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MWBRANDS SUSTAINABILITY GROUP POLICY

As a responsible, leading company within the canned fish industry in Europe, MW Brands takes its responsibility to the marine environment extremely seriously. We understand the issues associated with fishing and that as a purchaser of fish products, our sourcing policy can have an impact on the marine ecosystem. We therefore work proactively with various specialists to ensure we continuously remain aware of any issues which arise over conservation and fish stocks. We work closely with the relevant management institutions and with our suppliers to ensure they are operating in a way which will help minimise the impact of our operations on the marine environment and contribute to more sustainable fisheries. An example of our commitment is being a founding member of the International Seafood Sustainability Foundation (ISSF).This is an internationally recognized global partnership that keeps conservation at the core of its mission and that brings together scientists, the industry and the environmental non-governmental organization community to achieve sustainable tuna fisheries. The ISSF undertake science-based initiatives for the long-term conservation and sustainable use of fish stocks, reducing by-catch and promoting ecosystem health.

Currently we sell tuna (skipjack, yellowfin, albacore and bigeye), salmon, mackerel, sardine, hake, herrings, brisling, anchovies and shellfish. MWBrands has never been and will never be in the bluefin tuna business. We consider it vitally important to address sustainability in all aspects of our sourcing and selling of fish. We achieve this through our fully integrated food chain. The following set of principles guide our sourcing of wild caught fish and we are independently audited against them to ensure that they are reflected in our procedures and have been complied with.

International compliance

We are committed to the United Nations Convention on the Law of the Sea (UNCLOS) and we fully support the RFMOs (1) espoused by it. We do not sell endangered or critically endangered species from the IUCN (2) Red List. Additionally, in making sourcing decisions we review other lists of unsustainable fish stocks and details of efforts made to ensure minimal impact on endangered or protected species as by-catch.

1. RFMO: Regional Fisheries Management Organisations
2. IUCN: International Union for Conservation of Nature

Fisheries management

We support actions to strengthen fisheries management objectives for the conservation and wise use of fish stocks and the conservation of their ecosystems, and actively seek to source fish from well-managed fisheries. In doing so we promote the use of best practice and take the initiative on actions recommended by the ISSF, by RFMO's, and by the competent qualified scientific authorities, working with our suppliers to achieve their implementation in a timely manner. We also support efforts to protect important spawning and nursing grounds and to rehabilitate critical habitats. Specifically, we understand the role of spatio-temporal Marine Reserves as a management tool and proactively work to implement them whenever recommended by RFMOs and science. We will not source fish from areas that RFMOs and/or best available scientific information has indicated need protection.

Through the ISSF we support the application of sound science and the precautionary approach to underpin the management of fish stocks and action to eliminate Illegal, Unreported and Unregulated (IUU) fishing. In this, we collaborate with RFMOs on tagging programmes and information sharing to strengthen scientific advice in the management of fisheries. For example, we provide RFMO's with details of our tuna purchases in order to allow them to perform cross checks against other sources. This improves information and management. As an example, the Portuguese sardine fishermen associations, from where MWBrands sources its sardines, implemented in 1998 a protective fishing ban of 6 weeks per annum, during the reproduction period for ensuring sustainability of the species. Support for such positive best practice, which became the letter of the law in 2009, assured good stock management during the last decade and has guided our procurement decisions.

Stock status

We source from stocks where catches are limited to a level to maintain high stock productivity and good health of the wider ecosystem. We support management that ensures fishing capacity is commensurate with the productivity of the fishery. For example, all the mackerel used in our canned products is sourced from the North East and West Atlantic, caught either by purse-seining, hand line or trawlers, where quotas are tightly controlled in each case. Similarly, all the salmon used in our canned products is sourced from the USA and Canada where methods of sustainable fishing are tightly controlled by the governments in each country. Where a supply cannot currently be sourced from a fishery that meets our requirements, we will either not purchase the fish, or we will work with the relevant management body to ensure that they improve to our standards.

Ecosystem impacts

We recognise that fishing can have impacts on the marine environment, including on non-target species. We, as a company that purchases fish products, recognise that these issues are connected to our industry. Therefore, where they are identified by best available science we work proactively with the ISSF and our suppliers to ensure that the ecosystem impacts of fishing are minimised through implementation of 'best practices' to reduce bycatch, including no-take zones where appropriate, and we encourage others to do so. In doing so, we accept advice from the ISSF, RFMOs and the relevant scientific authorities. For example, as a result of their negative ecosystem impact, we do not currently source fish caught by long-line fishing methods or by drift-nets.

We also do not buy fish from fishing vessels that do not ban the practice of shark-finning. Additionally, all the tuna we sell is caught by either purse seining (primarily from the Atlantic and Indian Oceans, with a small amount coming from the Western Pacific Ocean), or pole and line (in the Atlantic). All our activities are monitored by the Earth Island Institute (Ell), ensuring that all the tuna in our canneries is dolphin safe.

Fishing operations

We work closely with our suppliers to ensure that fishing operations comply with national and international laws and agreements and with the stock management and fishing methods covered by the appropriate RFMOs. We are always proactive in seeking information and technical advice from qualified scientific authorities and engaging with concerned NGOs.

We actively encourage fishing operations that minimise by-catch and the risks of 'ghost fishing' and we meet annually with our suppliers to discuss progress in this. All the mackerel used in our canned products is sourced from the North East and West Atlantic, caught either by purse-seining, hand line or trawlers, the sardines processed in our factory are caught in the Atlantic (mainly Portugal) using small seines and quotas are tightly controlled by the governments of each country. For tuna suppliers, we actively promote the presence of on-board observers to confirm implementation of best practices to reduce by-catch and juvenile catch.

We take the issue of Illegal, Unreported and Unregulated (IUU) fishing extremely seriously. We recognise the risks that IUU fishing can pose to the sustainability of fisheries and we do not buy fish from IUU vessels or fish that has been trans-shipped at sea. We review on a quarterly basis the official IUU lists published by RFMOs and we commit to be fully compliant with the new EU regulation on IUU N° CE/I005/2008. To reduce the risks, we do not source fish from fisheries where there is a high incidence of illegal fishing. Furthermore, we support the disqualification of the parent company once any boat has been proven by RFMOs and/or competent authorities to have been acting as an IUU fisher.

Catch to Consumer

In addition to supplying safe fish products of high quality and high nutritional value, MWBrands pursues full-chain traceability from catch to consumer and ensures that the entire supply chain conforms to our high standards. All MW Brands canned fish is traceable and all cans will display information on the species and fishing ground within 2010. We go beyond the mandatory sustainability, fishing and environmental requirements to offer a higher standard of sustainability and risk mitigation that we ensure is independently assessed. We work closely with our suppliers, governments, the EU, RFMO's and NGOs to maintain, improve and update on all environmental aspects of the food supply chain and have implemented initiatives to reduce environmental impacts, including C02, throughout the supply chain.

We encourage our suppliers to promote social aspects of fishing through adequate onboard conditions of fishers, and by supporting the sale of by-catch that is fit for human consumption to local populations. Moreover we process on site all the raw material we buy in this way generating a high level of permanent employment at our Seychelles and Ghana plants and contributing to coastal countries social development. We work with suppliers to ensure that the principles that underpin our sourcing policy are applied to improve the traceability of fisheries products back to their origin, strengthening buying procedures within the industry, For example, all our mackerel suppliers commit by contract to deliver mackerel that has been caught from sustainable sources implying:

• Legal fishing only by registered vessels
• Strict respect of the quotas allocated to each fishery
• Respect of non fishing areas (spawning areas for instance)
• Respect of fishing bans and moratoria (during reproduction for instance)
• Respect of minimum landing size
• No by-catch landings (vessels are equipped with escape tunnels / separation grids enabling potential by-catch species to escape).