©Negocios Industriales Real NIRSA

At NIRSA we depend on healthy seas for a healthy business – they are inseparable. As a leading player in the Pacific fishing industry, NIRSA is fully committed not just to playing its part, but demonstrating leadership on environmental issues in an effort to move the harvesting of Pacific tuna and other species onto a long-term sustainable footing. In partnership with our customers, suppliers, employees and key stakeholders, we aim to develop policies and practices that move beyond compliance with existing fisheries management frameworks and legislation. Our aim is simple: to place responsible businesses practices at the centre of all our commercial activities.

On our vessels, in our factories, from our corporate headquarters in Ecuador to the many countries in which we trade around the world, our plan is to become a true and recognized champion of sustainable development.

As catchers and processors of quality seafood, our business inevitably has a number of environmental impacts. Of primary concern is the effect of our operations on marine sustainability, and the fish stocks from which we draw our harvest. As we embark on an ever more ambitious approach to sustainability, our focus must inevitably be on ensuring responsible fishing practices.

We recognize that the exploitation of Pacific tuna stocks in particular has raised a number of issues. Many of these can only be solved by collective action; by governments, fishing management authorities, NGOs and the many companies involved in Pacific fisheries. We readily acknowledge that in the past NIRSA itself has not played as active a role in ensuring responsible fishing practices as stakeholders might have expected. For this reason, we are launching an ambitious sustainability programme to adapt to a new era where responsibility is no longer optional, but essential. We recognize that making the required improvements to our environmental management systems will be a long and difficult process. But we are fully committed to meeting the challenge, and we will be transparent and open with all our stakeholders about our progress in the months and years ahead.

NIRSA is firmly committed to leadership on environmental issues and has thus developed an ambitious environmental sustainability policy whose primary focus at its first stage is the sustainability of tuna fish stocks. NIRSA is committed to the following sustainability actions:

Developing long-term collaborative links with scientists.

So that commercial fishermen’s knowledge on the fishery and fishes are combined with scientific knowledge and used to address issues of common concern. In that regard, NIRSA has established a “tuna working group” with the objective of addressing conservation and management issues related to FADs (fish aggregating devices) from a new perspective: associating scientists and stakeholders such as skippers and fleet owners to address research and management issues. The aim will be to define the best FAD-fishing practices and appropriate management measures to be taken to ensure a sustainable fishery.

Reduction in number of FADs carried by vessels.

NIRSA will voluntarily impose a reduction of twenty percent in the number of FADs carried by its purse-seiners that fish for tunas. This target will be accomplished in a five-year period; thus, a yearly progressive reduction will be applied until 2014.
In this regard, a reduction of 4% in the number of FADs used by NIRSA’s vessels has been applied for the first year.

Preclude the deployment of FADs near the coast.

NIRSA voluntarily precludes its tuna fleet operating in the eastern tropical Pacific from deploying FADs within 40 miles of the coast, where tuna juveniles tend to aggregate.

Commitment to making fishing technology more sustainable in the long term.

In that regard, NIRSA has designed a juvenile excluder device which allows young tuna to escape harvesting (Arrue's grid), and has pioneered the use of it on its vessels. NIRSA’s initiative has also been extended to all tuna vessels >363 t of carrying capacity operating under the Ecuadorian flag.

NIRSA will continue exploring the feasibility of modifying its purse seine nets or fishing methods in order to increase juvenile escapement and minimize the catch of non-target species.

Preclude transshipment of tuna at sea and use of tender vessels.

In accordance with recommendations made by the Inter-American Tropical Tuna Commission (IATTC), NIRSA precludes the transshipment of tuna at sea, and the use of tender vessels operating in support of vessels fishing on FADs. The role of tender vessels is to deploy, repair, maintain and replace the FADs at sea.

Preclude the practice of fish discarding.

NIRSA is opposed to the wasteful practice of discarding, where healthy tuna are returned to the sea dead or dying. In this regard, NIRSA requires all its purse-seine vessels to first retain on board and then land all tuna caught, except fish considered unfit for human consumption for reasons other than size. A single exception may be the final set of a trip, when there may be insufficient well space remaining to accommodate all the tuna caught in that set.

Commitment to minimizing levels of accidental bycatch.

NIRSA is committed to minimizing levels of accidental bycatch of non-target species, and encourages the release, when practicable, of marine mammals, sea turtles and seabirds entangled in FADs and other fishing gear.
In this regard, NIRSA has planned for its vessel crews training programmes on how to minimize levels of accidental bycatch of non-target species, and how to treat incidentally-caught marine mammals, sea turtles and seabirds properly to improve their survivability, with the support of IATTC staff members and experts from other scientific institutions and non-governmental organizations (NGOs). All NIRSA’s vessel crews are required to attend these training programmes.

Accordingly, a workshop for captains and crews of NIRSA’s vessels on the bycatch in the tuna fisheries took place at NIRSA’s plant in Posorja in April 2010. This workshop was conducted by Dr. Martin Hall from the Inter-American Tropical Tuna Commission (IATTC) and funded by the International Seafood Sustainability Foundation (ISSF). The discussions were focused on the bycatch in the tuna fishing on FADs, bycatch composition, discarding of small tunas, technological and operational solutions to mitigate the bycatches of small tunas, sharks, marine turtles and of pelagic bony fishes, effects of sorting grids, what kind of research is needed and the role fishermen play in the search for technological solutions.

Moratorium on growth of tuna fishing fleet.

NIRSA maintains a moratorium on the growth of its tuna fishing fleet. In compliance with IATTC regulations, which state a moratorium on the growth of the tuna fishing fleet operating in the eastern tropical Pacific, NIRSA’s fleet has long remained at its current size. These regulations also state that any acquisition of new vessels will be considered only to replace those lost through sinking or attrition due to old age, in which case the total capacity of the replacement vessel would not exceed that of the vessel or vessels replaced.

Addressing conservation and management issues.

Making captains and crews from NIRSA’s vessels fully aware of what sustainable fishing is all about, including the vital role they play in achieving sustainable fisheries, is of paramount importance for NIRSA. In that regard, seminars are given to captains and crews of NIRSA’s tuna fishing vessels on the importance of sustainable fishing practices and ecosystem conservation, and the need to avoid all illegal, unregulated and unreported (IUU) fishing, report infractions and comply with all sustainability measures in effect in the eastern tropical Pacific tuna fishery. The first seminars took place at NIRSA’s plant in Posorja in February 2010. These seminars are repeated every time a vessel is in port, so that crews from all vessels have the opportunity to attend one. A Certificate of Attendance is provided to all those who attend these seminars. Starting in 2011, NIRSA will require every crew member to have this certificate.
In line with the above objective, NIRSA has produced two posters about sustainable fishing and the need to combat IUU fishing to be displayed on the bridge and in the dining room of each vessel as well as in suitable places around NIRSA’s headquarters and processing plant.

Addressing IUU fishing.

NIRSA seeks to avoid all IUU fishing through the implementation of the following measures:

• Reporting vessels presumed to have carried out IUU fishing activities in the eastern tropical Pacific, in accordance with IATTC Resolutions and the FAO IPOA-IUU* criteria on this issue. In particular, NIRSA will report vessels engaged in any fishing activities which are in contravention of IATTC conservation and management measures, or are conducted in a manner inconsistent with the conservation of living marine resources under international law.
*FAO IPOA-IUU - International Plan of Action to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated fishing, Food and Agriculture Organization of the United Nations.
• Equipping all its vessels with satellite-based Vessel Monitoring Systems (VMS). In this regard, all NIRSA’s tuna vessels are equipped with VMS, which allow for constant monitoring of the location of NIRSA’s fleet, and are very helpful in supporting IATTC’s conservation and management programs, including compliance. A double watch is kept on the position of each vessel by NIRSA itself and by national authorities.
• Not being engaged in commercial transactions with vessels included in any Regional Fishery Management Organization (RFMO) IUU vessel list. According to this, NIRSA does not purchase seafood from any company or vessel which appears on any RFMO or Greenpeace IUU blacklist.
• Carrying observers on board. Currently, all NIRSA’s tuna vessels >363 t of carrying capacity carry an observer on board in every fishing trip, in compliance with the IATTC observer programme.

NIRSA also recognizes the importance of addressing IUU fishing to improving conservation and management of tuna stocks in the western and central Pacific Ocean. This includes ensuring compliance with closed areas/marine reserves established to curb pirate fishing and to protect the region's tuna stocks.

Minimizing pollution.

NIRSA is committed to minimizing pollution by:

• Minimizing offal and waste effluent into the sea. In this regard, NIRSA’s vessels are all equipped with either a sewage treatment plant or a sewage retention tank where sewage is chemically treated before being discharged into the sea. Also, NIRSA’s vessels have an oily water separator installed to clean bilge water before discharge in accordance with regulations issued by the MARPOL Protocol. All inorganic garbage, including any type of plastic trash, and used oil are retained on board and unloaded in port;

• Prohibiting its tuna fishing vessels from disposing of salt bags at sea. In this regard, all used salt bags are retained on board and measured before unloaded in port. A record of the used salt bags returned by each vessel is kept;

• Fostering the recovery of FADs when they are not being used in the fishery; and,

• Ensuring strict fuelling procedures as recommended by the responsible national authorities.

Support implementation of management measures on other fisheries.

In accordance with domestic fishing regulations, NIRSA has long precluded the use of whole thread herring for reduction to fish meal.
NIRSA has also supported a complete ban on the capture of thread herring off Ecuador during March and September of each year, and of Pacific anchovy during the period January to June to protect breeding activities.

Implementing traceability in the seafood chain.

Tracing seafood products from the ship that caught them to the supermarket shelf is essential not only for food safety, but also to ensure that the fish has been legally and sustainably caught. In that regard, NIRSA may demonstrate complete traceability of seafood products sourced from the company’s own fleet, from ocean to supermarket shelf. Traceability audits are performed at random by national authorities and customers.

Using policy advocacy to promote environmental sustainability.

NIRSA will be an active voice for sustainability policies in relevant government/fisheries management bodies and other relevant fora. As a significant force in the tuna sector we will seek to use our share of voice to advance environmental management improvements.
In this regard, NIRSA is committed to being actively engaged in dialogue with all relevant Government authorities to reach higher standards of sustainable fishing practices, including strict sanctions for illegal fishing. NIRSA will also be an active voice in spreading awareness about the need for a more sustainable long-term management scheme for the eastern tropical Pacific tuna fishery.

In February 2010 NIRSA became a member of the International Seafood Sustainability Foundation (ISSF), a global partnership among scientists, the tuna industry and the global conservation organization World Wildlife Fund (WWF), whose mission is to undertake science-based initiatives for the long-term conservation and sustainable use of tuna stocks. As such, NIRSA is committed to work with RFMOs to achieve their objectives of conservation of tuna stocks and their ecosystems, strive to eliminate all IUU tuna fishing, minimize bycatch and discards, and collect data to promote better scientific understanding of tuna stocks.

Striving for third-party certification.

NIRSA will pursue, where practical, relevant third-party sustainability certification for its fishing practices. In this respect, NIRSA will continue to comply with Earth Island Institute certification as a dolphin-safe tuna company.

Along the same line, it is worth mentioning the signature of a Memorandum of Understanding between the WWF, the National Fishing Chamber of Ecuador, the Ecuadorian Tuna Boat Owners Association (ATUNEC) and the Undersecretariat of Fisheries Resources of Ecuador for a Marine Stewardship Council (MSC) certification project for the Ecuadorian skipjack tuna purse seine fishery. In this regard, an MSC pre-assessment of the fishery is underway. As a leading player in the Ecuadorian fishing industry, NIRSA has played its part in making this project happen.

Deploying full transparency.

NIRSA will regularly review this policy and set measurable targets. We will deploy full transparency and regularly update on challenges and our progress. We will encourage the reporting and recording of all environmental events with potential to adversely affect our business.
In the event of any dispute about NIRSA’s fishing practices, we shall seek to respond rapidly and openly to any questions made by a third-party, be they a customer, fisheries management authority, government, NGO or other stakeholder.
Starting in 2010, an annual sustainability report on how NIRSA is meeting its responsible fishing commitments will be produced each year.

Assuring supply chain integrity.

NIRSA has begun its new sustainability strategy by focusing on its own wholly owned vessels. We shall require the above standards of all suppliers from whom we purchase seafood.

Overall, NIRSA supports ongoing and new research into the ecosystem impacts of fishing activities. The company supports the expansion of technological and policy instruments that have a major role to play in ensuring a sustainable future for the Pacific marine environment.

We strongly believe that NIRSA’s initiative can set an interesting precedent for formulating action plans to resolve the sustainability issues facing the tuna fishery in the eastern tropical Pacific.

We very much welcome feedback from customers, environmental stakeholders and other interested parties on the contents of this sustainability policy.