December 1st, 2025

Reflections on a worker empowerment initiative in Scotland’s fishing sector

Working with Focus on Labour Exploitation on a WSR pilot project in the seafood industry has highlighted again the care and commitment genuine worker engagement requires.

Over the past 18 months, I worked with Focus on Labour Exploitation (FLEX) on an ambitious effort to support a Worker-Driven Social Responsibility (WSR) pilot in Scottish fishing. Our small outreach team set up in Aberdeenshire with a great sense of possibility: to help create a structure through which migrant fishers could safely raise concerns and advocate for their rights — a complete innovation in this context, and a bold attempt to shift power.
The pilot has now come to an end (see this announcement by FLEX and International Transport Workers Federation (ITF)). There are many reasons for this ending, which I will not all cover here – the partner organisations are continuing their analysis work. For now, my reflection is through the lens of supply chain due diligence. But it would be impossible to write about this experience without honouring the human side — my team, the local people we met, the realities they shared, and the communities that welcomed us.

(For background, here you can revisit the WSR principles and the pilot concept)

Understanding the risk context

We were working in a known high-risk environment. UK retailers and brands have, for years, acknowledged serious concerns around migrant fishers’ working conditions and have made varying commitments to addressing these risks. Yet as we began building a programme with and for fishers, several structural barriers became clear:

• Gaps in meaningful engagement
Some companies were not yet ready to engage directly and openly with organisations representing or supporting workers. This limited our ability to learn about industry realities and further develop the pilot idea. It also limited the sector’s ability to explore worker-driven approaches to address problems that cannot be managed in isolation.

• Fragmented supply chains
The seafood sourcing landscape is dispersed, fluid and commercially very complex. Retailers often have limited control over where exactly their fish comes from - which in itself contributes to risk.
A figure that still strikes is that around 80% of UK-landed seafood is exported, while the UK imports over 1.1 million tonnes from around the globe, worth about £3.4 billion. Without clear visibility and defined leverage points, even well-intentioned companies struggle to influence upstream working conditions.

• Weak or inaccessible worker representation
Apart from not being unionised, many migrant fishers in the UK are isolated on vessels where shore access is irregular, restricted, or risky, depending on immigration status. Traditional, industry-led worker voice mechanisms simply don’t work for a majority of these people. Again, in HRDD terms, this lack of community and representation is a risk factor in itself.
We know these dynamics are not unique to Scotland; they reflect broader challenges across labour-intensive sectors in which global mobility, immigration regimes and commercial pressures intersect.

Thoughts on our responsible exit

One of the most difficult parts of this project has been navigating its end. When place-based initiatives generate expectations – amongst local stakeholders, community members, and outreach staff – I believe those involved carry a responsibility to avoid harm when we step away.
The team at FLEX and the people we met had placed cautious hope in the idea of a pilot. Our outreach workers invested time and built relationships in communities who rarely receive sustained attention. Even though we were not in a position to commence formal, structured outreach at vessel level, ending something like this can leave a vacuum.
For me, this raised important questions about responsible endings in localised HRDD work:

• How do we close a chapter without abandoning communities and disappointing trust? What can we leave behind?
• How do we communicate endings with care?
• How do we ensure that insights aren’t lost but can serve other people and future work?

These have been uncomfortable reflections, but essential ones. Ending a process well allows space for new things to emerge.

Insights to build on

Part of ending well, ti us is seeing how our experience can be helpful. How can we make our learnings accessible to those working towards a similar purpose – in this specific context or for migrant worker communities elsewhere?
Since the project has been multifaceted and the learnings rich, we’ll be sharing inisghts in various ways. For FLEX and for ITF, the commitment to learning and systemic change continues. FLEX is planning a series of reports and will discuss insights within their networks. Both organisations will continue advocacy for migrant fishers and explore worker-driven models.

On my side, I hope these reflections here contribute to ongoing discussions in the HRDD community – within and beyond seafood.
Unsurprisingly, the themes below are not new. Some may even be tired of reading advice on “what makes meaningful HRDD.” And yet, I want to reaffirm our work in Aberdeenshire fishing towns mirrors key principles we as business & human rights professionals keep holding up.

These things do matter:

• Engagement must be collaborative and grounded in dialogue**
Impactful solutions require buyers, worker organisations, and civil society groups to meet at eye level — to meet as humans — even when interests and language differ. Progress is rarely immediate, and it requires time and an openness to the result (from both sides). A carefully facilitated process can build understanding. Companies can apply this understanding across other geographies and supply chains too.
(The STITCH framework I find one of the most useful ones to describe requirements in more detail.)

• Good HRDD requires a proactive mindset
Waiting for confirmed cases clearly linked to one’s “own supply chain” is no longer adequate. (It never was.) In sectors with limited oversight and known structural risks, companies should anticipate patterns and think strategically about their responsibility, rather than react only to incidents.

• Who are we talking about? Who are we talking to? – Mapping representatives
In the fishing context, many workers lack access to community networks or trusted support structures. On vessels with five or six crew with different experience levels and from multiple nationalities — some of whom cannot legally step onto UK soil — questions of representation are not straightforward. There is no simple “worker voice solution.” Mapping legitimate representatives and understanding gaps (which will always exist, and it’s normal) is foundational to meaningful engagement.

• Commercial structures shape responsibility
As sketched above, the nature of seafood sourcing — global, fast-moving, and often indirect — influences what companies can realistically control. But it doesn’t remove responsibility. A clearer understanding of buyer leverage, market relationships and the limits of visibility is central to designing effective HRDD measures.
When transparency is limited and the chain of responsibility is diffuse, HRDD risks becoming symbolic, not truly targeted to rightsholders. Overcoming this takes courage: bringing commercial teams into conversations, acknowledging constraints, and taking incremental steps toward better governance.

(There is, of course, also a much bigger piece about systemic rethinking of what the UK seafood market as a whole promotes and rewards, which I won’t go further into here.)

Looking Ahead

FLEX, ITF and others in the WSR space will continue to build on this experience — including their work on visa reform, recruitment pathways, and the conditions that enable worker-driven models. Here, our fishing project offers important reflection points around the maturity of workers’ communities, buyer leverage, and the nature of incentives for companies etc.
For me, the experience reinforced lessons that seem to apply across local due diligence interventions: worker engagement must be locally grounded, attuned to the communities it’s meant to empower, and structurally supported. Anything less risks reinforcing the very problems HRDD is there to address.