The european supermarkets ranking on tuna: Our methodology

08 November 2023

Over the summer 2023, BLOOM, Blue Marine Foundation and Greenpeace UK requested tuna sourcing information from 36 European retailers in France, the United Kingdom, Spain, Italy, Germany and Belgium. The results of this survey have led to the ground-breaking “Willful Ignorance” ranking of Europe’s leading supermarkets in terms of their tuna sourcing practices.

Interviewed retailers were asked to provide:

• The annual volumes of canned tuna sold domestically, with data stratified by species, fishing technique, and origin, for both name-brand and own-brand products (i.e., products under the retailer’s label);
• The steps taken by the retailer to address the many social and environmental harmful impacts associated with tuna fisheries, in particular those using drifting Fish Aggregating Devices (FADs).

Based on the retailer’s data that was sent in response and on public information available online, two different scores were established for each retailer. Firstly, retailers were scored based on their level of cooperation with us. This score covers their responsiveness and the quality and completeness of the answers they provided to our information requests over the summer.

The second score attributed to retailers reflects the quality and level of ambition of their environmental and human rights policies. It is based on an extensive review of the online accessible publications of the different retailers. Over 300 documents, letters, and datasets related to sourcing policies, duty of vigilance plans, ethical codes of conduct, and human rights policies were analyzed to score the 36 retailers’ policies against 17 selected criteria.

An important disclaimer: BLOOM’s scoring is exclusively based on retailers’ public policies and on the responses to our enquiries. The ranking therefore only evaluates European retailers’ delarations, not the actual implementation of their policies or the concrete compliance with their commitments. 

The methodology behind the Cooperation and the Policy scores

Both grades are based on several criteria exposed below. One “Cooperation” and one “Policy” score, both out of 10, were computed.

The Cooperation score is computed based on the information provided by the retailer in response to our information requests. If the retailer referenced external documents in its response, they were taken into account in BLOOM’s evaluation. The total was computed by adding up the points and bringing the total to 10 points (compared to the maximum number of points reachable). For this score, weights were given to several criteria.

→ Find the resulting scoring table here in order to know the various weights applied to each variable using the example of British retailers.

The Policy score is based on all the relevant retailer information available online. Solely the information published in the retailer’s official policies, documents or website, was taken into account (e.g. information from the Tuna Protection Alliance or the Ocean Disclosure Project was taken into account, while external communications published on sectorial journals were excluded from the evaluation). However, if nothing was published by a retailer, we used the information that they provided in their private response to us.

The Policy score is the average of the “Environmental Policy” and “Human Rights Policy” scores (both out of 10 too). Some criteria are both relevant to Environmental and Human Rights risks, therefore the related points earned were divided by two and contributed equally to the Human Rights Policy and Environmental Policy score (see. 2.2.2 section).

Some national retailers interviewed were part of the same international corporation (e.g. Carrefour, Aldi, Lidl). In these cases, we took into account both international corporate policies and the relevant national policies.

Choice of retailers assessed

BLOOM, Blue Marine Foundation and Greenpeace UK reached out to European market leaders during the summer 2023 asking for tuna sourcing information. We targeted the largest retailers in the markets that consumed the most tuna. In total, 36 retailers based in France, the United Kingdom, Spain, Italy, Germany and Belgium were contacted. Retailers were selected and included in this process based on three main criteria: their national market share, their European market share and their international market share. With BLOOM being based in France, while Blue Marine Foundation and Greenpeace UK that contributed to the data requested being based in the UK, the largest number of retailers contacted belonged to these markets (11 retailers for France and 10 for the UK). For the remaining countries, we included the largest players and the ones that were either part of an international corporation or that were part of a group that was already being interviewed in another country in our sample survey.

Defining baseline documents

A sourcing policy, also called procurement policy, is a set of requirements that a company uses to ensure that its products are sourced from suppliers that meet its standards. In the case of “responsible”, “sustainable”, or “ethical” sourcing policies, the criteria used are meant to address the various environmental (climate, biodiversity), social (human rights, workers rights) and governance risks. Retailers selling tuna should have a dedicated tuna and/or seafood sustainable sourcing policy.

An ethical code of conduct, which can be translated as a supplier code of conduct, refers to all the international human rights standards and laws to which the company is actively committed in its business activities. Ethical codes of conduct cover at least the company’s direct employees, and the company specifies whether they extend to business partners and suppliers, and whether they require their suppliers to apply the same standards to their own suppliers.

1. “Cooperation” grading criteria

1.1. Did the retailer respond to our first enquiry letter?

1 point	Yes, it was late (one week maximum) and the retailer gave us prior notice
2 points	Yes, it was on time (the deadline was on June 23rd 2023)

1.2. What was the level of engagement of the retailer with us?

1 point	The retailer demonstrated a minimum level of engagement, with only one response to our numerous enquiries.
2 points	The retailer was engaged and responded to several letters and emails.

1.3. How complete was the dataset provided by the retailer?

This score was computed twice: firstly to evaluate the data on the retailer’s own-brand tuna (tuna marketed under the supermarket’s name or brand), and secondly to evaluate the name-brand tuna (tuna marketed under a national tuna brand) sold by the retailer. In case the retailer declared not selling any name-brand product, the final score is computed only based on own-branded tuna and normalised to 10.

Regarding the quantitative data requested:

1 point	The retailer provided relative volumes of name-brand and own-brand tuna (in tonnes or in percent).
1 point	The retailer provided quantitative data with a minimum level of granularity. Quantitative data was provided relative to tuna species, fishing areas and fishing gear but no link between the variables was established, making it difficult to see whether there are any problematic practices within the supply chain overall.
2 points	The retailer provided quantitative data with an intermediary level of granularity. Quantitative data was provided relative to tuna species, fishing areas and fishing gear, and a link between the variables was established, giving a higher level of precision in the data but not sufficient to see problematic practices within the supply chain overall.
3 points	The retailer provided quantitative data with the highest level of granularity possible. Quantitative data was provided relative to tuna species, fishing areas and fishing gear, and all links between the variables were established, giving a satisfying level of precision in the data to see whether there are any problematic practices within the supply chain overall.
1 point	The retailer specified the different tuna species present in its tuna offering.
1 point	The retailer specified the different fishing areas related to its tuna offering.
1 point	The retailer specified the different fishing gears related to its tuna offering.
1 point*	The retailer specified the number of tuna suppliers it deals with.
1 point*	The retailer specified the name of the different tuna suppliers it deals with.
1 point*	The retailer specified the location of the different tuna suppliers it deals with.

* These points do not apply to UK retailers which were not questioned on these points.

Regarding the qualitative data requested:

1 point	The retailer expressed and explained the different measures it is currently implementing to address the different environmental impacts related to the sourcing of tuna.
1 point	The retailer expressed and explained the different measures it is currently implementing to address the different social impacts related to the sourcing of tuna.
1 point	The retailer expressed and explained the different objectives and related future actions it is looking to implement in order to address the environmental issues in its tuna supply.
1 point	The retailer expressed and explained the different objectives and related future actions it is looking to implement in order to address the human rights issues in its tuna supply.

2. “Environmental and Human Rights” Policies grading criteria

Points were attributed to retailers each time they included measures in their supply policy in favor of environmental and human rights.

For each criterion, extra points were awarded to retailers when they set precise and time-bound objectives.

For retailers that set specific short-term objectives (by 2025 latest), the following number of extra points were awarded: (number of points which will be reached by 2025 – number of points reached today) / 2

For retailers that set specific long-term objectives (by 2030 latest), the following number of extra points were awarded: (number of points which will be reached by 2030 – number of points reached today) / 4

2.1. Policies and scope

2.1.1. The retailer has published a policy that specifically addresses the sustainability of its tuna supply chain (contributes to the environmental policy score).

1 point	Yes.
2 points	Yes, and the version number or at least the date of publication is mentioned.
1 point	Yes, and it covers the whole perimeter (own-brand and name-brand products), but with different requirements. This point only applies if the policy clearly details the scope of its policy.
2 points	Yes, and it covers the whole perimeter (own-brand and name-brand products) with equal requirements. It treats its tuna supply as a whole.

2.1.2. The retailer has published a policy that specifically addresses human rights and labour rights issues along its supply chain (contributes to the human rights policy score).[1]

1 point	Yes.
2 points	Yes, and it is has an updated version number or at least the date of publication.

2.2. Content of policies

2.2.1. Retailers’ environmental policies on tuna

2.2.1.1. Regarding the health of tuna populations, the retailer’s policies and statements:

1 point	Include specific and regular attention to the state of sourced tuna populations.
2 points	Include specific and regular analysis to the state of tuna populations and a halt to the supply of all overexploited and overfished populations. N.B.: In the Indian Ocean, both Bigeye and Yellowfin tunas are currently overfished.[2]
3 points	Include specific and regular analysis of the state of tuna populations and a halt to the supply of all overexploited stocks, also prioritising the reduction of large-scale harmful industrial fisheries over smaller scale more virtuous fisheries. In this sense, the retailer commits to prioritizing delisting suppliers who rely on industrial FAD-associated purse seine fisheries[3] rather than smaller-scale pole and line fisheries.

2.2.1.2. Regarding the fishing gear, the retailer’s policies and statements:

1 point	Authorise only non-mesh, non-entangling drifting FADs, and experiment the use of biodegradable drifting FADs.
2 points	Prohibit the use of all drifting FADs. Same for retailers that do not use drifting FADs.
1 point	Require that an observer systematically verifies the “FAD free” claim or the performance of audits or any assessment to check the veracity of the “FAD free” claim. Same for retailers that do not use drifting FADs.

2.2.1.3. Regarding marine pollution, the retailer’s policies and statements:

1 point	Ensure that suppliers adapt their fishing gear to reduce ghost fishing gears[4] (excl. FADs, see above).
1 point	Ensure that suppliers geolocate their drifting FADs and implement robust strategies to retrieve them. Same for retailers that do not use drifting FADs.

2.2.1.4. Regarding purse seine fishing setting techniques, the retailer’s policies and statements:

1 point

Refer to a ban of fishing on schools of dolphins and whales. Equal treatment point for retailers using no drifting FADs. Same for retailers that do not source from purse seiners.

2.2.1.5. Regarding bycatch, the retailer’s policies and statements:

1 point	Identify the issue of bycatch and require that suppliers engage in a bycatch reduction process.
1 point	Refer to the performance of bycatch audits.
1 point	Mention a maximum bycatch rate authorised in procurement.

2.2.1.6. Regarding the fishing of juvenile tuna, the retailer’s policies and statements:

1 point	Refer to a minimum weight/size criterion for purchased tuna, with no means to prove it.
2 points	Refer to a minimum weight/size criterion for purchased tuna, with means to prove it.

2.2.1.7. Regarding consumer information at product level, the retailer’s policies and statements:

1 point	Require that some tuna products include basic traceability information (species, location, gear).
2 points	Require that all tuna products include basic traceability information (species, location, gear including whether FADs are used)
0,5 point each	Best practice extra points: given for each of the following additional information directly available on all tuna products (without requiring scanning a QR code)[5]: Major fishing area (FAO) Vessel name or identification number scheme (IMO) Processing location Processing factory name FADs use

 2.2.2. Retailers’ Environmental and Human Rights policies

The following criteria are both relevant to the environmental impact of fisheries and human rights protection. Each point scored in this category count both for the environmental and human rights policy score with equal weight.

2.2.2.1. Regarding fisheries monitoring, the retailer’s policies and statements:

1 point	Require the monitoring with observers[6] and/or electronic monitoring (no frequency specified, or less than 100% observer coverage).
2 points	Require the systematic surveillance with observers and/or electronic monitoring (100% observer coverage).
3 points	Require 100% observer coverage (human and/or electronic monitoring), with 100% human observer coverage for purse seiners (if the retailer sources from purse seiners) and observer reports.
1 point	Best Practice Extra Point: if the retailer policy accounts for the varying means between large-scale industrial fleets and smaller-scale fisheries in implementing this measure and therefore targets industrial fishing fleets operating on the high seas in priority.

2.2.2.2. Regarding Illegal Unreported Unregulated (IUU) fishing, the retailer’s policies and statements:

1 point	Ensure not to buy IUU tuna by checking that the fishing vessel is not on the IUU blacklists (accessible here: https://www.iuu-vessels.org/ and/or Regional Fisheries Management Organisations (RFMO)[7] blacklists and/or European Union IUU blacklist).
1 point	Require that fishing vessels are registered at the RFMO level, or at local level if the vessel solely fishes in Exclusive Economic Zones and it considered small-scale (e.g. pole and line).

2.2.2.3. Regarding transshipment of tuna fishing vessels at sea, the retailer’s policies and statements:

1 point	Authorise transshipment at sea that follow the rules of the relevant RFMO.
2 points	Prohibit transshipment at sea for all tuna related fisheries and in all circumstances except in cases of force majeure where the crew or the ship are at direct risk.

2.2.3. Retailers’ Human Rights policies

In this section, the expression “Human Rights” is used generically to address on-land and at-sea human rights and labour rights protections for workers.

2.2.3.1. Regarding human rights, the retailer’s policies and statements:

1 point	Publicly declare that they apply to all employees and supply chain business partners.
1 point	Require that suppliers apply the policy to their suppliers too.
1 point	Explicitly refer to working in accordance with the International Bill of Rights including the Universal Declaration on Human Rights, and the International Labour Organisation (ILO) core conventions.
1 point	Explicitly refer to working in accordance with the Maritime Labour Convention (MLC) 2006, ILO 188 Working in Fishing Convention, and/or the Cape Town Agreement on safety, and/or the Geneva Declaration on Human Rights at Sea.
1 point	Explicitly refer to working in accordance with the United Nations Guiding Principles for Business on Human Rights.
1 point	Detail the internal process implemented to ensure the policy principles are introduced, continually updated and known to all employees as part of a continuing professional development (CPD) and business partners (e.g. governance and review process, training of employees and suppliers).

2.2.3.2. Regarding human rights risk assessment process, the retailer’s policies and statements:

1 point	Require Human Rights risk assessments[8] to be undertaken.
2 points	Require regular Human Rights risk assessments to be performed with a full value-chain &/or product approach. This means that risk is evaluated at each step of the tuna supply chain, with a specific attention to the various risks arising from differing production activities.
1 point	Best Practice Extra Point: Mention the undertaking of tuna or wild seafood-specific Human Rights Impact Assessments (HRIA) and the reports of these assessments are published.

2.2.3.3. Regarding social auditing schemes, the retailer’s policies and statements:

1 point	Refer to the implementation of regular social audits of suppliers without mentioning the frequency, or less frequently than every twelve months.
2 points	Refer to the implementation of regular social audits of at-risk suppliers: every twelve months.
1 point	Specifically require audits of suppliers of the first and second tier[9] for high-risk food products.
2 points	Specifically require supplier of the first, second and third tier for high-risk food products.

2.2.3.4. Regarding grievance mechanisms,[10] the retailer’s policies and statements:

1 point	Require an effective complaint/grievance mechanism is available for all employees along the supply chain of the retailer’s product offering, with means to prove it. N.B. The term “employees” here refer to the retailer’s own employees and the ones of its direct and indirect suppliers and business partners.
2 points	Require that an effective complaint mechanism is available for all employees along the supply chain of the retailer’s product offering, with means to prove it, and regularly publishes information regarding the number and type of alerts received and actions deployed in response.
1 point	Engage in communities work at the start of identified at-risk food supply chains, to ensure the effective deployment of the grievance mechanism and its accessibility to most at risk employees of the chain.[11]

2.2.3.5. Regarding the company’s remediation procedure/plan,[12]the retailer’s policies and statements:

1 point	Are published.
1 point	Account both for the remediation of the victim (process, means, results) and the disengagement of unlawful commercial partners.
1 point	Explicit delisted commercial partners and the reasons for their delisting.
1 point	Best Practice extra point: express that the process is “victim-led”, or a similar sentence that states that the victim will be at the heart of the remediation process, ensuring its protection and consent.

NOTES

[1] Contrary to environmental policies, human and labour rights policies normally cover the whole of a retailer’s offer (own-brand and name-brand products), so we only accounted for whether the human rights policy was present or not.

[2] The Indian Ocean Tuna Commission latest tuna stock assessments are available here.

[3] A Fish Aggregating Device (FAD) is a floating object used for the purpose of facilitating the harvesting of fish such as tuna, which are naturally attracted by them and thus aggregate beneath them. They are extremely detrimental to marine biodiversity and tuna populations. Read more in our Tuna War Games report.  

[4] Ghost fishing gear, is any discarded, lost, or abandoned, fishing gear in the marine environment. This gear continues to fish and trap animals, entangle and potentially kill marine life, smother habitat, and act as a hazard to navigation.

[5] We decided not to consider QR codes, as this practice does not allow all consumers to quickly and easily access information on the origin of the tuna, as a printed text on the can would.

[6] An ‘observer’ is a person who is authorised by a regulatory authority to collect information in the field (either at sea or on shore) to support sustainable aquatic resource management. The observer must be financially independent of the industry being monitored (IOBR, CCROP-SR).

[7] An RFMO is a Regional Fisheries Management Organisation. It is an international organisation that establishes binding measures for conservation and sustainable management of highly migratory or straddling fish species.

[8] As per the United Nations Guiding Principle on Business and Human Rights n°18: “In order to gauge human rights risks, business enterprises should identify and assess any actual or potential adverse human rights impacts. This is a foundational step for effective management of human rights risks.”

[9] First tier suppliers are usually manufacturers producing the final product that will be sold to the consumer (i.e. canneries in the case of canned tuna). Second tier suppliers are usually manufacturers converting raw materials into pre-processed, intermediate materials that will be used by first tier manufacturers (i.e. suppliers converting raw tuna into loins and/or pre-cooked tuna). Third tier suppliers usually directly source the raw material (i.e. fishing companies and vessels). 

[10] The term grievance mechanism is used to indicate any routinized, State-based or non-State-based, judicial or non-judicial process through which grievances concerning business-related human rights abuse can be raised and remedy can be sought.

[11] As per the United Nations Guiding Principle on Business and Human Rights n°29: “To make it possible for grievances to be addressed early and remediated directly, business enterprises should establish or participate in effective operational-level grievance mechanisms for individuals and communities who may be adversely impacted.”

[12] As per the United Nations Guiding Principles on Business and Human Rights n°15: “In order to meet their responsibility to respect human rights, business enterprises should have in place policies and processes appropriate to their size and circumstances, including (…) processes to enable the remediation of any adverse human rights impacts they cause or to which they contribute.”

Remediation/remedy refers to both the process of providing remedy for a negative human rights impact and the substantive outcomes that can counteract or compensate for the negative impact. These outcomes may take a range of forms such as apologies, restitution, rehabilitation, financial or non-financial compensation, and punitive sanctions (whether criminal or administrative, such as fines), as well as the prevention of harm through, for example, injunctions or guarantees of non-repetition.