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Corey Norton - WWF - On How STF Aims to Provide New ESG Legal Compliance Resources at a Scale Otherwise Impractical

New supply chain laws pose novel compliance challenges, particularly for EU and U.S. companies, that can be overcome most effectively, and perhaps only, through efforts like the Seafood Task Force. These laws require companies to know, and sometimes even publicly report, on a rolling basis how thousands of actors across distant supply chains perform on ESG issues.  If executives ask how their companies can ensure they always have the required evidence from their supply chains, they will most likely find these new laws require bandwidth and expertise that are not common corporate capacities. Even the biggest companies typically will not have enough people to coordinate thousands of distant actors, nonetheless expertise on numerous evolving legal standards or ability to generate new types of compliance evidence required.  Industries and their supply chains acting together, however, can pool bandwidth, capacities and expertise to track what laws require, coordinate understanding among supply chains and implement required practices faster and more effectively than companies acting alone.  This is a core goal the Seafood Task Force pursues.

For example, forced labor and deforestation import prohibitions and scope 3 reporting, due diligence and false advertising laws all require companies to oversee the entirety of their supply chains and respond to inadequate results.  This requires full supply chain traceability, expertise to evaluate labor conditions, monitor tree cover and collect emissions data and then procedures to report related results back down the supply chain, generally to a brand. Companies overall will not have adequate personnel to work with each of their thousands of supply chain companies to align them on practices needed, identify and engage localized monitoring expertise and implement systems to collect and respond to data from suppliers at multiple levels of the supply chain.  Even if companies did have those capacities, deploying them alone would be massively duplicative from company to company and excessively onerous for each supplier needing to work with multiple customers trying to do their own, but essentially same, thing. 

One solution seeing success is to bring actors from all levels of the supply chain around the table to accelerate everyone’s understanding of the issues, draw upon collective expertise on procedures that can work while avoiding duplication and reducing cost and burden for everyone by divvying them up among all involved.  This is the essence of the STF and where it is already starting to operate.

At the STF table are key actors from all levels of certain critical tuna and shrimp supply chains.  This has enabled whole supply chains to start by developing a common code of conduct, traceability procedures, assessment methods and data collection and flow.  The work is challenging, touches many sensitivities and raises thorny legal questions, but it is showing compliance resources to address new supply chain ESG legal duties are possible at scale and lower burden through collective action. Even more is possible in terms of geographic scope, ESG legal requirements covered and data availability.  Each current and new STF member company’s legal compliance can be accelerated the more companies commit to this direction and dive into the hard work required to go there.

Corey L. Norton

Vice President for Supply Chain Legality

WWF

The views in this article are those of the author and do not necessarily represent the views of the STF.

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