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Indicator 1.4.7

Requirement

The UoC shall report to ASC the production volumes and sales/dispatch volumes of ASC certified and non-certified products originating from each site, and submit specified traceability data (when requested), according to ASC data submission procedures.

No additional guidance is provided for this indicator.

Indicator 1.4.6

Requirement

The UoC shall disclose to buyers of their ASC certified product, upon request, a list of all veterinary therapeutants applied to the product.

No additional guidance is provided for this indicator.

Indicator 1.4.5

Requirement

The UoC shall not sell or dispatch the following as ASC certified: a. crustaceans treated with antibiotics at the UoC, or b. any product treated with antimicrobials listed as Critically Important Antimicrobials for Human Medicine by the World Health Organisation (WHO), at any stage in the lifecycle of the product.

How Do I Interpret This Requirement?

  • This requirement addresses situations where a product may conform to the Standard, however it cannot be sold or dispatched as ASC certified.

  • The UoC should:

    • Maintain detailed records of any antibiotic treatments applied prior to the UoC (see Indicator 1.5.2).

    • Implement a process to ensure that the product under 1.4.5(a) or (b) is not sold or dispatched as ASC certified.

Evidence of Implementation

  • Records:

    • antibiotic treatments, including those applied prior to the UoC.

Auditors Should Confirm

  • UoC’s process to ensure that the product under 1.4.5(a) or (b) is not sold or dispatched as ASC certified.

Indicator 1.4.4

Requirement

Indicator applicability: every UoC using compound feed The UoC shall disclose to all buyers of their ASC certified product when a product’s feed contains >0.9%77European Council. (2003). Regulation (EC) No 1830/2003 concerning the traceability and labelling of genetically modified organisms and the traceability of food and feed products produced from genetically modified organisms and amending Directive 2001/18/EC. European Parliament, Council of the European Union. Genetically Modified Organisms (GMO) or macro ingredients produced from GMO.

How Do I Interpret This Requirement?

  • The required disclosure is to the UoC’s buyers of ASC certified products.

  • A public disclosure is possible but not required.

  • The UoC shall ensure buyers are informed when a product’s feed contains or is produced from GMO.

  • Disclosure may be provided to buyers individually or collectively.

Evidence of Implementation

  • Records:

    • disclosure to buyers.

Auditors Should Confirm

  • Evidence of disclosure to buyers.

Indicator 1.4.3

Requirement

Indicator applicability: every UoC using compound feed The UoC shall demonstrate that feed products, subject to conformance with Indicator 2.12.1, are accompanied by the following information: a. the originating feed mill holds valid certification against the ASC Feed Standard with the appropriate scope of certification in relation to the ASC Production Model (i.e. Mass Balance Production Model or Segregation Production Model product); and b. feed is traceable as ASC-conforming throughout all steps between the feed mill and site; and c. documentation accompanying the feed identifies the feed as ASC-conforming; and d. documentation accompanying the feed identifies the production model applied (i.e. Mass Balance Production Model or Segregation Production Model); and e. for ASC-conforming Segregation Production Model feed, the product is identifiable by a distinct feed name in formal documentation accompanying the product and is listed on the schedule to the feed mill certificate.

How Do I Interpret This Requirement?

  • Indicator 2.12.1 requires the UoC to only use ASC-conforming compound feed.

  • Use of non-conforming feed will be treated as a non-conformity against Indicator 2.12.1.

  • For product which is sold under the segregation model, identifying the feed production model and distinct feed name is required by the ASC Feed Standard, Indicator 3.3.2.

Evidence of Implementation

  • Process to confirm the originating feed mill holds valid certification against the ASC Feed Standard.

  • Records:

    • traceability system and its verification, for example:

      • use of a digital traceability system

      • outcome of any input-output exercises and traceability tests.

      • accompanying documents incorporating information required by 1.4.3(c), (d) and (e).

Auditors Should Confirm

  • Process to confirm the originating feed mill holds valid certification against the ASC Feed Standard.

  • Effective traceability and segregation systems are in place.

  • Outcome of any input-output exercises and traceability tests.

Indicator 1.3.2

Requirement

The UoC shall ensure that information provided as evidence of conformance to the ASC Requirements is not falsified or misrepresented.

How Do I Interpret This Requirement?

  • Records are documented information that provides permanent evidence about past events. They should:

    • Be completed and maintained in a way that ensures information is accurate and preserved;

    • Be genuine;

      • they should be completed at the time of the checks or shortly after.

    • Capture and illustrate information when processes do not perform as expected.

      • for example, if the cooling system ceases to work, it is important that temperatures above the acceptable range according to internal requirements are recorded so that management can learn from these events.

        • recording temperatures only within the acceptable range will lead to management not understanding that a backup temperature regulator might be needed.

    • Be legible;

    • Be complete;

      • which may include a form of authorisation through the initials of the supervisor verifying records are complete;

  • Be stored appropriately:

    • paper records should be stored in a way that prevents damage.

    • where records are stored electronically, this storage should be backed up.

    • If incidences of falsification of records or misrepresentation of information are identified, corrective action and actions to prevent recurrence should be taken.

Evidence of Implementation

  • Records:

    • that demonstrate genuineness.

    • corrective action and actions to prevent recurrence when incidences of falsification of records or misrepresentation of information are identified.

Auditors Should Confirm

  • records and their genuineness

  • effectiveness of corrective action and actions to prevent

Indicator 1.3.1

Requirement

The UoC shall discourage all forms of corruption and shall encourage ethical behaviour and integrity in their business operations.

How Do I Interpret This Requirement?

  • Corruption can:

    • Happen anywhere;

    • Involve anyone;

    • Take many forms. For example:

      • extortion

      • embezzlement

      • bribery

  • Examples of corruption are:

    • A manager buys supplies from a friend and in return, the friend gives 20% of the profits to the manager. This may go as far as the manager excluding other appropriate suppliers from the system of approved suppliers.

    • A piece of infrastructure has an unsafe mechanism and the owner pays the manager cash to not disclose this at the next audit.

  • Examples of extortion are:

    • Employee A threatens to provide information to the manager which could get Employee B into trouble or fired, unless Employee A is paid a requested amount of money.

    • A site owner threatens to hurt the owner of the neighbouring plot of land unless the land-owner agrees to give up some of his land so that the site can build an additional building.

  • Examples of embezzlement are:

    • A site manager getting cash from the first point of sale in exchange for under-declaring harvest volumes (i.e. the purchaser receiving more product that they are paying for).

    • A sourcing manager purchases cheaper non-eligible feed but registers them as eligible and provides documentation falsely declaring it as more costly eligible feed, as financial sourcing performance increases the sourcing manager’s bonus.

  • Examples of bribery are:

    • A supplier buys a new car for a site manager, in exchange for the site manager giving the sourcing contract to that supplier.

    • A site pays cash to customs officials to speed up the passage of their feed through the import and export system.

    • A sustainability manager offers auditors excessive accommodation and lunches to reduce the audit effort or to turn a blind eye to non-conformities.

Evidence of Implementation

  • Policies preventing corruption, including extortion, embezzlement and bribery.

  • Terms of dismissal should employees engage in these practices.

Auditors Should Confirm

  • Management and employees are aware of:

    • what these practices involve and how to recognise them.

    • the policies in place for preventing corruption, including extortion, embezzlement and bribery.

Useful Resources

Indicator 1.2.4

Requirement

The UoC shall annually review the management system and revise it where necessary to ensure its continued suitability, adequacy and effectiveness in implementing the ASC Requirements.

How Do I Interpret This Requirement?

  • The UoC’s management system review should provide the opportunity to assess its suitability, adequacy and effectiveness in continuously ensuring conformance with the ASC requirements.

  • The review should consider:

    • Progress and effectiveness of changes implemented following the previous management review.

    • Financial and personnel resources necessary to maintain the management system.

    • Changes in the internal and external context of the site which may give rise to previously unanticipated issues.

    • Performance review since the previous management review.

    • Internal and external audit outcomes.

    • Grievances raised.

    • Progress towards longer-term ASC targets, e.g. an increase in wage payments.

    • Progress towards site commitments.

    • A mechanism for employees’ feedback on the effectiveness of the management system

    • The outcome of the review should include addressing any need for changes and opportunities for improvement in the management system, which is documented and communicated to relevant employees for implementation.

Evidence of Implementation

  • Records:

    • of the review and its outcomes.

    • meeting minutes.

Auditors Should Confirm

  • Review is conducted at least annually.

  • Records.

Indicator 1.2.3

Requirement

The UoC shall ensure that relevant employees have the necessary skills and training to implement the ASC Requirements.

How Do I Interpret This Requirement?

  • At the site, it should be clear who is responsible for what tasks and management should ensure all employees are competent for the role that they will be carrying out. Employees should have:

    • Knowledge,

    • Experience,

    • Training (theory and on the job),

    • Capacity, and

    • Decision-making permissions.

  • ‘Relevant employees’ and ‘necessary competencies’ refer to an employee’s function and area of responsibility:

    • For example, a Health and Safety Manager is able to carry out and regularly update the Health and Safety risk assessment and define mitigating measures, but might not have the experience to treat injuries. Or the person responsible for first aid can take immediate action in the case of an injury and has access to and an overview of all first aid supplies, but might not have the experience to carry out a Health and Safety risk assessment.

Evidence of Implementation

  • Job descriptions of all employees.

  • Organisational chart with clarity on who is responsible for what.

  • Records and documents of training.

Auditors Should Confirm

  • Employees and management are clear on their roles and responsibilities in the implementation of ASC Requirements.

  • Employees have the necessary competencies, knowledge and experience to implement the ASC Requirements.

Indicator 1.2.2

Requirement

The UoC shall appoint at least one member of management responsible for the implementation of the ASC Requirements.

How Do I Interpret This Requirement?

  • The responsible person may be one person or several persons, covering the wide range of issues addressed by the ASC Requirements.

    • For example, a human resources manager may be responsible for the requirements on labour rights and working conditions, and a fish health and welfare manager may be responsible for the requirements on fish health;

      • senior management should be responsible for seeking more specialised knowledge when needed.

  • The responsibility should be embedded in the organisational structure documentation to ensure clear accountability.

Evidence of Implementation

  • Records:

    • that evidence the responsible person(s) were designated by the management.

    • role description of the responsible person(s) for the implementation of ASC Requirements.

Auditors Should Confirm

  • The management designated responsible person(s) for the implementation of the ASC Requirements.

  • through records and interviews with employees and the management.

  • Role description of the responsible person(s) for the implementation of the ASC requirements.