CONTENTS

Introduction.................................................................................................................................... 3
Scope............................................................................................................................................. 4
Marine ingredients sourcing policy – constructed on a risk-based approach..................................... 5
Origin of marine ingredients........................................................................................................... 6
Where do the marine ingredients come from?................................................................................ 7
Skretting Global sourcing targets.................................................................................................... 8
Multi-species fisheries.................................................................................................................... 9
Responsible sourcing criteria for marine ingredients manufacturers............................................... 10
Requirements for traders.............................................................................................................. 11
Sustainability information to be recorded and to accompany each batch of marine ingredients...... 12
Public disclosure of origin of marine ingredients............................................................................ 13
Annex 1. Risk of marine ingredients originating from IUU fishing activities.................................... 14
Annex 2. Forced labour (slavery) in the marine ingredients supply chain........................................ 16
Annex 3. Marine ingredients certification schemes and references................................................ 19

2 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYINTRODUCTION

This document describes the Responsible Sourcing
Policy for Marine Ingredients developed by Nutreco
and Skretting.
It is a policy document that addresses relevant topics for the industry, and also serves as apractical guide for the marine ingredients procurement staff to decide on what type of marine
ingredients can be sourced for our global operations.
A crucial part of protecting the ocean is ensuring that fish stocks caught for direct or indirect
human consumption are fished responsibly – within clearly defined, sustainable limits. Throughour Sustainability RoadMap 2025, we strive to ensure that our marine feed ingredients comefrom sustainable sources in the short- and long-term. We also actively work to align industry
incentives to support processes that will lead to improved fisheries management. In addition
to wild-caught fish, we are increasing the use of by-products (or “trimmings”) from theprocessing of fish for human consumption. It is estimated that 29% of fishmeal is derived fromby-products1. This also makes it possible for us to use feed ingredients that are not in directcompetition with human nutrition, and which support the development of a circular economy.

1. IFFO (international Fishmeal and Fish Oil Organisation).

3 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICY

Nutreco and Skretting strive to ensure that all of the marine-based
feed ingredients that we use come from sustainable sources, wheretransparency on stock status and trends in biomass changes are
publicly reported. This requirement includes the aim to align industry
incentives that support processes leading to improved fisheries
management. Our ambition is that all of the fishmeal and fish
oil that we use originates from fisheries that are managed

according to the FAO Code of Conduct for Responsible Fisheries.

We also recognise that with a finite supply offishmeal and fish oil, further growth of theaquaculture feed production will require further
reduction of the inclusion levels of marine
resources in these diets.

SCOPEOur Responsible Sourcing Policy for Marine Ingredientsrefers to feed ingredients manufactured from fish andaquatic crustaceans. “Marine” in this context refers toboth fish and aquatic crustaceans living in both saltand fresh-water. Typical forms of marine ingredientsare fishmeal, fish oil, fish protein concentrates andfish protein hydrolysate (FPH).
Aquatic plants and algae are not included in the scope of this policy.
Regulations and specifications in the Nutreco Code of Conduct for Business Partners
are always valid for manufacturers of marine ingredients supplied to Nutreco and Skretting.
Also, the specifications in the marine supplement are valid regarding the primary origin(species/fisheries) of marine ingredients.
The marine ingredients sourcing policy will in some areas give more detailed explanation, guidance
and in some areas additional specifications. In addition, it also specifies the Nutreco and Skretting
sourcing roadmap for marine ingredients. The different sustainability classes or levels of marine
ingredients are put in context related to industry practice and definitions in the most importantaquaculture feed standards.

4 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYMARINE INGREDIENTS SOURCING POLICY –CONSTRUCTED ON A RISK-BASED APPROACH

A responsible marine ingredients sourcing policy
is important as it serves to use marine resourcesin a sustainable way and to not put the reputationof Nutreco and Skretting and the wider aquacultureindustry at risk.
Marine ingredients originating from reduction fisheries (made from whole fish) must havethe strictest sustainability sourcing criteria. This is because the aquafeed industry is by
far the most important sector buying marine ingredients and is positioned to exercise
significant purchasing power.
Marine ingredients and aquaculture feed certification schemes have less strict criteria
on fishery management of the by-products originating fisheries than for whole fish. Thisis because one has priority on resource utilisation. Even so, Nutreco and Skretting are
mindful that this must not be used as an opportunity to create and expand markets formarine ingredients coming from by-products that originate from poorly managed fisheries.

5 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYORIGIN OF MARINE INGREDIENTS

Aquaculture products

Wild fisheries

Reduction Fisheries

Marine Marine
ingredients
ingredients

Marine by-products

A reduction fishery is one that uses (or “reduces”)

Marine ingredients refer to products

The processing of fish for human consumption gives rise to by-products

its catch to produce fishmeal or fish oil rather thanoriginating from fish and aquatic(also referred to as “trimmings”) in the form of heads, viscera, frames, skins

for direct human consumption. After the fish are

crustaceans living in both salt andand others such as tails, fins, scales, mince, blood, etc. These materials maycaught, they are delivered directly to a marine

fresh-water. Typical forms of marine

constitute up to 70% of fish and shellfish after processing where fish fillet

ingredients processing plant. Marine ingredients

ingredients are fishmeal, fish oil,yield is species-dependent and is often in the range of 30-50% of the fish.

from reduction fisheries can also be referredfish protein concentrates and fish

The waste generated after processing is a valuable raw material from whichto as marine ingredients from “whole fish”.

protein hydrolysate (FPH).

fishmeal and fish oil may be produced.

6 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYWHERE DO THE MARINE INGREDIENTS COME FROM?*
By-products from aquaculture

Do the by-products originate from an ASCor BAP-certified farm?

YES

By-products from wild fish catch

BUY

NO

Do the by-products originate from MarinTrust
approved3 aquaculture by-product materials?
OR from farms in the BAP or ASC improvers
programmes, and can they be traced back to thespecies they were made from and the country
that the farm(s) were located in?

Do the by-products originate from fishery/species that are MSC certified or are certified
to a GSSI2 recognised scheme?

YES

Whole fish1

BUY

Sustainability class

Is the fishery/species MSC certified or certified
YES
to a GSSI2 recognised scheme?

BUY

A+

NO

NO

YES

BUY

Do the by-products originate from a MarinTrust
approved3 by-product material? And does eachdelivery have a species declaration?

YES

BUY

Is the fishery/species approved3 by the
MarinTrust certification programme AND/OR
part of a Comprehensive (MSC) approved FIP(Fishery Improvement Project)?

YES

BUY

YES

BUY

A-

YES

BUY

B

YES

BUY

C

A

NO

NO
Is the by-product coming from an aquaculture
product that was intended for human consumption?
YES
AND can it be traced back to the species it wasmade from and the country the farm(s) werelocated?
NO

BUY

Are the by-products coming from species thatare not classified as Critically Endangered orEndangered in the IUCN Red List? AND can they
YES
be traced to the supplying fish processor
or handler and by species or mix of species
for each delivery?

BUY

Is the fishery accepted by the MarinTrust
Improvers Programme AND from a MarinTrustsite AND/OR part of a Comprehensive (MSC)
approved FIP (Fishery Improvement Project)?
NONO
Can the manufacturer provide a simple list of thespecies that make up the by-products (this can be a YES
simple listing of species processed within a year)NO

BUY

Is the fishery categorised at least in class B2
in the FishSource Score (6 or above across all
FishSource scores) (See Annex 3).
NO
Does the fishery come from a country not listedon the list of countries with high risk of IUU
fishing activities5?
NO

DO NOT PURCHASE!

DO NOT PURCHASE!

DO NOT PURCHASE!

1. If the fishery originates from a country with a high risk of slavery in the fishing sector (Annex 2 in the policy), the manufacturer in addition to Nutreco Code of Conduct for Business Partners must fulfil the criteria specified in the policy – regardless of certification status.
2. Global Sustainable Seafood Initiative. 3. Note that MarinTrust has separate criteria for all three origins of materials. 4. Sustainable Fisheries Partnership. 5. See Annex 1 in the policy. * References in Annex 1, 2 and 3
7 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYSKRETTING GLOBAL SOURCING TARGETS
By-products from aquaculture

By-products from wild fish catch

Whole fish

Sustainability classA+
Target minimum

50%

TargetTarget85%

by 31.12.2025

by 31.12.2025

A

Target maximum

Target maximumA-

by 31.12.2025

of global purchases 31.12.2025

100%

by 31.12.2025

50%

15%

B
Buy until 31.12.2025

Buy until 31.12.2025

C
Buy until 31.12.2022

8 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYMULTI-SPECIES FISHERIES

Multi-species fisheries are targeting numerous species
and sizes simultaneously. Due to the wide variety of
species taken, these fisheries have proven difficult tomanage world-wide but there has been considerable
progress in recent years. Multi-species fisheries are
not pure reduction fisheries.
Normally, most of the catch goes to direct human consumption, with the remainder(small fish and fish considered not edible) used for fishmeal production.
Multi-species fisheries are the dominant type of fisheries world-wide but are particularlycommon in the tropics due to the high species diversity. MarinTrust has launched a pilot to
be tested during the next three years with relevant fisheries such as mixed trawl fisheries inSoutheast Asia. During this period, the pilot approach will work as a part of the MarinTrust
Improver Programme (MarinTrust IP).

9 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICY

Skretting will only purchase fishmeal

from tropical multi-species fisheries if:• The fishery is part of a Fishery Improvement Project (FIP)
that is accepted as part of the MarinTrust Improver Programme• The fishmeal manufacturer has been accepted
for the Improver Programme• Fishmeal from fisheries mentioned above shall only be usedby Skretting in geographical areas where fisheries mentioned
above are locatedRESPONSIBLE SOURCING CRITERIA FOR
MARINE INGREDIENTS MANUFACTURERS

Marine ingredients manufacturers shall fulfil
all general criteria in Nutreco’s Code of Conduct
for Business Partners.
Fisheries materials shall not be processed from illegal, unreported, and unregulated (IUU)
fishing activities. This is regardless of products purchased by Skretting – it is a general
requirement to their activity.

Marine ingredients manufacturers shall implement traceability systems
that enable the original materials used in the products sold to Skretting
to be traced back to the fishery/fisheries of origin, or to the farmed
species and country of origin. Data that shall be recorded and reported
to Skretting for each batch of fishmeal is described later in this document.

10 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYREQUIREMENTS FOR TRADERS

A trader in this context is a company/person who buys
(takes legal ownership of) a batch of marine ingredientsfrom the manufacturer, and then sells (invoices) the
batch to another party. A company or person that does
not take legal ownership over the marine ingredientsis not a trader, but more a type of agent.
Traders must always declare the name (and factory) of the manufacturer.
In addition, they must see to it that all of the information that Skretting
requires from the manufacturer follows the batch of fishmeal and fish oil
through the value chain.
If a trader sells a consignment of marine ingredients claimed to be MarinTrust
certified, then the trader must provide a valid MarinTrust Chain of Custody certificate.

11 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYSUSTAINABILITY INFORMATION TO BE
RECORDED AND TO ACCOMPANY EACH
BATCH OF MARINE INGREDIENTSThe manufacturer will report to Skretting all normal
information linked to the transaction (name and details of
manufacturer, volumes, nutritional information and so on).
In addition, we would like to highlight information that must accompany eachbatch to decide or confirm the sustainability status of the marine ingredient.
Information to follow each batch of marine ingredients:
Information

Comment

Manufacturer information

Name, location and validity and certification schemes

Country of origin

Country where the batch was processed

Species that make up the batch

List the common name in English and also the Latinname. When a complete list of by-catch is declared,
species that in total constitute less than 5% of the batch
can be recorded as “other”

Certification status

MSC, MSC (Comprehensive) Fishery Improvement
Project, MarinTrust, MarinTrust Fishery Improvement
Project, No certification

Type of product

Whole fish or by-product

FAO fishing area

See FAO Fisheries & Aquaculture - FI fact sheet search

12 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICY

Information the manufacturer must record andthat will be available upon request from Skretting
Information

Comment

Fishing vessel

Name of fishing vessel

Flag stateState where fishing vessel
is registered

Jurisdiction where caught

Jurisdiction where the fish was caught

Fishing gear

Trawl, purse seine, otherLanding port of delivery/
manufacturing

Name and nationality of port

PUBLIC DISCLOSURE OF ORIGIN
OF MARINE INGREDIENTSSkretting will publicly disclose the originof its marine ingredients through its
sustainability reporting.
As a minimum, the information disclosed shall be:• The main species and the fisheries used
• The ratio of whole fish (reduction fisheries) and by-products• The certification status of reduction fisheries used
This information can also be used to support other initiatives of public
disclosure in this area, for example, the Ocean Disclosure Project.

Disclaimer:
Nutreco and Skretting are committed to sourcing sustainably and being accountable for criteria articulated
in our policy and when specific incidences of non-compliance are brought to our attention, will act
expeditiously to rectify and resolve.

13 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYANNEX 1. RISK OF MARINE INGREDIENTSORIGINATING FROM IUU FISHING ACTIVITIESIllegal, unreported, and unregulated (IUU) fishing remains
one of the greatest threats to marine ecosystems due
to its potent ability to undermine national and regional
efforts to manage fisheries sustainably as well as
endeavours to conserve marine biodiversity.
IUU fishing takes advantage of corrupt administrations and exploits weak management regimes,in particular those of developing countries lacking the capacity and resources for effective
monitoring, control, and surveillance. IUU fishing is also found in all types and dimensionsof fisheries; it occurs on the high seas and in areas within national jurisdiction; it concerns
all aspects and stages of the capture and utilisation of fish; and it may sometimes be
associated with organised crime.
When a marine ingredients manufacturer is approved by Skretting and the fishery product(s)originates from a MarinTrust approved or MSC certified fishery, the risk of IUU fishing activity
related to what is purchased is low because it is part of what is being evaluated in thecertification process. But materials purchased from Class C sources defined in thispolicy can potentially be vulnerable to IUU fishing activities.

14 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYIn order to have a better understanding of these risks
and to also mitigate them, Nutreco and Skretting will
use The IUU Fishing Index, which provides a measure of
the degree to which states are exposed to and effectively
combat IUU fishing.

Countries ranked with highest riskfor potential IUU fishing activities

We have used the coastal filter by state responsibility of this index together with some additionalcountries based on the risk of lack of ability to enforce national laws and regulations.
Additionally, Nutreco is an active member of SeaBOS, where Task Force 1 addresses IUU fishing,endangered species and forced labour. This policy will be updated with publicly available progress
reported by SeaBOS.
Skretting shall buy marine ingredients originating from these high-risk countries only in class A+, A,
A- or B from 01st January 2023. Purchases in class C are not allowed from 1st January 2023. Thisis done to reduce the risk of receiving marine ingredients based on IUU material.
The list will be revised and updated according to developments in the market.

Cambodia, Gambia, Kiribati, Mauritania, Myanmar, Oman, Philippines,
Senegal, Seychelles, Somalia, Taiwan, Timor-Leste, Vietnam, Yemen
15 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYANNEX 2. FORCED LABOUR (SLAVERY) IN
THE MARINE INGREDIENTS SUPPLY CHAIN

Forced labour is defined by the International Labour
Organization (ILO) as “work or service exacted from any
person under the menace of penalty and for which theperson has not offered himself voluntarily”. For the sakeof simplicity in this document, we will refer to forced
labour as “slavery”.
Nutreco’s Code of Conduct for Business Partners demands that its suppliers do not engage inslavery. In this context, marine ingredients suppliers are no different to any other supplier Nutreco
and Skretting. At the same time, we know that our marine ingredients suppliers are in turnsupplied by many fishing vessels. In most cases, these fishing vessels are independent businesses
and are not owned by the marine ingredients manufacturers. There have been numerous reports
about incidences of slavery in the fishing sector. As such, Skretting is at risk of being supplied byfishmeal factories that have been supplied by fishing vessels using slave labour.
Fishing vessel slavery country risk table
We have constructed a risk table that consists of the Country Risk Rating according to the World
Bank, the Slavery Index of the country and two factors that describe the risk of forced slavery in thefishing sector.

16 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYTable 2. High risk countries based on the 25 biggest fishmeal countries in the world
Country

Share of global production-Average 2019-20161

World
Bank Index2

Slavery
Index3National
Fisheries Policy4

Wealth andInstitutional Capacity4

Total Risk
score

Total Risk
score

Philippines

1.2

3

3

3

3

12

HIGH

Thailand

5.7

3

3

3

3

12

HIGH

India

3.2

3

3

2

3

11

HIGH

China, PR

8.1

3

3

3

2

11

HIGH

Iran

0.7

3

3

3

2

11

HIGH

Russia

1.9

3

3

3

2

11

HIGH

Mauritania

2.3

3

3

1

3

10

HIGH

Mexico

2.6

3

3

2

2

10

HIGH

Vietnam

6.2

3

2

2

3

10

HIGH

Indonesia

0.9

3

3

2

2

10

HIGH

Pakistan

1.4

3

3

1

3

10

HIGH

1. Data from IFFO statistical yearbook 2020-21
2. The risk classification of countries relies on the Worldwide Governance Indicators from the World Bank, being aggregate indicators of governance 1996-2019. These determine the level of risks related to governance in sourcing countries. Classified as low (1), medium (2) and high (3) risk.
3. Based on the 2018 Global Slavery Index published by the organisation Walk Free. Classified as low (1), medium (2) and high (3) risk.
4. Countries classified by National Fisheries Policy (catch outside EEZ, distant water fishing, and subsidies), and Wealth and Institutional Capacity (GDP per capita, value landed per fisher, and unreported landings). Data published in study about forced labour in the fishing sector in the 2018 Global
Slavery Index.

17 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYIn some countries, marine ingredients manufacturers
can own and operate their own fishing vessels. Notethat in such cases, the working conditions aboard thefishing vessel(s) are included in Nutreco and Skretting’s
manufacturer assessment and are covered by the
Nutreco Code of Conduct for Business Partners.
Criteria for marine ingredients suppliers located in high-risk countries
If Skretting sources marine ingredients from a supplier located in a high-risk country(risk rating >9.9), the following will apply:

1. Skretting shall request information from the marine ingredients supplier demonstrating that
actions have been taken to mitigate the risk of bonded labour onboard the fishing vessels thatare supplying it. The supplier shall be able to demonstrate that actions are part of their quality
management system.
2. The information requested above shall be not older than two years.
3. If the marine ingredients manufacturers (in high-risk countries) are supplied by fishing vessels
fishing in international waters, then the marine ingredient supplier must be audited before being
approved. The focus of the audit shall be working conditions and legal compliance regardingfishing boats supplying them. The audit can be a third-party audit, or an audit conducted byqualified Skretting staff.

18 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICYANNEX 3. MARINE INGREDIENTSCERTIFICATION SCHEMES AND REFERENCES

A. Global Sustainable Seafood Initiative (GSSI) - scope fisheries
GSSI has developed a Global Benchmark Tool which provides formal recognition of seafoodcertification schemes that successfully complete a rigorous and transparent benchmark process,underpinned by the FAO Guidelines. Once a scheme successfully completes the Benchmark Process,the scheme is formally and publicly announced as “GSSI recognised”. This means that they are “inalignment” with all 186 Essential Components and thus aligned with the FAO Code of Conduct for
Responsible Fisheries.
It is important to note that GSSI recognition does not include a ranking of any kind,nor does it declare the scheme “sustainable”. Additionally, the GSSI Benchmark Process
looks at environmental, governmental and operational criteria. It does not include social issues.
The Marine Stewardship Council fishery certification is approved by GSSI.
B. Marine Stewardship Council (MSC) fishery certification
The Marine Stewardship Council (MSC) is an independent non-profit organisation that sets a standard
for sustainable fishing. Fisheries that wish to demonstrate they are well-managed and sustainable
compared to the science-based MSC standard are assessed by a team of experts who are independentof both the fishery and MSC. Seafood products can display the blue MSC eco-label if that seafood canbe traced back through the supply chain to a fishery that has been certified by the MSC.
The mission of the MSC is to use its eco-label, for which it receives royalties from the licensing ofproducts, and its fishery certification programme to contribute to the health of the world’s oceansby recognising and rewarding sustainable fishing practices, influencing the choices people make whenbuying seafood, and working with partners to transform the seafood market to a sustainable basis.

19 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICY

C. MarinTrust programme
MarinTrust is a unique international certification programme for marine ingredients.
MarinTrust works with third-party accredited (ISO 17065) certification bodies which audit
fishmeal and fish oil producing factories and assess the responsibility of fisheries. The key
principles of the MarinTrust standard are responsible sourcing and responsible production,with full traceability and product segregation as key requirements.
The programme consists of two parts. The marine ingredients factory is certified based on
demonstrating responsible production practices and full traceability. Fisheries are assessed
and then approved if they fulfil the criteria in the standard. A batch of fishmeal or fish oil
produced by a MarinTrust certified factory and consisting of 100% approved fishery material
is MarinTrust certified.

20 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICY

D. FishSource
FishSource was created in 2007 by the Sustainable Fisheries Partnership (SFP). FishSource compiles
and summarises publicly available scientific and technical information about the status of fisheries into
an easily interpretable form. It aims to make this information more accessible to seafood buyers andhelp them take actions to improve the sustainability of the seafood that they purchase.
FishSource evaluates the fishery within five areas:
Score 1: Is the management strategy precautionary?
Score 2: Do managers follow scientific advice?
Score 3: Do fishers comply with managers’ decisions?
Score 4: Is the fish stock healthy?
Score 5: Will the fish stock be healthy in the future?
Detailed information can be found at FishSource.
E. IUCN redlist
The International Union for Conservation of Nature (IUCN) is a membership Union composed of bothgovernment and civil society organisations. It harnesses the experience, resources and reach of its
more than 1,400 member organisations and the input of more than 18,000 experts.
The IUCN Red List is a critical indicator of the health of the world’s biodiversity. The IUCN Red List
Categories and Criteria are intended to be an easily and widely understood system for classifying
species at high risk of global extinction. It divides species into the following nine categories: Not
Evaluated, Data Deficient, Least Concern, Near Threatened, Vulnerable, Endangered, CriticallyEndangered, Extinct in the Wild and Extinct. Detailed information: IUCN redlist.

21 MARINE INGREDIENTS RESPONSIBLE SOURCING POLICY