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Human Rights and Environmental Due Diligence: How ASC Assists in De-Risking Aquaculture Supply Chains
May 6, 2026
Aquaculture plays a critical role in global food systems, employment and economic development. Continued growth in global aquaculture is helping to meet the growing demand for seafood.
However, alongside its contributions, the sector is associated with human rights and environmental risks, such as unsafe working conditions, forced labour, inadequate living conditions for workers, water pollution, fish escapes, habitat degradation and more.
There is an opportunity, and responsibility, for companies to identify, prevent, and address the impacts linked to their operations and supply chains through human rights and environmental due diligence (HREDD).
In simple terms, it means:
- recognising what risks to human rights and the environment exist; and
- taking steps to address them before they cause harm.
This impacts those directly affected and empowers consumers. By choosing products from companies that take their HREDD responsibility seriously, they can drive positive change across the sector.
Certification supports company action, even if it is only one piece of the bigger HREDD process. It can strengthen and operationalise HREDD by providing credible data, signal risk of impacts, and identifying remediation pathways. Company-led due diligence is needed to interpret those findings, address systemic risks and ensure that protections are embedded into corporate governance, practices, and procurement strategies.
Why does HREDD matter?
Effective human rights and environmental due diligence can help companies improve people’s lives, reduce environmental impacts, build consumer trust, enhance the industry’s reputation, attract responsible investment and improve ESG framework alignment.
HREDD is a matter of ethical best practice and risk management. It is also becoming a regulatory requirement in many global markets, including the European Union, despite recent scope reductions on the EU Omnibus package. Regardless of regulatory considerations, expectations from investors, business partners and broader society are clear: companies are expected to know and show how they manage and address human rights and environmental risks.
The EU Omnibus package
The European Union’s Omnibus package aimed to reduce overall administrative burdens for EU companies and included amendments to the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD) at the cost of ‘simplification’ and ‘scope reduction’. Still, CSRD expands requirements for sustainability disclosure, including environmental and human rights impacts, while the CSDDD requires mandatory HREDD for large companies operating within the EU and certain non-EU firms active in EU markets.
Recognising the risks
The critical first step is acknowledging that risks exist in any industry. In seafood, risks are heightened by complex, transnational supply chains, diverse production systems, and varying regulatory frameworks across producing countries and remote locations. Environmental impacts and labour conditions can differ significantly depending on species farmed, production intensity, geography and governance contexts.
Recognising there are risks is not an admission of wrongdoing; it is a prerequisite for taking meaningful action. When companies are transparent about where risks are most likely to occur, they can design realistic plans for corrective action, prioritise resources on the highest-risk areas and engage constructively with suppliers, workers and communities.
Ignoring or downplaying risks increases the likelihood of harm to people and the planet, regulatory non-compliance and reputational damage, decreasing the ability of the sector to attract financing or investment.
How companies should conduct HREDD and how ASC certification can support this
Due diligence can be incorporated into a seafood company’s operations through six generally recognised steps (adapted from the OECD Due Diligence Guidance). Certification against an ASC standard supports these steps through requirements for responsible operations, provision of credible data and benchmarks for risk management, but it does not replace the company’s overarching due diligence obligations.
Due diligence process and supporting measures (Source: OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct.)
Step 1: Embed responsible business conduct
HREDD starts with making a commitment at senior executive level and embedding respect for human rights and the environment into corporate governance, risk management, incentives and decision-making structures. Clear policies on fair wages, safe working conditions, anti-discrimination practices, and zero tolerance for forced labour, are essential along with responsible use of resources and minimal impact on ecosystems and climate.
The policies should span the supply chain and be integrated into companies’ entire operations, including commitments in procurement, contracts and buying procedures, as well as ensuring teams have the expertise and mandate to implement them.
By adopting ASC certification, companies signal their commitment to sustainability. The ASC programme offers structured requirements and independent third-party verification for environmental and social performance.
More specifically, the ASC Farm and Feed Standards require companies to develop and implement a human rights policy that covers their workers and nearby communities, embedded within a management system, and approved by senior management. The ASC Feed Standard mandates that these policies are operationalised through supplier codes of conduct and contractual expectations throughout the supply chain. Regular dialogue with workers and communities required in the ASC standards fosters transparency and accountability.
Step 2: Identify and assess adverse impacts
Identification is the first tangible step to implementing a policy or management system. Companies start by mapping their supply chains – from feed ingredients and hatcheries to farms through processors and distribution – to identify high-risk areas where human rights abuses and environmental impacts might occur. This includes understanding the specific challenges workers and communities face and biodiversity-specific impacts in each geography. In HREDD, it is important to look beyond tier 1 suppliers.
Supporting tools, whether a company’s own or from external human rights and environmental organisations, to conduct risk assessments, value-chain mapping, scientific monitoring and meaningful engagement with stakeholders (including workers and local communities) provide essential information. The results of which identify where and how adverse impacts occur, their likelihood and severity, and which supply chain tiers or geographies are most exposed.
ASC certification requires farms and feed mills to undergo third-party assessments against strict social and environmental requirements, which help identify risks early on, and take action to mitigate where requirements are not met. Risk assessment is embedded within certain aspects of both the ASC Farm and Feed Standards, through requiring an environmental risk assessment and health and safety risk assessment, for example.
The ASC Feed Standard dives deeper, requiring the feed mill to apply a risk-based due diligence approach into all feed ingredients (of greater than 1% volume), including assessment of labour risks, deforestation and responsible marine ingredients and upstream sourcing risks, with clear prioritisation of the most severe and likely harms. Current developments in the ASC Chain of Custody module are designed to strengthen risk assessment further down the aquaculture supply chain.
Step 3: Cease, prevent or mitigate
Once risks have been identified, companies should prioritise and implement appropriate actions to stop ongoing harms, prevent potential impacts and mitigate those that cannot be fully avoided. This may include activities such as providing additional training to workers, improving effluent and waste management, working with suppliers to improve labour conditions, or even changing suppliers. This approach creates a culture of ongoing improvement.
Seafood buyers also have a key role to play. Procurement practices, such as lowest-cost sourcing, short-term contracts, price squeezing and shifts to weaker regulatory contexts, have a strong and immediate effect on human rights and environmental practices. Buyers can support remediation through long-term relationships, financial and technical support to suppliers, and responsible exit strategies where impacts cannot be mitigated. This reinforces continuous improvement rather than risk avoidance.
ASC standards require companies to take corrective actions where they fail to meet a requirement (recognised as a non-conformity) as assessed by third-party auditors. This means that ASC-certified farms and feed mills are driving continuous improvement, mitigating negative impact and delivering positive change across the sector.
Step 4: Track
Due diligence is a continuous process. Established monitoring systems with clear indicators, milestones and metrics support effective tracking of mitigation measures. This can include routine internal audits, performance data collection, supplier performance tracking and feedback mechanisms for workers and communities.
The ASC Farm and Feed Standards require management systems to be in place and collection and maintenance of data through both conformance with standard indicators and demonstration of performance. This can be seen through the requirements to set up effective grievance mechanisms for workers, communities and other external stakeholders, which should inform ongoing risk management and monitoring.
Step 5: Communicate
Public reporting on human rights and environmental performance, including policies, impact assessments, mitigation efforts and monitoring results, holds companies accountable. This accountability sends a strong message to consumers that the company is taking responsibility. These communications are achieved through sustainability reports, corporate websites and supplier engagement platforms.
ASC certification delivers transparency. The results of all certification audits are publicly available for anyone to verify the performance of the farm or feed mill and understand the improvement actions being taken. Products sourced from certified suppliers delivers the assurance that ASC certified seafood originated from feed mills and farms certified by ASC.
Step 6: Provide for or cooperate
Where identified human rights or environmental impacts were not prevented or mitigated, companies should focus on remediation. This could mean compensating affected workers or communities, or contributing to activities that restore lost habitat.
ASC certified farms and feed mills are required to carry out remediation, if forced or child labour are identified, and implement corrective actions for any non-conformities against the standards’ human rights and environmental requirements.
The importance of collaboration
ASC, and other certification schemes, can play an important enabling role in HREDD through providing a ‘tool’ to assess operations, but this does not replace or limit a companies’ own responsibility to identify, prevent and remedy adverse impacts. Certification provides structured requirements across key social and environmental impacts, independent third-party verification of performance and comparable benchmarks that support companies in identifying risks, monitoring performance and delivering improvements.
Companies alone cannot achieve effective HREDD in the seafood sector. Collaboration between companies, governments, certification schemes, NGOs, worker representatives and other stakeholders is essential. Working together allows organisations to pool resources, share best practices, and support each other in tackling common issues.
Industry groups can collaborate on shared projects or sector-wide standards, while governments can create legal frameworks that hold companies accountable. Engaging with workers’ representatives and NGOs provides on-the-ground insights essential for meaningful change.
By fostering a collaborative environment, companies create a safe space for progress and ensure that all parties are working towards an ethical aquaculture sector, shifting away from a punitive mindset, towards one focused on prevention, learning and continuous improvement.
Learn more
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