsubishi's system to verify human rights violations among suppliers has
failed before, Mitsubishi ought to review the human rights risks in its seafood supply chain, andestablish improved measures to address the identified risks.

Sharks finning in Longxing 629 © APIL

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V. Recommendations:
For Tuna Free of Human Rights Risks
1. To the Korean government (Mainly from the perspective ofprotecting workers)
1.

Ratify the Work in Fishing Convention (ILO C188), and bring domestic laws in line withinternational standards to improve the safety, health, medical care, living conditions, and laborrights of migrant fishers.

2. Ensure public and governmental oversight over the recruitment and immigration processesof migrant fishers, and thereby address illegal practices of wage deduction and charging ofrecruitment fees.
3. Guarantee non-discrimination against migrant fishers, particularly in wages, working
conditions, and living conditions compared to Korean fishers.
4. Review the implementation status of the ban on passport confiscation; amend the Seafarers
Act to extend the prohibition on passport confiscation for recruitment agencies, captains, andfishers.
5. Inspect implementation of the measure on imposing upper limit to sailing period; limit all DWF
sailing periods to 6 months.
Katsuura Fish Port ©Shutterstock

6. Conduct effective labor inspections on DWF vessels, and disclose their results withtransparency.
7.

Establish victim support measures for DWF migrant fishers within the comprehensive plan on
human trafficking.

8. Actively participate in the ratification of labor standards discussed in RFMOs, such as the
WCPFC.

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2. To the Japanese government (Mainly from the perspectiveof business and human rights)
1.

3. For Japanese corporations importing seafood
1.

Develop guidelines for suppliers, incorporate compliance clauses in all supplier contracts, andRatify the Work in Fishing Convention (ILO C188), and bring domestic laws in line with

conduct independent and effective regular audits, including direct interviews with downstream

international standards to improve the safety, health, medical care, living conditions, and labor

suppliers. Monitor and ensure thorough enforcement of these guidelines.

rights of fishers including migrant workers.
2. Revise the Special Law for Strengthening Conservation and Management of Tuna Resources(the Tuna Management Law) and Act on Ensuring the Proper Domestic Distribution andImportation of Specified Aquatic Animals and Plants (Aquatic Products Act). This entails
an expansion of the mandatory fisheries certification to cover a broader range of seafood
products. Additionally, as part of the certification criteria, it is essential to consider not only
the absence of IUU fishing activities but also to ensure throughout the entire supply chainthat the seafood products are not associated with human rights violations, including forcedlabor, human trafficking, and child labor. Furthermore, mandate Japanese fishing actors to
obligatorily create and submit reports such as fishing vessel voyage reports, trading partner
reports, and seafood product reports for domestically harvested seafood to the enhancementof international traceability standards for seafood products.
3. Develop regulations that not only restrict the importation of IUU-fished products but also
prohibit imports where there's a risk of human rights violations. Contribute to strengthening
international standards for human rights and labor conditions in fishing activities.
4. Enact legislation mandating the disclosure of supply chain lists and the appropriate human

2. Establish specific procurement policies and guidelines considering unique international
standards and human rights risks in the fisheries industry. This should include theimplementation of onboard monitoring systems and external audits for suppliers.
3. Conduct human rights due diligence for the identification, prevention, and mitigation of humanrights risks concerning the seafood industry, and disclose its process, progress, challenges,
and identified human rights risks to ensure accountability.
4. Build a grievance mechanism accessible to fishers. Given the prevalence of migrant labor
exploitation, especially in the fisheries industry, ensure multilingual support to address theneeds of affected workers.
5. Conduct ongoing dialogues with stakeholders in the fisheries industry and obtain stakeholder
consent to publicly disclose the specific details of these dialogues.
6. Identify and publicly disclose all suppliers, including harvesters and vessels, up to the final
supplier. Work across the industry to enhance traceability of seafood products, addressing
issues such as regulations on transhipment at sea.

rights due diligence for all companies, including those in the fisheries industry.
5. Establish a public helpdesk where all companies, especially small and medium-sizedenterprises, including those in the fisheries industry, can seek advice on the implementationof appropriate human rights due diligence.
6. Actively support the ratification of labor standards being discussed in RFMOs such as the
WCPFC.

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4. To the Regional Fisheries Management Organizations
1.

For the WCPFC, to adopt the Conservation and Management Measure on labor standards at its
21th Regular Session, in order to ensure protection of fishers and promote responsible fishing.

2. For RFMOs other than the WCPFC, particularly those on tuna conservation, to proactively
discuss and adopt labor standards to ensure human rights of fishers.
3. Closely monitor implementation of, and states’ compliance with, transhipment measures;
disclose records of reported transhipments and strengthen transparency in the transhipment
process.

Fishing vessel in Pacific Ocean © Adobe Stock

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Endnotes
1.

Yozell, S., & Shaver, A. (2019) 「Shining a Light: The Need for Transparency across Distant Water Fishing」, Stimson.
Available at: https://stimson.org/wp-content/files/file-attachments/Stimson%20Distant%20Water%20Fishing%20

15. Ministry of Oceans and Fisheries (2021) "Statistical Survey of DWF", Number of workers. https://kosis.kr/statHtml/
statHtml.do?orgId=146&tblId=DT_MLTM_5002622&conn_path=I2 (Accessed: 27 October 2023)
16. Article 2 (Definitions) of the Distant Water Fisheries Development Act, Subparagraph 12 & 13
12. The term “illegal fisheries” means any of the following fisheries activities:

Report.pdf (accessed 27 October 2023)(a) Fisheries operations or fisheries activities in any waters under the jurisdiction of any state, conducted by a ship of
the said state or a foreign state without a permit from such state, or in violation of the law of such state; (b) Fisheries

2.

Ministry of Oceans and Fisheries (2022) "Statistical Survey of Pelagic Fisheries in 2022". https://www.ofis.or.kr/boards/

activities engaged in by a ship of a member state of any international fisheries organization in violation of a legally binding

view/board_stats/19692 (accessed 27 October 2023).

preservation and management measure of the said international fisheries organization, or any provision of the relevantinternational law; (c) Fisheries activities conducted in violation of domestic law or international duty of the relevant state,3.

including states which cooperate with an international fisheries organization;

National Institute of Fisheries Science, "Fishing Mode Diagram". https://www.nifs.go.kr/contents/

13. The term “unreported fisheries” means any of the following fisheries activities:

actionContentsCons0103.do (accessed 27 October 2023).
4.

(a) Fisheries operation conducted in waters under the jurisdiction of any state, for which a report has not been or has
been made falsely to the relevant authorities in violation of the domestic law of such state;

Reconstructed from KOTRA homepage. Jin, Seoksoon (2022.8.8) "Tuna Market Trends in Japan", Korea Trade-Investment(b) Fisheries operation conducted in any waters under the jurisdiction of an international fisheries organization, for which

Promotion Agency (KOTRA). https://dream.kotra.or.kr/kotranews/cms/news/actionKotraBoardDetail.do?SITE_

a report determined by the international fisheries organization has not been made or has falsely been made;NO=3&MENU_ID=430&CONTENTS_NO=1&bbsGbn=254&bbsSn=254&pNttSn=195658 (accessed 27 October 2023).
5.

Sajo Group, "DWF Business". https://ind.sajo.co.kr/business/pelagic.asp (accessed 27 October 2023).

6.

Dongwon NOW (2019.2.10) "How many ships does Dongwon Group own?", Dongwon Group. https://media.dongwon.com/

14. The term “unregulated fisheries” means any of the following fisheries activities:(a) Fisheries activity in any waters under the jurisdiction of an international fisheries organization, engaged in by astateless ship or a ship of a non-member state or virtual non-member state of the international fisheries organization in
non-conformity with or in violation of a preservation and management measure of the said organization;(b) Fisheries activity conducted in any waters not subject to a preservation and management measure of an international
fisheries organization or conducted with respect to fisheries resources in circumvention of any obligation of states for

post/512 (accessed 27 October 2023)
7.

Dongwon Fisheries, "Tuna voyage". http://www.dongwonfish.co.kr/?t=deep&s=page02 (accessed 27 October 2023).

8.

Silla, "Tuna longliner". http://www.sla.co.kr/b_sea03.htm (accessed 27 October 2023).

9.

Ministry of Oceans and Fisheries (2021) "Statistical Survey of DWF," Production Status by Industry. https://kosis.kr/
statHtml/statHtml.do?orgId=146&tblId=DT_MLTM_5002625&conn_path=I2 (Accessed: 27 October 2023)

10. International Seafood Sustainability Foundation (ISSF), "Lognline". https://www.iss-foundation.org/tuna-stocks-andmanagement/tuna-fishing/fishing-methods/longline/ (accessed 27 October 2023).
11.

Sustainable Fisheries Partnership (SFP) (2022.12) "Reversing the Decline of Sharks, Sea Turtles, and Seabirds in theWestern Central Pacific Ocean". https://drive.google.com/file/d/1iMSROtO9_8wM4UxcFUEL3nzQdE3Hbmft/view

the preservation of living marine resources under international law; https://www.law.go.kr/%EB%B2%95%EB%A0%B9/%E
C%9B%90%EC%96%91%EC%82%B0%EC%97%85%EB%B0%9C%EC%A0%84%EB%B2%95 (accessed 27 October 2023)
17.

org/9650/20200406212646/http:/p3-raw.greenpeace.org/korea/Global/korea/publications/reports/oceans/2013/apr2013-iuu-report-kor.pdf (accessed 27 October 2023).
18. Ibid.
19. Environmental Justice Foundation (EJF) (2019) 「Blood and Water: Human rights abuse in the global seafood industry」, p.
23, p. 25. https://ejfoundation.org/resources/downloads/Blood-water-06-2019-final.pdf
20. Hare, S. R. et al. (2021) "The Western and Central Pacific Tuna Fishery: 2020 Overview and Status of Stocks", PacificCommunity, pp. 18-19, p. 37. https://www.spc.int/resource-centre/publications/the-western-and-central-pacific-tuna-(accessed 27 October 2023).
12. Jacobson, P., & Gokkon, B. (2022.12.2) "'It was a shark operation': Q&A with Indonesian crew abused on Chinese sharkfinning boat", Mongabay Series. https://news.mongabay.com/2022/12/it-was-a-shark-operation-qa-with-indonesiancrew-abused-on-chinese-shark-finning-boat/ (accessed: 27 October 2023)
13.

Greenpeace Seoul Office (2016.1.5) "Is Tuna the Only Thing in a Tuna Can?", Greenpeace. https://www.greenpeace.org/
korea/update/6816/blog-ocean-does-your-canned-tuna-only-have-tuna/ (accessed: 27 October 2023)

14. WWF, "Factsheet: Human Rights Issues at Sea". https://wwfasia.awsassets.panda.org/downloads/human_rights_issues_
at_sea__final___1__1.pdf (accessed 27 October 2023).

70

Park, Ji-hyun (2013), "Report on IUU Fishing in Korea," Greenpeace. https://wayback.archive-it.

fishery-2020-overview-and-status (accessed August 18, 2023).
21.

Tickler, D. et al. (2018) "Modern slavery and the race to fish", Nature communications, 9(1) https://www.nature.com/
articles/s41467-018-07118-9

22. Values are based on bluefin and bigeye tuna, which are used exclusively as sashimi tuna, excluding skipjack and yellowfin
tuna, which are mostly used in processed foods such as canned food.
23. Ministry of Oceans and Fisheries (2021) 「Statistical Survey of DWF」, Export Status by Species. https://kosis.kr/statHtml/
statHtml.do?orgId=146&tblId=DT_MLTM_5002628&conn_path=I2 (accessed 27 October 2023)

7124. Ministry of Oceans and Fisheries (2021) 「Statistical Survey of DWF」, Export Status by Country. https://kosis.kr/statHtml/

35. Campling, L. et al. (2017) "The Tuna Longline Industry in the Western and Central Pacific Ocean and its Market Dynamics",

statHtml.do?orgId=146&tblId=DT_MLTM_5002629&conn_path=I2 (accessed 27 October 2023) A report by the FFA puts

Pacific Islands Forum Fisheries Agency (FFA). Available at: https://www.ffa.int/system/files/Campling-Lewis-McCoy%20

the figure at 70 percent.

2017%20The%20Tuna%20%20Longline%20Industry.pdf (accessed 27 October 2023).

25. Ministry of Oceans and Fisheries (2021) 'Statistical Survey of DWF', Export Status by Country. https://kosis.kr/statHtml/

36. Korea Trade Statistics Institute. "Detailed Import and Export Statistics". https://bandtrass.or.kr (accessed 27 OctoberstatHtml.do?orgId=146&tblId=DT_MLTM_5002629&conn_path=I2 (accessed 27 October 2023)
26. Food and Agriculture Organization of the United Nations (2022) "The State of World Fisheries and Aquaculture 2022".

2023).
37. CCSBT. "Catch Documentation Scheme Data" https://www.ccsbt.org/en/userfiles/file/data/CDS_Report.xlsx (accessed

Available at: https://www.fao.org/3/cc0461en/online/sofia/2022/consumption-of-aquatic-foods.html#note-1_24

27 October 2023)(accessed 27 October 2023).
38. CCSBT. (2019.10.27) 「Korea: 2021 Annual Report to the Compliance Committee and the Extended Commission." https://
27. Our World in Data (2023.6.12), "Fish and seafood consumption per capita, 2020". Our World in Data. https://ourworldindata.

www.ccsbt.org/system/files/CC16_SBTFisheries_KR.pdf (accessed 27 October 2023)

org/grapher/fish-and-seafood-consumption-per-capita?tab=chart (accessed on 27 October 2023); Lang'at, V.
(2018.12.12) "Countries That Eat The Most Fish", WorldAtlas. https://www.worldatlas.com/articles/countries-that-eat-themost-fish.html (accessed on 27 October 2023)

39. Global Fishing Watch et al. (2021) "Strengthening Regulation, Monitoring and Control of Global Seaborne Reproduction
Activities". https://globalfishingwatch.org/wp-content/uploads/korean-contributions-from-the-ground.pdf (accessed 27
October 2023).

28. Campling, L. et al. (2018) "FFA Trade and Industry News 11(1)", Pacific Islands Forum Fisheries Agency (FFA). https://www.ffa.int/node/2055 (accessed 27 October 2023); Lecomte, M. et al. (2017) "Tuna: fish and fisheries, markets andsustainability", Développement Durable & Relations Internationales (IDDRI). https://www.iddri.org/sites/default/files/

40. Environmental Justice Foundation (EJF) (2018) 「Out of the shadows. Improving transparency in global fisheries tostop illegal, unreported and unregulated fishing」. Available at: https://ejfoundation.org/reports/out-of-the-shadows-

IMG-PHOTOS/Publis-Covers/201811-Tuna-gloablEN.pdf (accessed: 27 October 2023); Kawamoto, T. (2016) "Tuna market

improving-transparency-in-global-fisheries-to-stop-illegal-unreported-and-unregulated-fishing (Accessed: 27 Octoberin Japan: challenges and prospects", INFOFISH. https://www.srilankabusiness.com/pdf/seafood_article.pdf (accessed: 272023).

October 2023)
29. Klein, C. (2022.11.25) "Number of fishing vessels owned in Japan 2003-2018", Statista. https://www.statista.com/
statistics/1284108/japan-number-of-fishing-vessels-owned/ (accessed: 27 October 2023)
30. Loew, C. (2020.6.24) "Japan's fisheries white paper reviews trends of FY 2019", SeafoodSource. https://www.
seafoodsource.com/news/supply-trade/japan-s-fisheries-white-paper-reviews-trends-of-fy2019 (accessed: 27 October2023); Ocean Policy Research Institute (OPRI) (2021.4.20) "The Marine Products Industry's Reliance on Foreign Workers
and the Issue of Continuity". Available at: https://www.spf.org/en/opri/newsletter/497_1.html?full=497_1 (Accessed: 27

41.

Talwar, M., & Mulvaney, K. (2023) "The High Cost of Cheap Tuna", Greenpeace https://www.greenpeace.org/usa/wpcontent/uploads/2023/02/Tuna-Retailer-Report-2nd-Edition-.pdf (accessed: 27 October 2023)

42. The IOTC, ICCAT, IATTC, and CCSBT only allow transhipment at-sea for tuna longliners.
43. Pew Trust. (2019) "Transhipment in the Western and Central Pacific." https://www.pewtrusts.org/-/media/
assets/2019/09/international_fisheries_transshipment_report.pdf (accessed 27 October 2023).

October 2023)
44. In 2019, Korea-flagged carrier vessels reported 79 transhipments in the Western Central Pacific, while location data
31.

Klein, C. (2022.10.5) "Production volume of tuna through marine fishing in Japan from 2012 to 2021", Statista. https://www.

revealed that they performed up to 201 transhipments.Ibid.

statista.com/statistics/762351/japan-tuna-production-volume/ (accessed: 27 October 2023) This statistic shows asteady decline in Japanese tuna production every year, except for a small increase in 2020.

45. CCSBT. (2022) "Report of the Seventeenth Meeting of the Compliance Committee." https://www.ccsbt.org/sites/default/
files/userfiles/file/docs_english/meetings/meeting_reports/ccsbt_29/report_of_CC17.pdf (accessed 27 October 2023)

32. Organization for Economic Co-operation and Development (OECD) (2021.1) "Fisheries and Aquaculture in Japan". OECD.
https://www.oecd.org/agriculture/topics/fisheries-and-aquaculture/documents/report_cn_fish_jpn.pdf (accessed

46. Request for Information Disclosure No. 11303127 (2023.9.26)

27 October 2023); Loew, C. (2022.4.11) "Japan's farmed bluefin sector found stronger footing in 2021", SeafoodSource.
https://www.seafoodsource.com/news/aquaculture/japans-farmed-bluefin-sector-found-stronger-footing-in-2021(accessed 27 October 2023)
33. FFA Trade and Industry News. (2018) Volume 11: Issue 1 January-February 2018 https://www.ffa.int/node/2055 (accessed
27 October 2023)

47. Pew Trusts. (2022) “Global Transshipment: working to make transfers of catch transparent, legal, and safe.” https://www.
pewtrusts.org/en/research-and-analysis/articles/2018/02/global-transshipment (accessed 27 October 2023)
48. The Global Fishing Watch identifies “potential transhipment” as a case where a fishing vessel and a carrier vessel remains
in the same location without movement for more than 3 hours. Global Fishing Watch "Carrier Vessel Portal" https://globalfishingwatch.org/carrier-vessel-portal/ (accessed 27 October 2023)

34. National Legislation Information Center. "Notice on Permission to Tranship Fish Catch in Overseas Waters (Enforced on
August 18, 2021)." https://www.law.go.kr/admRulLsInfoP.do?chrClsCd=&admRulSeq=2100000203818#AJAX (accessed
27 October 2023)

72

49. ICCAT. "Vessel Information: Meita Maru" https://www.iccat.int/en/VesselsRecordDet.asp?id=8188 (accessed 27 October
2023)

73

50. IOTC, "Vessel Information: Oryong 371" https://iotc.org/vessels/history/125781 (accessed 27 October 2023)

65. Dongwon Industries (2021) "Half-Yearly Report (General Corporation)". https://kind.krx.co.kr/common/disclsviewer.do?method=searchInitInfo&acptNo=20210813001291&docno= (accessed 27 October 2023).

51.

A search on the WCPFC site of vessels under Japan's flag authorized for transshipment on the high seas turns up six
vessels under the ownership of four companies: Toei Reefer Line Ltd (two vessels: Kenta Maru and Gouta Maru), Taise

66. Dongwon Industries, "Distribution Business". https://www.dwml.co.kr/contents/distribution/distribution (accessed 27

Maru Shipping Co. Ltd. (two vessels: Taise Maru No. 15 and No. 24), Suyashoten Co. Ltd. (one vessel: Suwa Maru No. 22)

October 2023).

and A-Hamahiro Co. Ltd (one vessel: No. 27 Sawajiri). In addition, there are 11 vessels owned or operated by Japanesecompanies, including five vessels that are Panama-based but operated by Japanese carriers, that are officially registeredwith the WCPFC, as shown below. A further eight vessels are owned by four Panama-addressed companies (3 vessels of
Panama TRL SA, 3 vessels of Star Navigation, and 1 vessel each for Oceanwide Shipping SA and United Reefer SA), butthey have Japanese names and are listed with Japanese masters. A further two vessels under two companies (Sea Road

67. Dongwon Fisheries, "Tuna voyage". http://www.dongwonfish.co.kr/?t=deep&s=page02 (accessed 27 October 2023).
68. Dongwon Fisheries (2021) "Half-yearly Report (General Corporation)". https://kind.krx.co.kr/common/disclsviewer.do?me
thod=searchInitInfo&acptNo=20210817001262&docno= (accessed 27 October 2023).

Line Inc. in Liberia and Wang Tat Co., PTE, Ltd. in Singapore) are owned by companies with addresses in other states, butthey have Japanese names and are listed with Japanese masters.

69. Yu Wang, "Facility Status". http://www.youwang.co.kr/business01.php (accessed 27 October 2023).
52. Toei Reefer Line Ltd., "Company profile" https://www.toeireefer.co.jp/about/outline.html (accessed 27 October 2023)
70. Silla, "Tuna longiners". http://www.sla.co.kr/b_sea03.htm (accessed 27 October 2023).
53. WCPFC. "Vessel Information: Kenta Maru" https://vessels.wcpfc.int/vessel/11656 (accessed 27 October 2023)
71.

tInfo&acptNo=20211115000597&docno= (accessed Aug. 19, 2023).

54. WCPFC. "Vessel Information: Gouta Maru" https://vessels.wcpfc.int/vessel/11398 (accessed 27 October 2023)
55. IOTC. "Vessel Information: Kurikoma" https://iotc.org/vessels/history/102969 (accessed 27 October 2023)
56. IOTC. "Vessel Information: Meita Maru" https://iotc.org/vessels/history/131323 (accessed 27 October 2023)
57. IOTC. "Vessel Information: Genta Maru" https://iotc.org/vessels/history/123921 (accessed 27 October 2023)
58. The information in this paragraph was sourced from the following sources Campling, L. et al. (2018) "FFA Trade andSilla, (2021) "Half-yearly report (general corporation)". https://kind.krx.co.kr/common/disclsviewer.do?method=searchIni

72. Silla SG, "Distribution Business". http://www.sillasg.co.kr/m/business.php (accessed 27 October 2023).
73. Silla, "Fleet Introduction". http://www.sla.co.kr/b_csea.htm (accessed 27 October 2023).
74. Silla SG, "Distribution Business". http://www.sillasg.co.kr/m/business.php (accessed 27 October 2023).
75. Silla, "Fleet Introduction". http://www.sla.co.kr/b_csea.htm (accessed 27 October 2023).

Industry News 11(1)", Pacific Islands Forum Fisheries Agency (FFA). Available at: https://www.ffa.int/node/2055 (Accessed:
27 October 2023)
59. Japan Ministry of Agriculture, Forestry and Fisheries, 「FY2021 Trends in Fisheries FY2022 Fisheries Policy Summary」, pp.

76. Ibid.
77. Sojitz (2008.9.8) "Sojitz to Enter the Tuna Farming Business". The Japan Times. https://www.sojitz.com/en/
news/2008/09/20080908.php (accessed 27 October 2023); Sojitz Tuna Farm Takashima Corporation. https://www.sojitz-

15-16. https://www.jfa.maff.go.jp/j/kikaku/wpaper/attach/pdf/index-2.pdf (accessed 27 October 2023).

tunafarm.com/en/ (accessed 27 October 2023); Kimura, K. (2022.2.8) "マグロが食べられなくなる？ 養殖の現場から見えてきた海洋資源のゆくえ", Caravan. https://www.sojitz.com/caravan/special/tuna/1.html (accessed 27 October 2023)

60. Sajo Industry, "DWF Business". https://ind.sajo.co.kr/business/pelagic.asp (accessed 27 October 2023).
61. Sajo Seafood (2022) "Quarterly Report (General Corporation)". Available at https://kind.krx.co.kr/common/disclsviewer.do

78. Gyokai Chizu (2020.8). "Nikkei Gyokai Chizu" https://www.cdjapan.co.jp/product/NEOBK-2525480 (accessed 27 October
2023)?method=searchInitInfo&acptNo=20220512000136&docno= (accessed 27 October 2023).
62. Sajo Industry (2022) "Quarterly Report (General Corporation)". Available at https://kind.krx.co.kr/common/disclsviewer.do

79. International Labor Organization (ILO), "C029 - Forced Labor Convention," 1930 (No. 29), http://ilo.org/dyn/normlex/en/f?
p=NORMLEXPUB:12100:0::NO::P12100_ILO_CODE:C029 (accessed: 27 October 2023).

?method=searchInitInfo&acptNo=20220513001245&docno= (accessed 27 October 2023).
63. Sajo Seafood, "Frozen Storage Business". http://sf.sajo.co.kr/business/freezeStorage.asp (accessed 27 October 2023).
64. Mitsubishi provided operational advice, a fishing boat, and a start-up loan of about $500,000 to help establish Dongwon
Industries, and it is no secret that the two companies have engaged in a close relationship ever since. Dongwon Food's
official blog (July 30, 2014) "A relationship with Japan's Mitsubishi Corporation that has been built on trust and faith!
[Dongwon F&B Blog]", https://m.blog.naver.com/dongwon_well/220076260901 (accessed on 27 October 2023)

74

80. International Labour Organization (ILO), (2012) "ILO indicators of Forced Labour", https://www.ilo.org/global/topics/
forced-labour/publications/WCMS_203832/lang--en/index.htm (accessed: 27 October 2023)
81.

United Nations Office of the High Commissioner for Human Rights (UN OHCHR),「Protocol to Prevent, Suppress andPunish Trafficking in Persons Especially Women and Children」 https://www.ohchr.org/en/instruments-mechanisms/
instruments/protocol-prevent-suppress-and-punish-trafficking-persons (accessed: 2023.10.27)

75

82. For more information on how migrant workers' susceptibility and vulnerability contribute to their trafficking throughout
the process of working on longliners, see the report “Captured at Sea”.Advocates for Public Interest Law & International

96. United States Department of State (2023) “2023 Trafficking in Persons Report: Korea, Republic of (Tier 2)” https://www.
state.gov/reports/2023-trafficking-in-persons-report/south-korea/ (accessed 27 October 2023)

Organization for Migration Office of South Korea (2017), “Caught at Sea”. Available at https://apil.or.kr/reports/8814(accessed 27 October 2023).

97. Ministry of Gender Equality and Family (27 March 2023), “First Comprehensive Plan on Prevention of Human Trafficking,etc. (2023~2027)” . http://www.mogef.go.kr/nw/enw/nw_enw_s001d.do?mid=mda703&bbtSn=710955 (accessed 27

83. Environmental Justice Foundation (EJF) https://ejfoundation.org/ (accessed October 29, 2023)
84. Advocates for Public Interest Law (APIL) https://apil.or.kr/ (accessed October 29, 2023)

October 2023)
98. まぐろ資源の保存及び管理の強化に関する特別措置法. https://elaws.e-gov.go.jp/document?lawid=408
AC1000000101_20150801_000000000000000 (accessed 27 October 2023); for an English translation, see. Act on

85. Detailed findings can be found in the following report. English: Advocates for Public Interest Law (APIL) & Environmental
Justice Foundation (EJF) (2023) 「Korea’s Migrant Fishers Plan fails to end human rights abuses at sea」. https://apil.

Special Measures for Enhancement of the Conservation and Management of Tuna Resources. https://faolex.fao.org/
docs/pdf/jap153731.pdf (accessed 27 October 2023).

or.kr/reports/3005637320 (accessed 27 October 2023).
99. National Fishery Products Quality Management System, Ministry of Oceans and Fisheries, "International Fisheries". http://
86. Korea Federation for Environmental Movements (2020.6.90) "[Press Release] Korea's longline fishing fleet ranks first

www.nfqs.go.kr/hpmg/quar/actionInterantionFisherForm.do?menuId=M0000197 (accessed 27 October 2023).

in the world for the amount of time fishers are “confined” on ships and first in the world for working hours at sea". http://kfem.or.kr/?p=207628 (accessed 27 October 2023).

100. https://www.jfa.maff.go.jp/e/, https://www.jfa.maff.go.jp/j/enyou/tuna/ "As of April 1, 2018, the pre-certification
application process for frozen tuna will be consolidated and managed by the Fisheries Agency. (Until March 31, 2018, the87. Campling, L. et al. (2017) "The Tuna Longline Industry in the Western and Central Pacific Ocean and its Market Dynamics",
Pacific Islands Forum Fisheries Agency (FFA). Available at: https://www.ffa.int/system/files/Campling-Lewis-McCoy%20

process was carried out in two stages: submission and verification of relevant documents to the Fisheries Agency, andapplication to the Ministry of Economy, Trade and Industry for issuance of a certificate.)"2017%20The%20Tuna%20%20Longline%20Industry.pdf (accessed 27 October 2023).
101. A translation of the above chart from the Ministry of Economy, Trade and Industry on import procedures can be found
88. Ministry of Oceans, Maritime Affairs and Fisheries (2020.12.07) "Wages for Foreign Fishermen to Become Transparent
and Working Conditions to Improve", Korea Policy Briefing. https://www.korea.kr/briefing/pressReleaseView.
do?newsId=156425353 (accessed 27 October 2023).
89. Advocates for Public Interest Law (APIL), (2020.12.10) "[Position Paper] Position of Civil Society Organizations on the
Ministry of Oceans and Fisheries' Plan for Implementation of Working Conditions for Migrant Crews at Sea". https://apil.
or.kr/news/16404
90. Advocates for Public Interest Law (APIL) & Environmental Justice Foundation (EJF) (2023) 「Korea’s Migrant Fishers Plan

at the bottom of this webpage. 日本 経済産業省, "まぐろ類の輸入管理（事前確認・通関時確認)". https://www.meti.go.jp/
policy/external_economy/trade_control/03_import/05_maguro/import_maguro.html (accessed 27 October 2023). The
original chart clarifies two points 1."Other tuna" refers to tuna species other than yellowfin tuna, bigeye tuna, southern
bluefin tuna, and skipjack tuna. 2. When importing bluefin tuna (fresh or frozen of Thunnus thynnus from the Atlantic
or Mediterranean Sea) and southern bluefin tuna (fresh or frozen of Thunnus thynnus from the Southern Ocean), a"Customs verification of certification at the time of import declaration" procedure may be required. More details can befound below. 日本 経済産業省, "特定地域からの輸入規制 (２号承認)". https://www.meti.go.jp/policy/external_economy/

trade_control/04_kamotsu/02_import/import_2go.html (accessed 27 October 2023) Chart on pre-verification: 日本 水産庁, "冷凍まぐろ類の事前確認制度の流れ". https://www.jfa.maff.go.jp/j/enyou/tuna/attach/pdf/index-100.pdf (accessed
Aug. 19, 2023).

fails to end human rights abuses at sea」. https://apil.or.kr/reports/3005637320 (accessed 27 October 2023).
102. Japan Fisheries Agency, "Act on Ensuring the Proper Domestic Distribution and Importation of Specified Aquatic Animals
91. Act on the Prevention of Human Trafficking, etc. and Protection of Victims https://www.law.go.kr/법령/인신매매등방지및피
해자보호등에관한법률/(18100,20210420) (Accessed: 27 October 2023)

and Plants (Act No. 79 of December 11, 2020)". https://www.jfa.maff.go.jp/attach/pdf/220614-1.pdf (accessed 27 October2023); Japan Fisheries Agency, 「Act on Ensuring the Proper Domestic Distribution and Importation of Specified Aquatic
Animals and Plants」. https://www.jfa.maff.go.jp/220614.html (accessed 27 October 2023).

92. Committee on Gender Equality and Family (2021) "Public Hearing on the Bill on Prevention of Trafficking in Persons,
Exploitation and Protection of Victims". https://committee.na.go.kr:444/women/reference/reference05.do?mode=view&articleNo=668054&article.offset=0&articleLimit=10 (accessed 27 October 2023).
93. To this date (27 October 2023), there exists no reports on the government providing identification or protection to a
trafficking victim.

103. Japan Fisheries Agency (2022) 「TECHNICAL NOTE on Class II Aquatic Animals and Plants」. Available at: https://www.jfa.
maff.go.jp/attach/pdf/220614-3.pdf (accessed 27 October 2023).
104. Technical documentation in regards to imported Class II seafood (日本 水産庁 (2023) 「4水漁第1561号」. https://www.
jfa.maff.go.jp/j/kakou/pdf/tekiseika_class2.pdf (accessed 27 October 2023); FAQ on the law that can present additional
requirements(日本 水産庁 (2022) 「「特定水産動植物等の国内流通の適正化等に関する法律」に関するQ&A」.); other

94. Yonhap News (9.9.2023) "Anti-human trafficking law presented to the international community... but next year's budget
halved." https://www.yna.co.kr/view/AKR20230908128700530
95. Hankyoreh (2023.9.14) "Foreign Worker Support Center Budget “0 won”... Centers practically abolished." https://www.
hani.co.kr/arti/society/labor/1108536.html (accessed 27 October 2023)

76

rules applicable to import of seafood (https://www.jfa.maff.go.jp/j/kakou/pdf/tekiseika_qa_1_2211.pdf (accessed 27
October 2023))
105. Japan Fisheries Agency (2022) 「TECHNICAL NOTE on Class II Aquatic Animals and Plants」. https://www.jfa.maff.go.jp/
attach/pdf/220614-3.pdf (Accessed: 27 October 2023); 日本 水産庁, 特定水産動植物等の国内流通の適正化等に関する法律.

77https://www.jfa.maff.go.jp/j/kakou/tekiseika.html (Accessed: 27 October 2023).
106. Japan Ministry of Agriculture, Forestry and Fisheries, "FY2021 Trends in Fisheries FY2022 Fisheries Policy Summary".
Available at https://www.jfa.maff.go.jp/j/kikaku/wpaper/attach/pdf/index-2.pdf (accessed 27 October 2023); see also119. Sojitz, "Respect for Human Rights". https://www.sojitz.com/en/csr/humanrights/ (accessed 27 October 2023).
120. Sojitz, "Sojitz Group CSR Action Guidelines for Supply Chains". https://www.sojitz.com/en/csr/humanrights/ (accessed
27 October 2023).

Organization of Responsible Tuna Fisheries (OPRT). OPRT (2021) "OPRT Newsletter International No. 75". Available at:https://oprt.or.jp/eng/wp-content/uploads/2021/09/OPRT75.pdf (Accessed: 27 October 2023).

121. Sojitz (2019) "Sojitz Group Sustainability Handbook". https://www.sojitz.com/en/csr/supply/pdf/handbook_e_group_200401.pdf (accessed 27 October 2023).

107. Japan Ministry of Economy, Trade and Industry (2022.9.13) "Release of Japan's Guidelines on Respecting Human Rights in
Responsible Supply Chains". https://www.meti.go.jp/english/press/2022/0913_001.html (accessed 27 October 2023).
108. HRN has also provided detailed information on Japanese companies in two reports published in 2021. Human Rights Now(2021) "Human Rights Abuses in the Global Seafood Industry and Its Links to Japan". https://hrn.or.jp/eng/wp-content/
uploads/2022/06/HRN-Human-Rights-Abuses-in-the-Global-Seafood-Industry-and-Its-Links-to-Japan-Nov.-2021.pdf(accessed 27 October 2023); Survey report on Japanese fishing companies: Human Rights Now (2021) "Report on the
Results of a Questionnaire Survey of Japanese Fishing Companies". https://hrn.or.jp/eng/wp-content/uploads/2022/06/

122. AEON CO., LTD., "Company Overview". https://www.aeon.info/en/company/overview/ (accessed 27 October 2023).
123. AEON CO., LTD. (2019) 「AEON Supplier Code of Conduct」. https://www.aeon.info/humanrights/pdf/aeon_Supplier_CodeofConduct_English.pdf (Accessed: 27 October 2023)
124. Ibid.

HRN-Report-on-the-Results-of-a-Questionnaire-Survey-of-Japanese-Fishing-Companies-Dec.-2021.pdf (accessed 27
October 2023).

125. Seven & i Holdings Co., Ltd. (2023.4) "Corporate Profile". https://www.7andi.com/en/company/profile.html (accessed 27
October 2023).

109. Forum Fisheries Agency, 26 October, 2017, p. 88, 162, https://www.bmis-bycatch.org/system/files/zotero_attachments/
library_1/6MS8UN34%20-%20Campling%20et%20al.%20-%20The%20Tuna%20Longline%20Industry%20in%20
the%20Western%20and%20Cent.pdf
110. Id., p. 84-86.

126. Seven & i Holdings Co., Ltd. (2019) "Seven & i Group Business Partner Sustainable Action Guideline". https://www.7andi.
com/var/rev0/0004/5003/12022695049.pdf (accessed: 27 October 2023)
127. 株式会社セブン&アイ・ホールディングス, "お取引先様とともにに築く持続的発展可能なサプライチェーンの構築". https://www.7andi.com/sustainability/theme/theme7/businesspartners.html (accessed 27 October 2023).

111. As of 2023.3.31. Toyo Reizo Co.,Ltd (2023.3.31) "Company Profile". https://www.toyoreizo.com/english/index.html(accessed 27 October 2023).

128. The information in this and the following paragraphs was sourced from the following sources Giseburt, A. (2022.11.10)"How Mitsubishi vacuumed up tuna from a rogue Chinese fishing fleet", Mongabay Series. Available at: https://news.

112. 東洋冷蔵株式会社, "TOREIのサステナビリティ". https://www.toyoreizo.com/sustainability/index.html (accessed 27
October 2023).
113. 三菱商事, 「マグロ類に係る調達ガイドライン」. https://mitsubishicorp.disclosure.site/pdf/themes_126/guidelines_tpg_
ja.pdf (accessed 27 October 2023).

mongabay.com/2022/11/how-mitsubishi-vacuumed-up-tuna-from-a-rogue-chinese-fishing-fleet/ (Accessed: 27
October 2023) See also Advocates for Public Interest Law (APIL) et al. (2020) "A Briefing on Longxing 629: A case ofillegal, unreported and unregulated (IUU) fishing activities and related human rights abuses on a tuna longliner". https://
hrn.or.jp/eng/wp-content/uploads/2020/07/Briefing_on_Longxing629.pdf (accessed 27 October 2023); Oceans Inc.
(2021.9.13) "Worked to Death: How a Chinese tuna juggernaut crushed its Indonesian workforce". https://www.oceansinc.
earth/worked-to-death (accessed 27 October 2023

114. Reflects information on the number of subsidiaries and affiliates and the number of employees as of March 31, 2023;
information on the company name, representatives, capital stock, share capital, outstanding shares, offices, andsubsidiaries as of April 1, 2023; and information on the organizational structure as of July 1, 2023. Mitsubishi Corporation,"About Us". https://www.mitsubishicorp.com/jp/en/about/profile/ (accessed 27 July 2023).
115. 三菱商事, "人权", https://mitsubishicorp.disclosure.site/ja/themes/118/ (accessed 27 October 2023)
116. 三菱商事, "2021 年度 現代奴隷法に係る声明 (仮訳)". https://www.mitsubishicorp.com/jp/ja/csr/modern-slaverystatement/pdf/fy2021.pdf (accessed 27 October 2023).
117. TRY INC., "Company 会社概要". https://www.try-sangyou.co.jp/about/ (accessed 27 October 2023).
118. As of March 31, 2023. Sojitz (2023) "Corporate Profile". https://www.sojitz.com/en/corporate/profile/ (accessed 27 July2023).

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APIL is a nonprofit public interest law organization that defends the rights of vulnerable migrants
and refugees in the Korean society and monitors human rights violations by Korean companies
in overseas. Our goal is a world of justice and peace where the innate dignity and human rights ofall people are guaranteed. To this end, we advocate for the rights of refugees, detained migrants,
stateless persons, and victims of human trafficking and monitor multinational corporations for humanrights violations through litigation and petitioning, research and legislative campaigns, education andpublic relations, solidarity with national and international organizations, and the use of international
human rights mechanisms.
“Tuna in the Black Box - Human rights risks hidden in the opaque tuna
supply chain from Korean fishing vessels to Japanese market”
Date of publication:

December 2023

Authors: 		

Chanyeong Evan Moon , Researcher, APIL				

Shin Young Chung, Attorney-at-Law, APIL				

C. Cade Mosley, Researcher, HRN				Kana Kawasaki, Researcher, HRN

Acknowledgements:

Jinsuh Cho,Tae Sung Oh

Design: 			

Jeong Jae-young

Human Rights Now (HRN) is an international human rights NGO based in Tokyo, Japan, with UN special
consultative status. HRN was established in 2006 by a group of human rights professionals, such as
lawyers, scholars, and journalists, as the first international human rights NGO based in Japan. With
over 700 members comprised of various human rights specialists, HRN works for the promotion andprotection of human rights for people in the world, with a special focus on Asia.
In 2012, HRN obtained UN special consultative status, and we have actively engaged in the UN
decision-making process to protect and promote human rights ever since.
Currently, HRN has a presence in Tokyo, Osaka, New York, Geneva, and Myanmar, and our activities
extend throughout Asia and to conflict areas of the Middle East.

			(jae0chung@gmail.com)81

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