James Sloan is a barrister at law in the English jurisdiction, but based in Fiji and running a law firm for quite a few years for now. But as most of the people I appreciate and admire, their job does not just define who they are… James’ life includes running, the environment with a particular focus on the ocean, governance systems and how to promote good decision making, providing a good working environment, travel, amateur photography, good science fiction and family. Hence we have quite a few overlapping interests!
He publishes an Ocean Law Bulletin I have been following for years (and you should too). He invites sometimes specialist in the region to co-write them and is always top reading.
So I was really honoured when he asked me to work on a piece on some of the updates and good stuff that has slowly been happening in the region and worldwide on the topic of decent labour in fishing vessels.
I’ll transcribe the article here below, but you also can read it in his page.
Unfortunately, offshore fishing is an industry that has become synonymous with poor working conditions and human rights abuses when compared with other ocean industries like shipping. This is because some of the activity of fishing itself takes place outside of the legal jurisdiction of any nation State, on the “high seas” and within EEZs where no State has sovereignty to make and enforce laws.
In effect it is an industry where bad players can get away with being unregulated and through the regime of flag State registration effectively claim "immunity" from legal oversight in relation to working conditions. This is not to say all offshore fishing vessel operators are bad players but those fishing vessel operators who do want to comply with good employment standards do not compete on a "level playing field".
The awareness raised by civil society organisations (CSOs) and stakeholders has led to various recent developments, including the development of a specific International Labour Organisation Convention (“ILO”) (Work in Fishing Convention, 2007 (No. 188)) (“C-188”) being developed and entering into force in November 2017.
Six months ago, in Cape Town, South Africa, the provisions of C-188 were brought to bear by South African authorities against a foreign owned fishing vessel (a link to ILO’s report on this story can be found here).
The problem exists because some flag States who do have the legal jurisdiction to enforce labour standards on vessels on the high seas that are registered to that flag State lack the ability or willingness to regulate offshore fishing vessels that "fly their flag". Effective and universal flag State regulation is an issue of oceans governance and this is same issue that underpins Illegal, Unreported and Unregulated (“IUU”) fishing on the high seas and within coastal States’ EEZs.
Solving this ocean governance issue in the fishing industry would likely lead to direct benefits for Pacific Island States both because employment opportunities would improve for Pacific Islanders and because those fishing vessels that are well regulated are more likely to comply with conservation and management measures put in place to protect the Pacific’s essential fish stocks.
In this extended legal bulletin we summarise the international law problem of unregulated labour standards in the offshore fishing industry and consider recent efforts that provide steps in the right direction to bring an end to a shameful problem that should no longer be tolerated in the 21st century.
After all, as things stand, on the high seas (areas beyond national jurisdiction) the transportation of slaves by sea is an international crime and is regulated by the law of the sea framework. Contrast this with forced/slave labour and human rights abuses on people “employed” on fishing vessels in the same areas of ocean, and who fall outside any effective regulatory law of the sea framework and as a consequence find themselves outside the reach and protection of the law. To change this may require an overdue shift in general international consensus to amend the current law of the sea and governance framework.
Six months ago, the competent authority in South Africa relied on its Port State jurisdiction to take enforcement action against the fishing vessel that had docked in one of its ports (South Africa is currently one of 10 signatories to C-188). Unfortunately the “long list of problems” that South African authorities found on board the fishing vessel “including lack of documentation, poor accommodation, insufficient food for fishers, and poor safety and health conditions on board” and overall “very poor” health and safety conditions is not unusual in the industry. In terms of employment standards there was not a crew list on the vessel and only two of the crew members were found to have employment agreements. The failure to keep a crew list may seem innocuous but in the context of reported issues that have happened at sea it is, in fact, a chilling reminder of how vulnerable undocumented and unrecorded crew members are.
However, lack of regulation in the offshore fishing industry is not a simple problem with a simple solution. As with many issues of oceans governance and fishing in particular the solution is not as simple as relying on new legal instruments or policy documents. Rather, solutions can only be found through a joint effort involving the industry, regulators and civil society collaborating within the existing legal and governance framework and calling for fundamental change. Above all nation States that register/flag vessels must step up or be compelled to step up to their legal responsibilities to bring the fishing industry employment standards in line with what is expected in the 21st century.
The issue of forced labour and work in fisheries has been the subject of the latest UN General Assembly Resolution (UNGA) on Fisheries - agreed in December 2017. Paragraph 172 of the UNGA Resolution provides:
(the UN General Assembly) Calls upon flag States to effectively implement their duty under the Convention with respect to labour conditions, taking into account applicable international instruments and national laws, and in this regard encourages States that have not yet done so to consider becoming parties to the Protocol of 2014 to the Forced Labour Convention, 1930 (No. 29) and the Work in Fishing Convention, 2007 (No. 188), and to implement the Guidelines for port State control officers carrying out inspections under the Work in Fishing Convention, 2007 (No. 188) and the Guidelines on flag State inspection of working and living conditions on board fishing vessels”… This paragraph is actually copied from last year's UNGA fisheries resolution paragraph 169 – i.e. this is the existing view of the UN General Assembly.
By calling on flag States “to effectively implement their duty…” the UNGA has recognised and gone to the heart of the knotty international law problem that affects many areas of Oceans Governance.
In summary the problem is:
The legal jurisdictions of nation States (sovereignty) only extends to a maximum distance of 12 nautical miles from their coastlines (assuming that the State is a coastal State).
Once any vessel/ship (including a fishing vessel) is beyond that distance, generally speaking, only the State that the vessel is registered to (the flag State) has any regulatory jurisdiction over the vessel.
As a consequence, for any worker aboard that vessel/ship he or she must rely on the flag State to protect his or her legal rights including employment rights.
This principle of jurisdiction recognises the ancient principle of freedom of the high seas, is part of customary International Law and is enshrined in the United Nations Convention on the Law of the Sea (“LOSC”).
In effect, if the fishing vessel owners and operators are not interested in providing adequate working and health and safety standards aboard the vessel (a bad player), and the flag State is not capable or interested in regulating those standards, then the worker aboard that vessel is outside effective regulation and is vulnerable to exploitation without legal rights or effective recourse.
This problem is exacerbated by the ability for States with no interest in regulatory standards to offer open registries where the international law requirement contained in LOSC to register the vessel is fulfilled in exchange for a registration fee. This currently accepted practice of registries of convenience produces vessels/ships that fly “flags of convenience”. There is also nothing to prevent a vessel from registering in new jurisdictions to fly a different flag, although under LOSC a vessel/ship cannot be registered in two jurisdictions at once as it is then deemed “stateless” (without nationality) and has no protection as it is not under the “jurisdiction” of any flag State and loses its effective flag State "immunity".
These open registries are well known and perhaps operate only to collect a registration fee. Generally speaking, they seem to have no interest in regulation, and are often in jurisdictions with inadequate employment protection (this fact may have attracted the registration in that jurisdiction in the first place as unscrupulous vessel owners will know that their operations will face little or no legal scrutiny in all areas beyond national jurisdiction).
This situation has led to many calls for a change to the governance framework based on LOSC that relies on flag State regulation to be effective. However, since its coming into force in 1982 there has been no amendment to LOSC, and in any event, the emphasis and approach of international law and LOSC is to seek solutions via universal cooperation and agreement/consensus among all nation States.
This unresolved and difficult international law governance problem presented by flag State jurisdiction remains the major barrier to change and effective enforcement despite the large number of international agreements and voluntary standards that vary in their scope and adoption in this area. Remember, South Africa were able to take action because the offending fishing vessel had docked in one of its ports and therefore had submitted to South African sovereignty/jurisdiction.
For example, prior to C-188, the ILO and the International Maritime Organization (IMO) established a number of binding legal instruments to improve fishers’ safety and working conditions. This included:
the IMO’s Torremolinos Protocol and the IMO’s Convention on Standards of Training, Certification and Watchkeeping for Fishing Vessel Personnel (STCW-F) which entered into force in March 2013; and
non-binding recommendations and codes, some of which were developed jointly between the ILO, the Food and Agriculture Organization (FAO) and the IMO.
As mentioned at the start of this piece the ILO has in recent years turned its focus to the fishing industry through the adoption of the C-188 (read more about it: Work in Fishing Convention, 2007 (No. 188).
In brief, C-188 seeks to ensure decent standards for all fishers regarding conditions of service, accommodation and food, occupational safety and health protection, as well as medical care and social security. The Convention came into force in November last year when the 10th country ratified it. C-188 is supplemented by the accompanying Work in Fishing Recommendation (No. 199) as well as two sets of Guidelines for flag States and port States carrying out inspections under the Convention.
On the safety side of work at sea, there is the 2012 Cape Town Agreement (CTA), adopted by the International Maritime Organization (IMO), which also outlines fishing vessel standards and includes other regulations designed to protect the safety of crews and observers and provide a level playing field for the fishing industry. The CTA updates, amends, and replaces the Torremolinos Protocol of 1993, relating to the Torremolinos International Convention for the Safety of Fishing Vessels, 1977.
Neither the Torremolinos convention nor the protocol will enter into force themselves, but the CTA reflects provisions contains in them. Once in force, the CTA will set minimum requirements on the design, construction, equipment, and inspection of fishing vessels 24 meters or longer that operate on the high seas. Its entry into force would empower port States to carry out safety inspections that could be aligned with fisheries and labour agencies, to ensure transparency of fishing and crew activities. The treaty consists of minimum safety measures for fishing vessels that mirror the International Convention for the Safety of Life at Sea (SOLAS)—an internationally binding treaty on safety for merchant vessels that entered into force in 1980. It also calls for the harmonised fisheries, labour, and safety inspections.
The CTA will enter into force 12 months after at least 22 states with an aggregate 3,600 fishing vessels of at least 24 meters in length operating on the high seas have expressed their consent to be bound by it (China alone gets to this number)
To date, 10 countries have ratified the CTA so there is still some way to go until the CTA enters into force, and at present, until it is in force, there are no mandatory global safety regulations for fishing vessels. The slow pace of ratification of these conventions inhibits effective control of safety and labour standards in the offshore fisheries sector.
It has been suggested that the “stagnancy” relating to finding a solution is due to a lack of a “pressure driver” around industry, governments and civil society, and as consequence it undermines important opportunities to prevent and detect instances of labour abuses. To some extent this must be right, however, in terms of international law, it is hard to make effective change when a universal consensus is the generally preferred or only method of change.
It should also be noted that as well intended as they are, neither C-188 or the CTA alone are capable of making this change to the underlying international governance issue related to flag States, where those flag States are not interested to, or do not, “implement their duty”.
However, there have been four interesting, recent and separate developments that may lead to some positive outcomes in the area of decent labour in fishing vessels. These changes are well-intended, specific and targeted, and I hope will lead the way towards, and set the standard for a fundamental change in the international consensus and approach in this area.
Development 1: FAO’s Development of a Position Paper on Decent Labour for COFI:FT in 2019
The COFI Sub-Committee on Fish Trade (COFI:FT) of the Food and agriculture Organization of the UN (FAO) has a specific mandate to:
promote social sustainability in fisheries value chains,
promote the recognition and protection of human and labour rights in national and international value chains, and to
collaborate with international partner organisations – such as International Labour Organization (ILO), United Nations Conference on Trade and Development (UNCTAD), Organisation for Economic Co-operation and Development (OECD) and others.
FAO Member countries through the COFI:FT session in 2017 recognised the complexity of addressing social issues relative to human and labour rights in fisheries value chains, recommending that FAO collaborate with interested partner organisations and stakeholders to develop a guidance document to assist fish value chain actors.This aims to improve the implementation of existing instruments and measures that encompass responsible business conduct, human rights and international labour standards.
At its thirty-third session in July 2018, the FAO Committee on Fisheries (COFI) decided that the guidance on social sustainability should be developed in cooperation with relevant stakeholders, including industry and fish worker associations, through a process known as the Vigo Dialogue. The aim is to improve the sector and move towards the achievement of the Sustainable Development Goals (SDGs).
The Vigo Dialogue will also focus on measures for social responsibility in the fisheries and aquaculture sector as strategic approaches to combat abuses of human and labour rights in fish value chains. The overall objective is to facilitate an open discussion to enable feedback and input from stakeholders in order to address the challenges and complexity of this topic.
In particular, the Dialogue will focus on the mandate from COFI on social responsibility and the process and roadmap for the guidance development and stakeholder involvement. The final outcome of the guidance development process will be presented to COFI-FT in 2019 and COFI in 2020.
This process is underway under the combined efforts of one of my friend and seafood labour specialist Katrina Nakamura, and myself.
Development 2: The Tuna from Responsible Fisheries Standard - UNE 195006:2016
The 2016 “Tuna from Responsible Fisheries” (Spanish acronym: APR) standard (UNE 195006:2016)by the Spanish Association for Standardisation (AENOR) is the first certification associated to an national normalization body, aimed at tuna fishing that incorporates crew labour issues.
It was prepared by the Technical Committee AEN/CTN 195 “Capture fisheries” whose Secretariat is held by AENOR. The standard is intended to guide the European Committee for Standardization (CEN) in the development of standards for tuna imports in the European market. The APR seal was granted to seven firms belonging to the Organisation of Producers of Frozen Tuna (OPAGAC) to certify that their tuna was caught with sustainable methods by fishing vessels that do not violate their workers’ rights. Together these 7 fleets own 39 boats fishing in the Atlantic, the Pacific and the Indian Oceans, their crews total approximately 1600 workers.
The APR seal certifies that the tuna offered to retailers and end consumers complies with all the relevant standards, which in terms of labour standards is based on ILO’s C-188 (Work in Fishing Convention, 2007 (No. 188))
In order to grant the APR seal, AENOR audits the tuna fishing boats for compliance with standard UNE 195006: ‘Ethical Tuna Fishing. Purse-seine Fishing Boats and Freezer Vessels’. This standard regulates occupational safety and social issues, as well as maritime and health controls.
The approach taken by this private sector group was to approach AENOR as the organisation legally responsible of development and diffusion of technical standards in Spain, and base their official compliance assessment as a state guarantee of impartiality that goes beyond the usual model of private certifications and ecolabels. This approach sets a baseline of good practices that could be replicated by industry groups based on one flag State as in this case or on various flag States under common beneficial ownership.
Development 3: WCPFC Resolution on Labour Standards for Crew on Fishing Vessels
At the Western and Central Pacific Fisheries Commission (WCPFC) 15th Regular meeting in Honolulu in December 2018, Pacific Island States as FFA members and through their representative Regional Fisheries Management Organisation (FFA) tabled a proposal for a Resolution on Labour Standards for Crew on Fishing Vessels. This was the first time that a labour proposal was tabled in any Regional Fisheries Management Organization (RFMO) on the global/regional stage.
Although this measure proposed by Pacific Island States was criticised by some for being ambiguous and uncertain in its effect it was adopted as a non-binding resolution (meaning that Members of the WCPFC are not, as yet, obliged to incorporate it into their legislation).
However, despite the criticism, Pacific Island States through their representative FFA have made it clear that this is an important issue for Pacific Islanders and this provides the opportunity to further pressure future meetings of WCPFC to make this a compulsory Conservation and Management Measure (CMM) at some stage, hopefully, in the near future.
After all, it is not a difficult stretch to make the link between fishing vessels registered to flag States who are interested in good regulation and workers’ rights with compliance with fisheries conservation and management measures. A formal CMM would also demonstrate leadership at an international level.
Therefore, in our view this is an important step, as an expression of what is important for Pacific Islanders who have the exclusive rights to the largest and most valuable EEZs globally. Further, it is significant and right (in our humble opinion) for a fisheries management body to express the importance of workers’ rights and health and safety issues that has also set a precedent for other RFMOs to follow.
Development 4: The incorporation of a labour component in a Taiwan fisheries legislation
Taiwan is a substantial player in world fisheries, and significant in the Pacific. Taiwan’s complex relationship with China has an impact on the way that Taiwan conducts its fisheries and meets its responsibilities as a flag State. Furthermore, its vessels and nationals have in the past been associated with the most notorious cases of labour abuses.
Partly because Taiwan was identified as a “non-cooperating state” in terms of IUU fishing by the EU who imposed a “Yellow card” in late 2015, Taiwan has revamped its legislation framework and included a labour component in its 2017/2018 Act for Distant Water Fisheries (link to translated version) where Article 26 reads:
Any distant water fisheries operator intending to hire abroad any foreign crew member shall obtain permission from the competent authority. Such hiring shall be done by the distant water fisheries operator itself or through domestic intermediaries or agents (hereinafter referred to as the agents).
The agents referred to in the preceding paragraph shall be authorized by the competent authority and shall deposit a certain amount of guarantee bond.
Regulations on the qualification of the foreign crew member, conditions for permission, required documents, rights and interests of the distant water fisheries operator and the foreign crew member, contents of contracts, conditions for authorization of the agents, period, management, conditions for revocation, rights and interests of the agents and the foreign crew members, contents of contracts, management responsibilities, the certain amount, submission and refund of the security, and other requirements as referred to in the preceding two paragraphs shall be prescribed by the competent authority.”
The Taiwan Fisheries Agency as the Competent Authority then endorsed the “Regulations on the Authorization and Management of Overseas Employment of Foreign Crew Members” which at least on paper makes substantial progress towards safeguarding the rights and benefits for foreign crews on distant water fishing vessels, and show other flag States what is possible
The regulation indicates the principle of “overseas employment, operation, and repatriation” is adopted due to the nature that Taiwanese distant fishing vessels conduct fishing activities in distant fishing grounds for a long period of time, and usually employ foreign crew members at foreign ports.
As the wage and other working conditions of these employed crew members are governed by the mechanism of the international labour market in principle the Taiwan government recognises it may not be the same as the domestically employed foreign labour in Taiwan to whom the Taiwanese Labour Standards Act is applied.
The 36 articles and forms of the regulation include quite advanced provisions to safeguard the rights of crew, such as the increased wage and specified working hours among others. Some of its main requirements include:
Minimum monthly wage is set as USD 450 per month (for reference purposes it is known that Vietnamese crew working in someChinese vessels make around USD 150 per month) and shall be paid directly to the crew member in cash or into the bank account designated by the crew member
Minimum daily rest time is set as 10 hours, and at least 4 days off per month is required. The vessel operator must also respect the need of the foreign crew member for religious holidays
The foreign crew member must have the accident, medical and life insurance, and the insured amount of the life insurance shall not be less than NTD$1,000,000. When a crew member is injured or sick during carrying out the duties, the vessel operator (master) shall arrange immediate medical treatment and shall pay the medical fees and other related expenses
The vessel operator shall cover the transportation costs of the round trip from the home country of the foreign crew member(s) to the port of embarkation and repatriation.
The Regulations also require that the vessel operators should provide easily accessible channels for crew for complaints filing, including a hotline for labour issues for the crew members on distant water fishing vessels. If any violations are detected, the Competent Authority will or should assist the crew members in retrieving their lawful benefits from the vessel operator and take punitive actions accordingly.
In addition, if any suspected violation of the “Human Trafficking Prevention Act” is found, the case will be referred to the judicial authority for investigation and due punishment, whether the vessel is registered to Taiwan or elsewhere but that owned (even partially) and operated by Taiwanese nationals.
The Taiwanese regulations include a series of forms that must be carried by vessels and operators, that will be useful and may be required in any event, for port and coastal States to assist in assessing compliance.
So far, these regulations have been implemented in the case of the vessel Fuh Sheng No.11accused of violation of ILO Work in Fishing Convention in Cape Town, South Africa. The investigations resulted in fines to the operators.
While the legislation by Taiwan is ground-breaking, it is too early to determine how far Taiwan will go to enforce the legislation.
Of course, despite the developments more solutions need to be found before working conditions on fishing vessels can be guaranteed to improve
Again, the above initiatives will not solve the fundamental problem of legal jurisdiction on areas beyond national jurisdiction where a flag State remains unwilling or unable to enforce standards.
Further problems exist for Pacific Island States because there are not uniform employment standards, including minimum wage standards, across all Pacific Island jurisdictions.
As well as these issues, there is the perennial and worrying problem of uninformed or misinformed crew members entering the fishing industry. In many places crew members are recruited who are unable to access any form of formal advice in relation to offers of work. The brokers or agents who recruit crew members may not be regulated under their own jurisdiction and as such the recruitment of crew members is another unregulated activity.
This may or may not be the case depending on the Pacific Island jurisdiction, with Fiji for example, making it compulsory for each foreign contract of service to be approved by the Ministry of Employment. However, this is not a uniform requirement across all Pacific Island jurisdictions and even where it is a required workers may still “slip through the gaps”, as it is well known that the crew members themselves may be distrustful or wary of authority during the recruitment process.
A 1998 FAO publication Social Issues in Fisheries - FAO FTP 375 expands on this problem:
10.3 Attitudes towards institutions and authorities
People’s attitudes to authority will also play a major role in shaping their responses to efforts to manage their fishing activity. Fishers the world over are renowned for being independent and suspicious of authority. This is as true in modern, industrialised fisheries as in artisanal fisheries in less developed countries.
In order to gauge what responses to different types of fisheries intervention might be, managers need to look at the history of management and assess how stakeholder communities have reacted to these interventions and also assess current opinions and attitudes towards authorities concerned with fisheries.
These attitudes towards the institutions responsible for fisheries can have a major influence on the extent to which future fisheries interventions will be observed. If a particular institution is commonly perceived by fishers as being either untrustworthy or dominated by particular sets of interests which are not necessarily sympathetic to the needs of fishers, co-operation is likely to be reduced. On occasions, the same set of fisheries interventions might succeed or fail simply depending on who it is that is seen to be enforcing them.
The brokers/agents working with prospective crew members may range from legally-regulated job placement agencies to informal setups (sometimes associated with people-smuggling and trafficking). In most cases, brokers/agents charge a fee to be paid against future earnings, which without good regulation may become a basis for debt bondage.
Further it is not uncommon for crew to be transferred from one broker to another, or brokers may source fishers for recruitment agencies or fishing vessels directly. Many crew may come from non-ocean fishing countries (i.e. Nepal, Laos) and will not be aware that they will be working on fishing vessels and what are the conditions until they find themselves in the harbour.
In relation to the practice of brokers/agents, it is important to understand the process of recruitment which usually starts with:
The crew member signing up with an agent in their home State/jurisdiction based on various promises and assurances that may or may not be committed to writing (in any event the crew member may or may not be illiterate)
An agent may then take the crew member to a vessel in a different State - X
The crew member may then join a vessel owned and operated by a company from a different State - Y
The vessel may be registered and therefore regulated by a different State - Z
At the end of this process the crew member may not have been provided with any accurate information during the recruitment process regarding his or her employment contract, working conditions and rights. As the crew member’s vessel leaves port, it is easy to see how vulnerable his or her position now is.
Importantly, the new Taiwanese legislation does include certain responsibilities and obligations relating to the crewing /recruitment agent or broker (if that agent is also Taiwanese) who is a key figure in the crewing sphere of the fishing industry and who usually is not bound by legislation/regulation.
Finally, a further area of interest is the role of the port State that (as in fisheries) can have a role if and when the vessel chooses to dock at the port State. At this point, port State jurisdiction applies and working and health and safety conditions on the vessel may become regulated by the port State. This is demonstrated by the recent South African enforcement proceedings.
However, this is still not a guaranteed solution because first, a vessel may choose not to enter a coastal/port State jurisdiction remaining outside these areas for years on end with their crew using other ships to dock with it to collect caught fish and refuel/restock. Secondly, many Pacific Island States, are not be sufficiently resourced to regulate foreign owned shipping vessels on issues around labour, nor is fair to expect them to do so.
The reality is that certain richer nation States, and New Zealand is a good example, can find ways to enforce standards in their own EEZs (NZ require all foreign fishing vessels to re-flag to NZ and require the fishing vessel to dock in NZ), but even then this does not extend NZ jurisdiction to areas beyond national jurisdiction.
As in many other aspects of fisheries and indeed in all situations that present a complex problem, there is no “silver bullet” that will solve the problem.
Only the coordinated collaboration arising from state, industry and civil society working towards a common goal can have a positive impact in this problem.
While all of the above initiatives discussed above represent steps in the right direction, more must be done in this area to achieve a full international consensus and change to improve the rights of workers on fishing vessels. This includes, but is not limited to:
Maintaining pressure at UN body levels in relation to this issue - i.e. there is international consensus against the transportation of slaves, why not for forced labour and human rights abuses aboard fishing vessels? Is there a minor amendment that could be made to LOSC?
Other States should follow the Taiwan example, sign up to and implement C-188 into domestic legislation
Continued collaboration between flag flag, port and coastal States supported by regional organisms and CSOs
Continued good work at the RFMO level - to follow the leadership of the FFA and the WCPFC to make compliance with labour standards (C-188) a CMM measure - this also links with better fisheries management
Incorporating minimum labour conditions (MLCs) on Licence Conditions, or as in the case of the FFA members, agree to MLCs (based on C-188) to be added to the Regionally-harmonized Minimum Terms and Conditions (MTCs) for access by fishing vessels
Blacklisting vessels, agents and skippers/masters found to be associated with labour abuses
Industry voluntary adoption of minimum labour conditions consistent with at least C-188 (MLCs) as part of their verifiable standards
Of course, this list is not exhaustive, but for change to happen collaboration is essential, and at an international level, forced/slave labour and human rights abuses should no longer be tolerated as part of the international law framework.