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Collective rights

Our commitment to human rights.

In addition to developing a Human Rights Policy, the Bolton Group and Bolton Food have outlined a theme in their Ethics Code for the management of Human Rights across the entire fishing chain, including and as far up as sales. Guaranteeing respect for fundamental human rights constitutes an essential element of the sustainability of our company.

Dignity and respect for the individual are at the heart of our corporate culture.

For this reason, the Bolton Group and Bolton Food are committed to promoting the respect of Human Rights and eliminating their violation, both within the company as well as among its suppliers.

The Human Rights Policy implements and supports the principles laid down in the Universal Declaration of Human Rights and the conventions which it inspired, including the ILO Declaration on Fundamental Principles and Rights at Work, the United Nations Conventions on the Rights of the Child, the Children’s Rights and Business Principles promoted by UNICEF, Global Compact and Save the Children.

The documents which form Bolton Food’s Policy and Ethics Code are a fundamentally important tool that is shared with our direct suppliers who endorse and apply their conditions.

As regards indirect suppliers, including tuna loins suppliers and vessels not owned by the company, we are supported by our strategic partner Tri Marine and its Ethical Sourcing Policy to guarantee respect for the requisites that make our supply chain safe and valuable to all those involved.





We began monitoring respect for the principles outlined in our Human Rights Policy by means of a self-assessment questionnaire. The results of the questionnaire will be validated by an auditing system to guarantee respect for our principles across the supply chain. 

As to define a priority action, we classified our suppliers, based on their exposure to the risk of human rights violations. Three aspects were taken into consideration in order to establish the level of risk:

  • Strategic relevance of the good/service supplied
  • Volume of supplier’s turnover
  • Country in which the good/services supplied is produced or issued

Suppliers at high risk are required to complete a self-assessment questionnaire once a year, suppliers at medium or medium-high risk are required to complete a questionnaire once every two years, while suppliers falling within medium-low or low risk categories are not sent this questionnaire. However, should the need arise, they too may be asked to complete it.

Overall risk categoryDescriptionFrequency of HRC dispatches
HighA high risk that could have a significant impact on human rightsOnce a year
Medium-highA medium-high risk that could have a significant impact on human rightsOnce every 2 years
MediumA medium risk that could have a significant impact on human rightsOnce every 2 years
Medium lowA medium-low risk that could have a significant impact on human rightsIf necessary
LowA low risk that could have a significant impact on human rightsIf necessary

To-date, in addition to sending questionnaires, suppliers considered at high risk have been evaluated. Based on the results that emerged from these questionnaires, we will take action by conducting on-field audits about potentially critical situations and in areas considered at major risk. Once these audits have been conducted, in the event of violations or anomalies being reported, we will evaluate the implementation of suitable actions to resolve or eliminate violations that have actually been identified.

We periodically evaluate our medium-high and medium risk suppliers through questionnaires.