H.E. António Guterres
Secretary-General
United Nations
New York, NY 10017
USA

13 August 2019

Dear Mr Secretary-General

I am pleased to confirm that New Zealand King Salmon reaffirms its support of the ten principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

As this is our first annual Communication on Progress, our accompanying documents have described our actions to integrate the Global Compact and its principles into our business strategy, culture and daily operations.

We are also committed to sharing this information with our stakeholders, using our primary channels of communication.

Yours sincerely

Grant Rosewarne
CEO & Managing Director
New Zealand King Salmon

NZKS CEO Grant Rosewarne has signed a statement of support for the ten principles of the United Nations Global Compact in the area of Human Rights and, Labour, Environment and Anti-corruption.
NZKS also provides an employee code of conduct that covers areas such as fair and open selection and provision of good and safe working conditions, including freedom from harassment or discrimination.
NZKS are committed to supporting social responsibility through voluntary engaging with The Best Aquaculture Practices. BAP is the world’s most trusted, comprehensive and proven third-party aquaculture certification program. BAP has continuously supported the improvement of the environmental, social and economic performance of the aquaculture supply chain and growing the global supply of responsibly farmed seafood. NZKS are 4 star BAP-certified which incorporates Feed, Hatchery, Sea Farm and Processing. The standard also ensures compliance with the International Labour Organisation (ILO) minimum age convention.
Our Goals are to introduce a supplier code of conduct that requires suppliers to adhere to the Global Compact principles on human rights and NZKS code of conduct. We want to maintain our BAP 4 star certification and aim to achieve Aquaculture Stewardship Council (ASC) certification on one of our salmon farms. ASC uses the ISEAL Code of practice for assessing the impacts of Social and Environmental activities through rigorous monitoring and evaluation.

NZKS aims to maintain 4 star BAP status which incorporates several human rights criteria. We also have a goal to be ASC certified by 2020 which has additional social responsibility criteria. We are working to implement a supplier code of conduct to encourage suppliers to support the United Nations Global Compact in the area of human rights.
Several NZKS company policies are under review to incorporate relevant up-to-date terminology to support human rights and the development of new training on discrimination etc.

NZKS focuses on the retention of the BAP voluntary certification standard that audit our social and environmental activities to global standards. NZKS reports annually to the Global Salmon Initiative (GSI) with independently verified information. NZKS also presents a comprehensive annual report on company performance to shareholders and the community.

https://www.kingsalmon.co.nz/kingsalmon/wp-content/uploads/2018/10/NKS23278-Annual-Report-2018-03.10.18.pdf

New Zealand Bill of Rights Act 1990 states everyone has the right to freedom of association. All New Zealand King Salmon staff have the right to freedom of association and collective bargaining. Through our BAP certification, NZKS is audited across several labour criteria in the BAP certification process and NZKS are certified compliant. Examples of areas covered in the BAP are minimum wage, zero use of child labour, working week mandate, compliance with local laws, etc.
NZKS has a goal to introduce a supplier code of conduct that requires suppliers to adhere to the UN Global Compact principles on human rights and reference human rights in the company code of conduct.
NZKS also has clear and fair recruitment policies and processes in place that are managed by the Human Resource department.

NZKS has a dedicated Human Resource department that develops and manages labour-related policies and procedures. All NKZS team members have a contract, stating hours of work, meals and breaks, work location, remuneration, holidays and leave agreements to comply with local and national laws.
NZKS has several policies in place, including a Remuneration Guide, Flexible Work Guide, and Code of Conduct. These guidelines are in line with Employment New Zealand.

NZKS is committed to supporting a diverse workforce in terms of race, age, and gender and our membership of the Employee Assistance Program continues to ensure relevant support and advice is available to every team member. All our team members are earning at or over the current living wage in New Zealand.
In the NZKS Annual Report, 2018 pg.98 Corporate Governance refers to the code of ethical behavior which the Board and all employees are signed up to. The code of ethics sets out a framework of ethical standards which cover several areas of the business, including compliance with laws and policies.

The company has recently completed its first Life Cycle Analysis (LCA) addressing its carbon footprint and is currently reviewing the outcomes from the document. The company full endorses and complies with the fundamental principle of precaution within the Resource Management Act 1991. The RMA is the primary legislation for management of the environment in NZ.”

NZKS is a signatory to the Sustainable Ocean Business Platform and endorses the United Nations Global Compact’s Sustainable Ocean Principles.
The company will continue to monitor and measure environmental activity across hatcheries and farms to meet consent and voluntary standard requirements.
NZKS will be implementing a number of changes across its farming practices to align with Global Best Practices in salmon farming. This will include implementation of single year class and introduction of a farm fallowing period.
NZKS is in the process of developing a supplier code of conduct with the intention to include requirements for suppliers to recognise and adhere to the UN Global Compact principles on the Environment.

Every hatchery and farm operate under stringent consent criteria which includes yearly reporting across several environmental performance indicators. NZKS engages a recognised science provider to complete annual monitoring summaries for each of our farms to monitor our environmental performance. Reports are submitted to the local council in line with consent requirements.
The 2014 ‘Best management practices (BMP) guidelines for Salmon Farms in the Marlborough Sounds-Benthic’ have already been incorporated at several of our farm sites. A review of the benthic standards was carried out in 2018 to ensure they are aligned with the latest knowledge.
BMP water column guidelines produced in cooperation with central and local government, independent science providers, industry and community representation has been completed and will be formalised by central government shortly.
Fresh water and sea water teams are trained in a number of areas to monitor and protect the environment which includes continuous environmental monitoring and handling of marine mammals and birds.
NZKS has signed up to the Ellen Macarthur Foundation’s New Plastics Economy. To meet this commitment the team has completed a packaging matrix, set internal targets for reducing, reusing and recycling packaging and completed a waste audit.
NZKS has also introduced a number of initiatives to reduce the use of fossil fuel. This will be discussed further in the 2019 Annual Report.

Each hatchery and farm operate under stringent consent criteria and includes yearly reporting across several environmental performance indicators. NZKS engages a recognised science provider to complete annual monitoring summaries for each of our farms to monitor our environmental performance. Reports are submitted to Marlborough District Council in line with consent requirements for annual review.
If an incident occurs, it would be reported to the correct monitoring body identified in the consent requirements.
NZKS environmental performance is audited by the Ministry of Primary Industry (MPI) in areas of biosecurity and under the Global Salmon Institute (GSI) and the Best Aquaculture Practices (BAP). We also have a goal to have a farm ASC certified which will also require further extensive auditing of our technical and social practices.

The board is legally responsible for the affairs and activities of the company.
The Board Charter (Charter) sets out the role, responsibilities, composition, structure and approach of the board.
NZKS has a Corporate Governance code which covers our approach to anti-corruption.
NZKS has not been involved in any legal cases, rulings or other events related to corruption and bribery over the COP reporting period.
Each year NZKS publicly reports its financial statements which are third party externally reviewed and publicly available through the Annual Report.
The Company code of conduct addresses bribery and dishonest and any behaviors that may bring the company into disrepute.

The Charter provides guidance for the effective oversight of the company by the board on behalf of its shareholders, employees, and other stakeholders.
The primary function of the company’s audit and finance committee is to assist the board in fulfilling its oversight responsibilities relating to the company.
To oversee the financial reporting and continuous disclosure processes to ensure that the interests of the shareholder are properly protected in relation to financial reporting and internal control and disclosure maintains integrity, transparency, and adequacy.

The audit and finance committee is responsible for the oversight of the company’s external audit arrangements to safeguard the integrity of financial reporting.
The company maintains an External Auditor Independence Policy to ensure that audit independence is maintained.
In terms of sales activity we abide by NZ competition law to ensure firms act ethically towards each other and consumers.

Ref
NZKS Policies - Code of Conduct
New Zealand King Salmon Investments Limited Corporate Governance Code

The company’s website includes a range of information relevant to shareholder and others concerning the operation of the company, including information about the sites we operate, aquaculture Best Management Practices (BMP), certifications, our brands and the corporate governance policies of the company.
Ref
New Zealand King Salmon Annual Report 2018
New Zealand King Salmon External Auditor Independence Policy pg. 47 of AR 2018
NZKS on NZX