
Image Source: Pexels; https://www.pexels.com/photo/close-up-of-anchor-17485780/
By Carlye Goldman, Natalie Leonard, and Elizabeth Parker
This report outlines research gaps and best practices in recruitment oversight- drawing on case studies and interviews with civil society organizations (CSOs)- and explores how CSOs help fishers exercise their voice and agency, and how fishers with a stronger voice in their sector can protect both fishers’ rights and, potentially, the fisheries.
As part of All Hands on Deck: Protections for Fishers in the Seafood Industry—the fourth edition of a collaboration with the Accountability Research Center and the Fisheries Governance Project—this report examines the systemic challenges migrant and distant-water fishers face in the global seafood supply chain, including exploitative recruitment, poor working conditions, limited access to remedy, and weak rights enforcement. Drawing on case studies and interviews with civil society organizations (CSOs), it highlights best practices in recruitment oversight, how non-governmental organizations (NGOs) and unions are helping fishers exercise their agency, and how fishers with a stronger voice can protect fishers’ rights and, potentially, the fisheries. The research focuses on two areas: (First) effective grievance mechanisms and steps companies can take to ensure fair, accessible processes, and (Secondly) whether fishers can safely contribute to reporting Illegal, Unreported, and Unregulated (IUU) fishing.
List of Acronyms
| Acronym | Full Meaning |
| AIS | Automatic Identification System |
| ILO C188 | ILO Convention 188 (Work in Fishing Convention) |
| CSO | Civil Society Organization |
| DWF | Distant Water Fleet |
| ETF | European Transport Workers’ Federation |
| FAO | Food and Agriculture Organization of the United Nations |
| ILO | International Labour Organization |
| IUU | Illegal, Unreported, and Unregulated (fishing) |
| NGO | Non-Governmental Organization |
| SBMI | Serikat Buruh Migran Indonesia (Indonesian Migrant Workers’ Union) |
| UNGPs | UN Guiding Principles on Business and Human Rights |
| Wi-Fi | Wireless Fidelity (used in the context of onboard communication access) |
Recruitment: The Gateway for Fisher Exploitation
In the global seafood supply chain, recent efforts have prioritized increasing product traceability and transparency to ensure quality and sustainability. However, significant gaps remain in extending these measures to labor practices. Profit-incentivized cost-cutting within this industry encourages exploitative recruitment practices, jeopardizing worker safety and increasing risk of labor abuses.1 Despite the efforts of fisher rights advocates, corporate interests, and legislative efforts to increase transparency, many recruitment processes within the industrial seafood supply chain remain veiled, perpetuating the exploitation of a vulnerable workforce as migrant populations are targeted to crew fishing fleets.
While fisher unions fight for their members’ rights to collective bargaining and grievance remediation, their efforts are hindered by a lack of transparency surrounding vessel ownership and opacity within the fisher-to-vessel recruitment pipeline.2 The complexity of this pipeline underscores the need to coordinate among Civil Society Organizations (CSOs), not only across data-driven and union approaches, but also across borders. An analysis of corporate policies, however, found that few companies are grappling with the multiple layers described below.3
Figure 1: Seafood Labor Supply Chain4

Figure 2: Recruitment Pathway of a Migrant Fisher5, 6, 7

Graphic made by report authors.
From Freedom to Forced Labor: The Path of a Migrant Fisher from Recruitment to Entrapment
Figure 2 expands upon Figure 1, the seafood labor supply chain diagram from Gearhart (2023), which identified the need for customers to review the labor practices of both vessels and recruitment agencies.8 Further research revealed that there are often two recruitment agencies involved, one in the fisher’s home country (sending country), and one in the vessel’s home country (receiving country).9, 10, 11 While this diagram portrays the recruitment process up to when the fisher boards the vessel, it doesn’t capture the repatriation process (how the fisher returns home), a critical stage where many fishers face continued risks of exploitation and rights violations as they often struggle to secure compensation.12
Recruitment agencies often first reach prospective fishers through informal brokers who recruit young men within their local villages and receive a cut of the fisher’s recruitment fees as compensation.13 The Union of Indonesian Migrant Workers (Serikat Buruh Migran Indonesia, SBMI), the largest migrant worker organization in Indonesia—noted that since 2017, many of these recruitment agencies are also posting job vacancies on Facebook and WhatsApp groups to reach their workforce.14 Labor abuses begin in this early stage of recruitment, as fishers are lured by false promises and coerced into signing misleading or inaccurate contracts.
Once connected, fishers rely on the recruitment agency in their home country for services such as help securing immigration documents and transportation to the vessel (which may not be in the vessel’s flag state).15 Upon arrival in the port country, migrant fishers are transferred to a local recruitment agency, increasing the risk of incurring more fees. SBMI shared that recruitment fees can amount to $1,200 US dollars—a staggering sum for workers who may be paid $175 USD per month on the vessel.16 These fees are a root cause of forced labor, as workers often take out high-interest loans to pay them, creating enormous amounts of debt.17 Furthermore, fishers on distant-water fleets (DWF) are often contracted and paid by their recruitment agency, affording agencies the power to deduct fees and any additional expenses from fishers’ wages, trapping them in a cycle of debt bondage.
Recruitment is a critical entry point where migrant fishers often face the greatest vulnerability. Fishing vessel owners frequently rely on third-party recruitment agencies to staff their vessels, yet oversight of these agents remains weak and inconsistent.18 While international guidelines, like those outlined in the International Labour Organization’s (ILO) Convention 188 (C188) and ILO Convention 181 (C181), offer frameworks for ethical recruitment, they are not uniformly adopted or enforced. Fishing companies are encouraged to screen agencies rigorously to prevent exploitation, selecting those that refrain from recruitment fees, provide contracts (written in a language the fisher understands) in advance, and adhere to document retention policies that comply with national laws.19 Nonetheless, many fishers report having their passports confiscated, being misled about wages, or unknowingly signing contracts they cannot read.20 The lack of standard legal safeguards, particularly in jurisdictions where recruitment agents operate with minimal or lax regulation, creates a breeding ground for abuse.
Non-binding practical documents that fishing companies are encouraged to use (e.g., toolkits, checklists) recommend detailed self-assessments before hiring, such as defining required qualifications, verifying agent accreditation, and checking for grievance mechanisms that are accessible to migrant workers.21 Yet, gaps persist, especially for illiterate or non-native language speakers who may need legal interpretation or support services. Without proper onboarding, orientation, and legal protections, fishers are often deployed under exploitative arrangements without recourse. Tools like model employment contracts, secure document storage, and transparent repatriation procedures exist on paper but are rarely implemented at scale.22 True recruitment reform requires stronger compliance enforcement by flag states, formal mechanisms for worker complaints, and solutions that center the fisher’s experience from the outset.
When the Gateway Becomes a Gatekeeper: Rights Denial and Worker Voice Suppression
These recruitment practices impede fishers’ ability to exercise their voice and rights to bargain collectively, access effective grievance mechanisms, and secure remedy. As fishers on the DWF are often contracted by the recruitment agency in their home country, and not the vessel owners directly, they are unable to bargain collectively with the captain or vessel owners for better working conditions.23 Because they often work on vessels flagged to countries other than their own, tracing and holding abusive parties accountable is difficult.24 This situation complicates the ability of fishers and unions to file for and secure remedy, especially as recruitment agencies and vessel owners often try to avoid commitments to remedy grievances. SBMI confirmed this reality, sharing that even when they contact and ask recruitment agencies to remedy fisher grievances—as required by Indonesian Law 18/2017—these agencies are unlikely to respond. 25
Furthermore, in cases where migrant fishers’ visas are tied to their employment, such as in Taiwan, fishers are often discouraged from transferring vessels, no matter the working conditions, for fear of deportation if their contract is terminated.26 These conditions deter fishers from speaking out about poor working environments, knowing that voicing a complaint could result in their contract’s termination and deportation upon arrival at port. If sent back to their home country, they would need to completely restart the costly recruitment process if they wished to work as fishers again.
CSO Strategies for Recruitment Reform
On both the international and domestic fronts, CSOs have a major role to play in reforming exploitative recruitment practices within the global seafood supply chain. CSOs, including trade unions, membership-based organizations, and NGOs, advance workers’ rights by strengthening community action and worker agency. Membership-based CSOs employ a “whole-of-worker” approach, using strategies to prevent abuses, secure remedy, and support overall well-being through fostering community.27 Unions and worker organizations are key to progress, providing critical support to fishers by upholding their rights to collective bargaining and making grievance mechanisms accessible. They also monitor labor abuse reporting, fight to secure remedy, and hold governments and employers accountable.28 These CSOs are thus essential for worker empowerment, which catalyzes meaningful, sustainable change.
The Union of Indonesian Migrant Workers (SBMI) indicated that their work goes beyond advocacy. It includes supporting grassroots fisher organizing and educating migrant fishers on their rights at all stages of the employment process from recruitment to work overseas.29 They also offer training for migrant fishers on how to address a violation of their rights on the vessel and where to go if they aren’t receiving their funds from the recruitment agency. Migrant fishers who have benefited from this sort of training enter the field with a greater understanding of their rights and are able to engage their recruitment agencies directly, asking questions to clarify terms within their employment contracts, payment mechanisms, and insurance.30
Many NGOs serve as partners to fisher organizers by developing campaigns centered around the goals and concerns of fisher organizations. However, Gearhart and Moynihan argue that because fisher-led solutions are key to sustained change, CSO efforts must focus on supporting national fisher unions’ efforts to build their power and strengthen fishers’ collective voice.31
Worker Voice
International labor standards are built upon the foundational principle that workers should have the right to organize, voice demands, and negotiate for improved working conditions. The International Labour Organization’s Declaration on Fundamental Principles and Rights at Work (ILO 1998) defines these respective freedoms—of association, organization, and collective bargaining—as “basic workers’ rights.”32 Scholars define this ability of workers to express their concerns and exercise collective agency to improve the terms and conditions of their work as “worker voice.” 33
Several advocates for decent work have expressed concern about the overuse or misuse of the term “worker voice.”34 Across sectors, it has been used to refer to the tools and systems through which workers can express concerns and offer feedback within their supply chains. But these tools are diverse, varying in use and effectiveness. They range from suggestion boxes, worker hotlines, employee surveys, and corporate responsibility efforts, to labor unions, collective bargaining agreements, and enforceable brand agreements.35 While the term has been used by practitioners, policymakers, and scholars to refer generally to any form of worker participation, effective worker voice mechanisms must be identified.
What Are Effective Worker-Voice Mechanisms?
According to Anner and colleagues, worker voice is “the capacity of workers to speak up, articulate, and manifest collective agency to improve the terms and conditions of work and livelihoods and to contribute to more equitable and democratic societies”.36 Mechanisms that most effectively enable worker voice are those that “enhance workers’ ability to elect, represent, protect, include, enable, and empower workers and their organizations,” such as democratic trade unions and collective bargaining.37 Within the global seafood supply chain, however, these tools are not always available to workers.
In the fishing industry’s private sector, there is a growing trend to adopt voluntary, market-driven governance mechanisms to address labor conditions in the seafood supply chain.38 These tools—including ethical standards, labeling systems, certification schemes, and codes of conduct—evaluate performance through social auditing strategies. However, these mechanisms have proven ineffective at transforming working conditions.39 Tools such as audit surveys and complaint mechanisms may appear to be participatory by claiming to ‘enable worker voice,’ yet, they fail to serve workers’ needs. Workers rarely use them effectively, hindered by limited knowledge, lack of trust, and businesses’ dominant control over defining and resolving labor issues.40 These tools treat workers as passive, excluding the people they are intended to protect.41
Individual vs. Collective Voice Mechanisms
Most effective forms of worker voice mechanisms promote collective, democratic representation, where workers are actively engaged, informed, and empowered. Individual voice mechanisms, like suggestion boxes and digital surveys, don’t carry the same power or credibility as collective voice mechanisms. Individual voice mechanisms are often ineffective at resolving workplace conflicts, especially those related to workers’ rights.42 Individual voice mechanisms, like hotlines, are only effective when paired with collective voice mechanisms, such as democratic trade unions.43 Most individual voice mechanisms exclude workers from participating in conflict resolution processes and deny access to effective remedy.44 Genuine mechanisms must both “capture the voices, experiences, and needs of workers,” and “channel that voice into a clear mechanism for remediation for those workers.”45 Improving working conditions requires incorporating workers’ input at every stage of employment—from recruitment to repatriation—shifting from a ‘worker-centered’ to a ‘worker-driven’ model.46, 47 This transition to a “worker-driven social responsibility paradigm” is critical to redistributing power and prioritizing worker agency within the seafood industry, thereby helping to protect fishers from exploitation.48
CSOs and Worker Voice
Both the dangers of marginalizing worker voice and the importance of CSO support to amplify collective voice within global supply chains are exemplified in the 2013 Rana Plaza factory collapse in Bangladesh, killing more than 1,100 people.49 Workers had limited union leverage to compel management before the tragedy.50 In countries with the protected right of freedom of association, unions can help prevent disasters like this.51 Within the fishing industry, CSOs’ support for and promotion of collective voice is pivotal to fishers exercising their power. The Global Seafood Alliance’s 2020 report, Worker Voice on Fishing Vessels, highlights the massive power imbalance on fishing vessels and the need for safe, trusted support onboard and onshore.52
CSOs promote collective voice through varied strategies, including employer engagement, advocacy, campaigning, grassroots organizing, and movement building. These efforts can be represented on a continuum, from fisher-absent NGOs that engage decision-makers with limited fisher involvement, to fully fisher-led advocacy groups. Understanding this spectrum of fisher-involvement within CSO strategies helps contextualize the breadth of contributions to advancing fishers’ rights.
The CSOs examined in this report represent this spectrum of engagement with fishers. At one end, organizations such as C4ADS and Conservation International operate without much direct involvement with fishers, focusing on data-driven investigations, collaboration with private and public sector actors, and policy advocacy.53, 54 Mid-spectrum organizations like the Issara Institute and Greenpeace blend corporate engagement and public mobilization to influence labor practices within supply chains.55, 56 At the grassroots end of the spectrum, Stella Maris and SBMI exemplify fisher-led operations, supporting collective voice and building collective power through worker organizing and rights education.57, 58
While each kind of CSO along this spectrum plays a distinct and valuable role, not all engage directly with fishers.59 The strength of some CSOs closer to the fisher-absent end of the spectrum lies in their ability to contribute information or apply pressure that can help secure remedy for workers.60 Their technical experience and legal expertise, combined with external funding, allow them to help workers file complaints, escape debt bondage, and seek compensation for workplace abuses or injuries.61 However, the impact of CSO efforts may remain narrow and short-term if they are not integrated with the work of fisher-led organizations, including trade unions and membership-based groups, that focus on sustained, long-term organizing. It’s the movement building strategies that can cultivate collective voice, thereby advancing structural and more sustainable change.62
The literature reviewed suggests that systemic reform in the global seafood supply chain requires prioritizing collective fisher voice, strengthening organizing rights, and shifting power to fishers themselves. Recently, there has been an uptick in fisher organizing, with many trade unions emerging in the sector.63 Still, challenges remain as many migrant fishers have never been organized and unions struggle to secure membership, dues, and participation.64 Despite obstacles, supporting this work enables fishers to claim power through collective, trusted efforts that foster negotiation, remedy, and broader change. Collective voice is the backbone of sustainable, democratic movement building. When workers are engaged in a trusted, collective effort, they can build the power to negotiate, seek remedy, and create change. Moreover, unions and membership-based organizations create a networked collective with staying power that goes beyond the technical support that an NGO might offer. In an industry of indebted workers, however, it can be difficult for unions to establish self-financing mechanisms.65 Outside resources should be directed toward these types of organizations, albeit carefully coordinated with their establishment of self-financing structures, as they lay the groundwork for lasting transformation.66
Pathways to Remedy for Fishers
Remedy is central to achieving justice for fishers subjected to labor abuse and exploitation. It includes restitution, compensation, rehabilitation, and accountability measures. According to the United Nations Guiding Principles (UNGPs), effective remedy must be legitimate, accessible, predictable, equitable, rights-compatible, and transparent.67 Yet, in practice, remedy for migrant and distant-water fishers is often inaccessible due to legal loopholes, geographic isolation, and the failure of both state and private actors to implement robust mechanisms.
Legal frameworks such as International Labour Organization Convention 188 (ILO C188) and the French Duty of Vigilance Law offer protections, but their effectiveness is still limited.68 C188, which establishes basic labor standards for the fishing industry, remains under-enforced, including in countries like Thailand where it was recently ratified in 2019. Moreover, supply chain regulations, such as France’s Duty of Vigilance Law, provide stricter corporate accountability but often fail to reach migrant workers at sea.69 In response, CSOs have stepped in to bridge the gap. Gearhart and Moynihan argue that remedy must go beyond legal processes to become a collective empowerment strategy rooted in organizing, peer support, and advocacy for stronger legal protection.70 Likewise, Parhusip’s article on “Emerging Port Infrastructure and Advocacy Networks for Migrant Fishers in Taiwan” underscores the importance of localized, culturally informed engagement at ports, where intermediary actors, such as local NGOs or unions, can support fishers asserting their rights.71
Grievance Mechanisms: Barriers and Risks to Remedy
Accessible grievance mechanisms are a prerequisite for meaningful remedy. Unfortunately, current mechanisms available to fishers are often inaccessible, mistrusted, or ineffective. While many companies promote hotlines and audits, these systems frequently fail due to language gaps, poor connectivity, employer control, and lack of follow-up.72, 73 Without trusted, independent mechanisms, fishers are unlikely to report abuse.
Key barriers to fishers’ ability to file grievances and secure remedy include debt bondage, document confiscation, and misinformation during recruitment, often via informal networks like Facebook.74 There is also fear of retaliation, especially amongst fishers on DWFs, due to isolation. CSOs report cases in which workers faced blacklisting, physical threats, abusive punishments, or denial of disembarkation after reporting. Even where legal frameworks exist, enforcement is inconsistent, as agencies and vessel owners often evade liability through complex subcontracting arrangements. These conditions show why grievance systems must be trusted, accessible, and legally protected with independent oversight.75, 76, 77
Promising Pathways and Institutional Support
In spite of obstacles, effective pathways to remedy do exist and are being developed for future implementation. SBMI has created a three-step grievance process, rooted in Indonesia’s national labor law, starting with demand letters, followed by tripartite mediation, and, if needed, escalation through criminal complaints under trafficking statutes.78 Their approach builds on peer networks, with many migrant workers returning to help others, making them trusted intermediaries with knowledge of national law and experience seeking remedy.79 While limited by funding and jurisdictional gaps, SBMI emphasizes that remedy must be continuous and supported not only by formal complaint channels but also by preventative efforts like legal orientation and pre-departure education.80 These outreach activities seek to prevent grievances by helping workers avoid exploitative recruitment and fostering agency.
While these local civil society organizations are critical to direct service and organizing, broader institutional reform also depends on globally oriented NGOs with capacity for high-level policy advocacy and research. Organizations like CI and C4ADS contribute by developing tools to strengthen fisher protections. CI promotes the integration of labor protections into governments’ implementation of the Port State Measures Agreement.81 C4ADS underscores the need for monitoring platforms to also capture labor abuses.82 The C4ADS database, Triton, only focuses on vessel ownership and IUU reporting, but that information could be used by unions like SBMI to help them pursue remedy even if the vessel disappears or claims bankruptcy.83 These NGOs, along with Greenpeace, also highlighted that greater collaboration and resource-sharing among CSOs is needed, as fragmented efforts limit the ability to address labor violations holistically.84
Research by Wilhelm et al. and Parhusip further underlines that grievance mechanisms disconnected from community realities are unlikely to succeed.85, 86 Top-down hotlines and audits often fail to win worker trust or deliver remedy because they do not account for the occupational realities, language needs, or social networks of migrant fishers.87 In contrast, community-embedded actors closely connected to fisher communities are identified as more trusted and effective in responsiveness and harm prevention.88 Integrating these community-rooted practices into formal remedy frameworks is thus essential for building legitimacy and ensuring fishers’ collective voices guide accountability efforts.
Technology is also a rapidly advancing catalyst for remedy, but it only succeeds when carefully implemented into broader grievance support systems. Wi-Fi and electronic monitoring (EM) can enable communication, document abuse, and enhance oversight.89, 90 Further, complaint apps, such as Issara Institute’s Golden Dreams mobile app, allow workers to report abuse anonymously in multiple languages, demonstrating the promise of digital platforms particularly when they are paired with follow-up support.91 Still, connectivity issues limit the app’s reach, as Wi-Fi is rare on distant-water vessels.92 Satellite Wi-Fi systems also remain costly, with monthly data plans ranging from $250 to $5,000 per vessel depending on usage, installation, logistics, and bandwidth needs.93 Still, expanding satellite Wi-Fi on vessels is critical, requiring shared investment from governments, industry, and buyers, alongside policies linking communication access and anti-retaliation protocols to vessel eligibility.94 These technologies function best when integrated alongside port-based support, community-level organizing, and CSO facilitation to reinforce trusted, participatory pathways to remedy.
Recommendations on Remedial Pathways
Current remedy mechanisms for fishers remain fragmented, relying on hotlines and top-down audits that offer individual voice but little systemic reform. Too often they extract information rather than empower workers and connect them to collective voice structures like unions, leading remedy to remain inaccessible, untrusted, and structurally disempowering.95, 96, 97, 98 These systems are also hampered by language barriers, poor connectivity, and lack of enforcement, leaving workers with few safe paths to report abuse. Effective remedy must rest on enforceable legal frameworks, be accessible at sea and onshore, and be co-governed by fishers. Remedy must also be viewed not as a one-time fix but as a continual, adaptive process responsive to the realities of fishers’ lived experiences.
Core features of successful remedy systems include accessibility, confidentiality, anti-retaliation protections, worker input, and legal mandates. Strategies to improve access include:
- Scaling pre-departure education and continuous dialogue amongst fishers and stakeholders
- Integrating unions and other membership-based organizations’ grievance systems
- Ensuring Wi-Fi and EM access on vessels
- Mandating labor metrics in port inspections
- Promoting greater transparency in recruitment and vessel ownership
- Strengthening coordination among unions, NGOs, and fisher organizations
Table 1 highlights targeted strategies towards some of the most pressing barriers fishers face while at sea for long periods of time.
Table 1. Targeted Solutions to Barriers on Remedy

While not exhaustive, this table illustrates examples of interventions that have proven promising or successful in specific contexts.99 The table also clarifies which actors are best positioned to implement each solution and highlights areas where further investment or innovation is needed. It offers a practical reference to guide future remedy efforts and support more strategic, coordinated responses. Overall, remedy must be grounded in fisher realities, not externally enforced frameworks.
IUU Reporting: What if Worker Voice Were Truly Free?
In an ideal world, where fishers were able to communicate with trusted representatives without fear of reprisals, they might help address IUU fishing. “IUU has been recognized by the United Nations as one of the seven major threats to world maritime security.”100 The Food and Agriculture Organization (FAO) defines IUU:
1. Illegal Fishing refers to fishing activity carried out without permission by foreign vessels in waters under the jurisdiction of another state, or in any other way that violates that state’s fisheries law and regulations;
2. Unreported Fishing refers to fishing that is not officially recorded; and
3. Unregulated Fishing refers to fishing activities carried out in areas where no applicable management measures exist.101
Advocates have argued that identification of labor rights abuses should trigger IUU investigations.102 Fishers, often closest to such violations, could help report IUU fishing if they had the freedom and protection to speak out.103 Though still a nascent concept in combating IUU fishing, fishers’ proximity to both human rights violations and legal infractions gives them a potentially valuable role in fostering transparency and accountability within seafood supply chains, if they could safely participate.
Chapsos and Hamilton’s (2019) study of Indonesian IUU networks reinforces this potential.104 Based on data from over 2,000 trafficked fishers, they show how IUU operations often rely on deceptive recruitment, forged documents, and coercive control to secure compliant labor and evade regulation. Another study concludes that trafficked fishers, if given protections, could serve as key witnesses to expose criminal fishing networks.105
The Link Between Labor Abuse and IUU Fishing
Labor exploitation and IUU fishing are deeply interconnected, with exploitative practices reducing costs while sustaining illegal fishing. A critical part of this system is the role of unregulated labor recruitment agencies acting as intermediaries between desperate migrant workers and vessel operators seeking cheap, compliant crews.106 Vessel owners intending to engage in IUU might seek out recruiters that will supply workers who are indebted, unaware of their rights, and unlikely to resist abusive conditions.107 This mutual dependency allows both to evade regulation: agencies profit regardless of legal compliance, while operators exploit a silent, invisible workforce.108 This arrangement illustrates how labor exploitation is not an unfortunate consequence but a structural necessity for IUU fishing.
Beyond recruitment, many fishers receive little or no training, limiting their ability to recognize and report illegal activities like bycatch or finning.109 This overlap between labor exploitation and IUU fishing highlights the urgent need for integrated monitoring systems that address environmental violations and human rights abuses together through coordinated strategies.
Currently, IUU detection relies on technologies like Vessel Monitoring Systems, Automatic Identification Systems (AIS), port inspections, and company audits, mainly targeting larger vessels.110 Yet audits often overlook labor conditions, prioritizing documentation over worker experience.111 As Nakamura et al. (2018) note, “the hands pulling fish from the net disappear from sight,” showing how supply chain audits miss fishers’ realities.112 Likewise, AIS data provides limited insight into vessel operations and labor conditions.113 These gaps highlight the need for systems centered on worker-generated data, with fisher-led reporting emerging as a crucial tool to improve transparency and enforcement across vessel types. The 2025 Monitoring for Change Report also finds that EM using cameras, sensors, and GPS can capture labor indicators at sea but faces challenges in reviewing-capacity and cost.
Unfortunately, the idea may be ahead of its time. Despite its potential, fisher-led reporting remains risky. Greenpeace USA experts stress that expecting vulnerable fishers to monitor IUU without training, protection, or support is unrealistic and potentially dangerous.114 They highlighted dangers like retaliation, blacklisting, job loss, and violence.115 Interviews consistently highlight dangers like retaliation, blacklisting, job loss, and violence. Recruitment conditions exacerbate fears: debts, lack of contracts, and identification make fishers reluctant to speak out. Social and moral pressures also discourage reporting.116 Without legal protections, labor enforcement, and CSO support, fisher-led reporting is often unsafe and infeasible.
Conditions for Safe and Effective Reporting
The recruitment supply chain is complex, requiring multiple strategies to mitigate risks (outlined in Table 1). Safe, effective fisher-led reporting requires legal protections, recruitment oversight, anonymous reporting mechanisms, and remediation pathways. Long-term success also hinges on fishers’ ability to build power and strengthen their collective voice.
CSOs vary in approach, some favor collective bargaining, others prioritize individualized grievance channels like hotlines or digital platforms. Despite these differences, many agree that centering fisher voice and agency is essential.117 Within this broader ecosystem, CSOs can play a vital role as facilitators, watchdogs, and advocates, ensuring fisher-led reporting is both possible and protected. If these groups can coordinate successfully and ensure effective protections for fishers who seek to speak out, they might also find pathways to preventing IUU.
Conclusion
Across every stage of the seafood supply chain, fishers face power imbalances compounded by isolation at sea, language barriers, debt, and threat of retaliation. While international legal frameworks, like ILO C188 and the UNGPs, provide important benchmarks, enforcement remains patchy and insufficient. As such, the lived experiences and voices of fishers often remain disconnected from the very systems designed to protect them.
CSOs have stepped in to fill these accountability gaps, providing grassroots advocacy, legal support, and technology-based solutions. Yet, their efforts remain constrained by limited funding and uncoordinated approaches between CSOs. Collective voice is key to overcoming structural power imbalances and ensuring grievance systems are effective. Without it, individual workers must navigate complex, high-risk complaint processes alone, often facing retaliation and rarely seeing resolution.
To address these challenges, three central reforms consistently surfaced throughout desk research and targeted interviews. Governments and corporations must support fisher organizing and embed worker voice across the supply chain by involving fishers in policy design and ensuring technologies like Wi-Fi and EM serve their needs. Recruitment systems should eliminate debt, ensure transparent contracts, and hold brokers accountable, with governments enforcing fair standards, employers ensuring debt-free hiring, and CSOs monitoring compliance. Access to remedy must be through CSO supported grievance systems that are anonymous, multilingual, trusted, and backed by legal enforcement mechanisms with companies taking proactive steps to ensure these systems are fair and accessible.
All in all, true change will require sustained, structural shifts that redistribute power to the people most impacted by exploitation. Fishers are not just sources of labor or victims of abuse. They are critical knowledge-holders with the experience to drive ethical reform with real impact. Fishers could also be allies in the fight to end illegal, unreported, and unregulated fishing, but to do so, they need a voice and the means to raise concerns without fear of retaliation. Protecting their rights is not only a legal imperative, but a practical necessity for building a just and sustainable seafood industry.
Notes
- Judy Gearhart, ed. 2023. “A Deeper Dive: Remedy and Recruitment in the Seafood Industry.” By Kelcey AllenRodriguez, Sloane Hardin, Suhyeon Kim, Victoria Latham, Olivia Mar, Carla Montilla, Connor Moynihan, Heather Mullen, Kiley Nivens, and Matthew Ridgeway. Unpublished report on behalf of Fisheries Governance Project. https://accountabilityresearch.org/wp-content/uploads/2023/05/Final-Paper_FGP-5-24-23.pdf.
- Gearhart, “A Deeper Dive.”
- Judy Gearhart and Connor Moynihan, ed. 2025. All Hands On Deck: Protections for Fishers in the Seafood Industry. Jeidy Barrios. Nicole Bernard, Jill Coleman, Parker Elizabeth, Judy Gearhart, Carlye Goldman, Natalie Leonard, Robert Menner, Jessica Mensah-Brown, Siobhan Powers, Aisha Tewfik. Accountability Research Center.
- Gearhart, “A Deeper Dive.”
- Rizky Oktaviana, Ade Herlina, Feliana Fauziyyah, Juwarih, Novia Kirana, and Adrian Basar (SBMI), interviewed by Natalie Leonard and Elizabeth Parker, Zoom, July 17, 2025.
- Gearhart, “A Deeper Dive.”
- Judy Gearhart and Connor Moynihan. 2025. Upwelling: Fishers Organizing for their Rights and Sustainable Fisheries. Accountability Research Center. Report. https://doi.org/10.57912/28616345
- Gearhart, “A Deeper Dive.”
- Oktaviana et al., interview by Leonard and Parker.
- Gearhart, “A Deeper Dive.”
- Gearhart and Moynihan, Upwelling.
- Greenpeace Southeast Asia. Forced Labour at Sea: The Case of Indonesian Migrant Fishers. 31 May 2021. https://www.greenpeace.org/static/planet4-southeastasia-stateless/2021/05/ef65bfe1-greenpeace-2021-forced-labour-at-sea-digital_final.pdf
- Gearhart and Moynihan, Upwelling.
- Oktaviana et al., interview by Leonard and Parker.
- Gearhart, “A Deeper Dive.”
- Oktaviana et al., interview by Leonard and Parker.
- Oktaviana et al., interview by Leonard and Parker.
- European Transport Workers’ Federation (ETF). Recruitment of Migrant Fishers. Brussels: European Transport Workers’ Federation, 2024. https://www.etf-europe.org/wp-content/uploads/2024/11/Recruitment-of-migrant-fishers.pdf
- European Transport Workers’ Federation, Recruitment of Migrant Fishers.
- Gearhart and Moynihan, Upwelling.
- European Transport Workers’ Federation, Recruitment of Migrant Fishers.
- European Transport Workers’ Federation, Recruitment of Migrant Fishers.
- Gearhart and Moynihan, Upwelling.
- Gearhart, “A Deeper Dive.”
- Oktaviana et al., interview by Leonard and Parker.
- Johanna Lee. 2025. “Fisher Organizing In Taiwan: A Country Case Study.” Accountability Research Center. https://accountabilityresearch.org/wp-content/uploads/2025/07/Fisher-Organizing-in-Taiwan_Final.pdf
- Gearhart, Judy. 2023. “Building Worker Power in Global Supply Chains: Lessons from Apparel, Cocoa, and Seafood.” Accountability Research Center. Accountability Working Paper 15. DOI: 10.57912/23931795
- Gearhart, Building Worker Power in Global Supply Chains.
- Oktaviana et al., interview by Leonard and Parker.
- Oktaviana et al., interview by Leonard and Parker.
- Gearhart and Moynihan, Upwelling.
- International Labour Organization (ILO). 1998. ILO Declaration on Fundamental Principles and Rights at Work and Its Follow-Up. Adopted 18 June 1998; annex revised 15 June 2010. Geneva: International Labour Office.
- M. Anner, M. Fischer-Daly, S. Amita, K. Maich, S. Okyere, and Y. Yint. 2023. Worker Voice: What it is, what it is not, and why it matters. Center for Global Workers’ Rights, The Pennsylvania State University: University Park. https://ler.la.psu.edu/wp-content/uploads/sites/4/2024/04/Penn-State-Worker-Voice-Report-Dec.-19-Final_amended_mfd_23March2024-2.pdf
- Anner et al., Worker Voice.
- Anner et al., Worker Voice.
- Anner et al., Worker Voice, 5.
- Anner et al., Worker Voice.
- Jessica L. Decker Sparks, Lee Matthews, Daniel Cárdenas, and Chris Williams. 2022. “Worker-less social responsibility: How the proliferation of voluntary labour governance tools in seafood marginalise the workers they claim to protect.” Marine Policy 139 : 105044. https://doi.org/10.1016/j.marpol.2022.105044
- Sparks et al., “Worker-less Social Responsibility.”
- Sabrina Zajak. 2017. “Channels for workers’ voice in the transnational governance of labour rights?.” Global Policy 8, no. 4 : 530-539. https://onlinelibrary.wiley.com/doi/abs/10.1111/1758-5899.12465#:~:text=https%3A//doi.org/10.1111/1758%2D5899.12465
- Sparks et al., “Worker-less Social Responsibility.”
- Anner et al., Worker Voice.
- Anner et al., Worker Voice.
- Anner et al., Worker Voice.
- Issara Institute. 2022. (B.) What is ‘Worker Voice’ in the Context of Global Supply Chains? Issara Institute. https://www.issarainstitute.org/_files/ugd/5bf36e_6fc0dc487c5c4e3ca6680aaf535259f7.pdf.
- Opi Outhwaite and Olga Martin-Ortega. 2019. “Worker-driven monitoring–Redefining supply chain monitoring to improve labour rights in global supply chains.” Competition & Change 23, no. 4 (2019): 378-396. https://doi.org/10.1177/1024529419865690
- Issara Institute. 2022. (A.) Worker Voice-Driven Ethical Recruitment Toolkit. Bangkok and Palo Alto: Issara Institute. https://www.issarainstitute.org/_files/ugd/5bf36e_fb28c5a7e4a14e9888ba6dee8efc951e.pdf
- Sparks et al., “Worker-less Social Responsibility.”
- Bennett Freeman, Sif Thorgeirsson, Adele Barzelay, and Brooks Reed. 2018. Shared Space under Pressure: Business Support for Civic Freedoms and Human Rights Defenders. London: Business & Human Rights Resource Centre and the International Service for Human Rights. https://media.business-humanrights.org/media/documents/ed628efe9bd9cb15e834c62b7a9b189d7d0ea6b9.pdf
- Freeman et al., Shared Space under Pressure.
- Freeman et al., Shared Space under Pressure, 71.
- Global Seafood Alliance. 2022. White Paper on Worker Voice on Fishing Vessels. https://www.globalseafood.org/wp-content/uploads/2020/11/GSA-White-Paper-on-Worker-Voice-on-Fishing-Vessels-Complete-004.pdf.
- Bruno Monteferri (Conservation International), interviewed by Carlye Goldman, Natalie Leonard, and Elizabeth Parker, Zoom, June 30, 2025.
- Erica Cherepko and Mia Hoskins (C4ADS), interviewed by Carlye Goldman and Natalie Leonard, Zoom, June 18, 2025.
- Issara Institute. “The Issara Model.” https://www.issarainstitute.org/the-issara-model
- Greenpeace USA. “Issues.” https://www.greenpeace.org/usa/issues/
- Oktaviana et al., interview by Leonard and Parker.
- Stella Maris. “What We Do.” https://stellamaris.org.uk/what-we-do/
- Gearhart and Moynihan, Upwelling.
- Gearhart and Moynihan, Upwelling.
- Gearhart and Moynihan, Upwelling.
- Gearhart and Moynihan, Upwelling.
- Gearhart and Moynihan, Upwelling.
- Gearhart and Moynihan, Upwelling.
- Gearhart and Moynihan, Upwelling.
- Gearhart and Moynihan, Upwelling.
- United Nations, Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework (Geneva: Office of the High Commissioner for Human Rights, 2011). https://www.ohchr.org/en/special-procedures/wg-business/access-remedy.
- International Labour Organization (ILO). Work in Fishing Convention, 2007 (No. 188), adopted June 14, 2007, Geneva: International Labour Office, https://normlex.ilo.org/dyn/nrmlx_en/f?p=NORMLEXPUB:12100:0::NO::P12100_INSTRUMENT_ID:312333
- Miriam Wilhelm, Vikram Bhakoo, Vivek Soundararajan, Andrew Crane, and Alin Kadfak. 2024. “Beyond Compliance-Based Governance: The Role of Social Intermediaries in Mitigating Forced Labour in Global Supply Chains.” Production and Operations Management 34, no. 5 (February 8, 2024): 3. https://doi.org/10.1177/10591478231224922
- Gearhart and Moynihan, Upwelling.
- Parhusip, Jonathan. 2023. “Emerging Port Infrastructure and Advocacy Networks for Migrant Fishers in Taiwan.” Asian and Pacific Migration Journal 32, no. 2 (June 2023): 371–83. https://doi.org/10.1177/01171968231191468
- Wilhelm et al., “Beyond Compliance-Based Governance.”
- Sparks et al., “Worker-less Social Responsibility.”
- Parhusip, “Emerging Port Infrastructure.”
- Wilhelm et al., “Beyond Compliance-Based Governance.”
- Sparks et al., “Worker-less Social Responsibility.”
- Gearhart and Moynihan, Upwelling.
- Oktaviana et al., interviewed by Leonard and Parker.
- Parhusip, “Emerging Port Infrastructure.”
- Oktaviana et al., interviewed by Leonard and Parker.
- Monteferri, interviewed by Goldman, Leonard, and Parker.
- Cherepko and Hoskins, interviewed by Goldman and Leonard.
- Oktaviana et al., interviewed by Leonard and Parker.
- Wilhelm et al., “Beyond Compliance-Based Governance.”
- Wilhelm et al., “Beyond Compliance-Based Governance.”
- Parhusip, “Emerging Port Infrastructure.”
- Wilhelm et al., “Beyond Compliance-Based Governance,” 1096.
- Parhusip, “Emerging Port Infrastructure,” 379.
- The Nature Conservancy, Conservation International, Global Fishing Watch, and Ocean Outcomes, Monitoring for Change: Insights from a Pilot on Electronic Monitoring and Wi-Fi Solutions for Social Responsibility (April 2025), 5.
- Global Labor Justice, Model Operational Guidelines for Wi-Fi Access and Fishers’ Rights on Distant Water Fishing Vessels (February 2025), 4. https://globallaborjustice.org/media/uploads/2025/04/WiFi_Guidelines_2025_02.pdf.
- Global Labor Justice, Model Operational Guidelines for Wi-Fi Access and Fishers’ Rights on Distant Water Fishing Vessels.
- The Nature Conservancy et al., Monitoring for Change, 34.
- The Nature Conservancy et al., Monitoring for Change, 22.
- The Nature Conservancy et al., Monitoring for Change, 41.
- Anner et al., Worker Voice.
- Sparks et al., “Worker-less Social Responsibility.”
- Wilhelm et al., “Beyond Compliance-Based Governance.”
- Parhusip, “Emerging Port Infrastructure.”
- Oktaviana et al., interviewed by Leonard and Parker.
- Adam Leonardo and Nowar Deeb, “Illegal, Unreported and Unregulated (IUU) Fishing in Indonesia: Problems and Solutions,” IOP Conference Series: Earth and Environmental Science 1081 (2022): https://iopscience.iop.org/article/10.1088/1755-1315/1081/1/012013/pdf
- Adam Leonardo and Nowar Deeb, “Illegal, Unreported and Unregulated (IUU) Fishing in Indonesia: Problems and Solutions.”
- Wilhelm et al., “Beyond Compliance-Based Governance.”
- Gearhart and Moynihan, Upwelling.
- Ioannis Chapsos and Simon Hamilton, “Illegal Fishing and Fisheries Crime as a Transnational Organized Crime in Indonesia,” Trends in Organized Crime 22 (2019): 255–273, https://doi.org/10.1007/s12117-018-9329-8.
- Adam Leonardo and Nowar Deeb, “Illegal, Unreported and Unregulated (IUU) Fishing in Indonesia: Problems and Solutions.”
- Gearhart, “A Deeper Dive.”
- Gearhart, “A Deeper Dive.”
- Gearhart, “A Deeper Dive.”
- Gearhart, “A Deeper Dive.”
- The Nature Conservancy et al., Monitoring for Change.
- Wilhelm et al., “Beyond Compliance-Based Governance.”
- Katrina Nakamura et al., “Seeing Slavery in Seafood Supply Chains,” Science Advances 4, no. 7 (2018): e1701833, https://www.science.org/doi/epdf/10.1126/sciadv.1701833.
- The Nature Conservancy et al., Monitoring for Change.
- Charli Fritzner, Sari Heidenreich (Greenpeace), interviewed by Elizabeth Parker, Natalie Leonard, and Carlye Goldman, Zoom, July 2, 2025.The Nature Conservancy et al., Monitoring for Change.
- Charli Fritzner, Sari Heidenreich (Greenpeace), interviewed by Elizabeth Parker, Natalie Leonard, and Carlye Goldman, Zoom, July 2, 2025.
- Charli Fritzner, Sari Heidenreich (Greenpeace), interviewed by Elizabeth Parker, Natalie Leonard, and Carlye Goldman, Zoom, July 2, 2025.
- Gearhart and Moynihan, Upwelling.
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ABOUT THE AUTHORS

Carlye Goldman is a second-year graduate student studying International Affairs: Natural Resources and Sustainable Development at American University and the University for Peace in Costa Rica and recently obtained a graduate certificate in Sustainable Agriculture & Food Systems from Tufts University Friedman School of Nutrition Science and Policy. She previously worked for the Foundation for Food & Agriculture Research, and is passionate about addressing challenges related to nutrition, sustainable agriculture, and food sovereignty in vulnerable populations.

Natalie Leonard is a second-year graduate student studying International Affairs: Natural Resources and Sustainable Development at American University and the University for Peace in Costa Rica. She is interested in the intersection of rights-based conservation and sustainable food systems, and she has contributed to research examining the relationship between forest cover change and coffee production in southern Costa Rica.

Elizabeth Parker is a 2025 graduate with a degree in International Affairs: Natural Resources and Sustainable Development from American University and the University for Peace in Costa Rica. They are passionate about environmental justice and ecological wisdom in global sustainability and currently serves as the Travel Coordinator for Soles4Souls, an international nonprofit advancing circularity and poverty alleviation through sustainable solutions.

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