Visit to the Thai Aquaculture and Processing Supplier in March 2025

In March 2025, we visited a shrimp aquaculture and processing company in southern Thailand (Seafresh Industry Public Company Limited, ”Seafresh”), one of our group’s suppliers, together with Seafood Legacy, an advisory on sustainable seafood procurement and Dignity in Work for All (DIWA), an NGO specializing in labor human rights.
In accordance with Marubeni’s basic policy, we checked the following items and found no major violations with respect to compliance with laws and regulations, respect for human rights, occupational health and safety, and environmental conservation. The main points confirmed are as follow.

＜Survey Criteria＞

This survey mainly used the following criteria to confirm the risk management situation:

Human Rights and Occupational Health and Safety	Marubeni Group Supply Chain Basic Supply Chain Sustainability Policy Marubeni Group Basic Policy on Human Rights Marubeni Group Basic Policy on Occupational Health and Safety Marubeni Group Seafood Products Procurement Policy Local relevant laws and regulations
Environment	Marubeni Group Supply Chain Basic Supply Chain Sustainability Policy Marubeni Group Environmental Policy Marubeni Group Seafood Products Procurement Policy Local relevant laws and regulations

In this survey, in terms of human rights/labor rights, occupational health and safety, and the environment, based on previously implemented survey methodologies, we developed a survey sheet consistent with the “Marubeni Group Seafood Products Procurement Policy” published in 2024. For the on-site survey, we received information on operational activities from Seafresh via a pre-questionnaire, enabling us to prepare requests for additional on-site verification documents and prepared for worker interviews.

During the on-site survey, details were confirmed based on a survey sheet by interviewing Seafresh's Social Responsibility (SR) manager and human resources staff regarding human rights and occupational health and safety, and consistency was confirmed with the contents of supporting documents. Extensive worker interviews were also conducted with 51 workers to confirm the extent to which policies and initiatives have been implemented and risks in the working environment.

Regarding the environment, the main subjects of interviews were the Chief Operating Officer (COO), SR manager, and Quality Control and Audit (QCA) manager, and the actual environmental impact within both the processing facility and the farm was confirmed. As implemented regular monitoring records and documents such as permits and certifications related to the operations were reviewed, and a simple confirmation of the traceability claims from the raw material hatchery to the final product was also conducted using international standards.

＜Detailed Items＞

Governance

• Seafresh has a policy regarding internal governance that includes compliance with laws and regulations and, keeps transparency to stakeholders such as investors. We also maintain documents that clearly indicate where responsibility lies within the company and set out the reporting and implementation procedures.

Human Rights/Labor Rights

• Workers of all nationalities reported satisfaction with the company, and especially Thai workers reported good awareness on employment rules and company policies related to labor and human rights. Also, the grievance system is comprehensive.

Occupational Health and Safety

• Good governance and management of OHS.
• Work Instructions on Risk Assessment showed procedures on conducting occupational health and safety per work section. Review internal risk assessment documents showed that the latest safety risk review was conducted regularly, showing control and mitigating measures identified.
• Occupational Safety, Health and Working Environment Policy contains adequate provisions on occupational health and safety. Site inspection showed policy being posted on bulletin boards in Thai, Myanmar, Khmer and English.

General Environment Impact

• Seafresh is committed to conserving water resources used in its operations, including ice production, and some recycled water is being used. In addition, a land-based recirculating aquaculture systems (RAS) has been installed at the aquaculture site. In this respect, it has been confirmed that the environmental impact of wastewater, along with the use of water resources, is being kept low.
• Seafresh is promoting the use of renewable energy throughout its facilities.
• At Seafresh, shrimp heads and shells generated during the processing process are sold to a nearby feed company every day and are properly disposed of and reused.
• Single-use plastics used within the Seafresh facility are collected at several collection points within the facility and disposed of appropriately.

Seafood Specific Environmental Impact

• A comprehensive biodiversity and environmental impact assessment has been carried out around the Seafresh farm, and the gaps identified by the assessors were improved.
• Detailed monitoring including water quality and feeding is carried out not only at the processing facilities but also at the farms in accordance with international best practices, and records are kept appropriately, so it can be said that risk management is in place that allows for rapid response, if a deterioration in water quality is detected.
• In addition to managing the sustainability of its own farms, the shrimp procured as raw materials for processing are sourced in accordance with Seafresh's environmental policy.

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Supply Chain