Thai Frozen Foods Association’s Policy and Implementation concerning
Child Labor and Forced Labor


a. Preface

Thai Frozen Foods Association (TFFA) is a private non-profit organization founded in 1968 under the Thai Trade
Association Act. The original name was Thai Marine Products Association, then changed to Thai Fishery and Frozen
Products Association in 1983 to cover the frozen products industry.

Finally, the present name of Thai Frozen Foods Association was adopted in 1994. The name clearly reflects the overall
scenario of frozen products as food item, as well as expands the association’s supervisory role beyond marine products
to cover many other food categories.

TFFA runs by Directors elected from its members to a 2 year-term. The main business of its members is processing and
exporting frozen foods. TFFA derives its income from annual membership fee, as well as service provided such as sample
analysis, arranging seminars, sales of forms and documents.

The TFFA’s members consists of 183 plants and 97 affiliated primary processors to the member plants whereas 75 member
plants are in Samutsakorn with 85 affiliated primary processors. (at 31 May 2012)

The key objective of the policy is to encourage responsible business practices by the members of the TFFA and to
promote conditions of work that provide a safe and motivating working environment that is free of child labour, forced
labour and discrimination and uphold and promote national labour laws and relevant international labour standards.

TFFA believes that good workplaces are safe and healthy workplaces where workers can contribute to continuous
improvements. Sustainable enterprises also respect the relevant labour standards including minimum age for employment,
reject the worst forms of child labor, reject forced labor and in the context of seafood processing industries in Thailand
recognize the positive role that non Thai migrant laborers play in the industry and promote the overall wellbeing of Thai
and non-Thai migrant workers and their families.

TFFA recognizes that such practices improve productivity and strengthen the innovativeness and competitiveness of
enterprises and contribute to the overall sustainability and economic viability of the industry.

b. Objective

   - All members committed to the elimination of child labor and forced labor from member’s facilities and affiliated primary
processors within 6 months.

   - Mapping all facilities to provide better means of prevention of abusive labor practices within 1 year.

   - Eliminate child labor and forced labor from member’s facilities and affiliated primary processors within 2 years.

The aim of the objective is to :

   - combat child labour and forced labour within the seafood industry.

   - help establish, promote and actively engage in removal of children from child labour in particular in its worst forms as
defined by the national legislation.

   - help establish, promote and actively engage in addressing situations of forced labour.

   - help establish, promote and actively engage in preventive strategies combating child labour and forced labour within
seafood industry.

   - support policies and programmes (formal and non- formal education and vocational training, access to social protection
services etc. for young workers and their families) aimed at improving workers and community members access to basic
services.

Thai Frozen Foods Association will communicate this policy and support its members in applying it within their enterprises
and their suppliers and report annually to its board on progress it has made toward applying these principles. It will
disseminate this policy to all of its new members and provide assistance and training to its members on how to address
the issue of child labour and forced labour in the supply chain. A short version laying out the basic principles of this policy
will be displayed in Thai, English, Burmese and other necessary language in all member factories with managers and workers
made aware of the rationale and content of the policy.

The Thai Frozen Foods Association assign a senior member of its board to be responsible for the effective implementation
of this policy who will also be responsible for reporting annually to the Board and external stakeholders about its performance
with respect to the implementation of the policy.

c. Commitment

The members of the Thai Frozen Foods Association shall :

   1. comply with national laws on child labour and minimum age.

   2. not use or support the use of child labour as defined in ILO Convention 138.

   3. seek to eliminate and prohibit the worst forms of child labour in accordance with national laws and regulations and
the ILO Convention 182.

   4. not use or support the use of forced labour

   5. not work with those who use child labour or forced labour

   6. cooperate fully with competent authorities in addressing situations of child labour and forced labour.

The members of the Thai Frozen Foods Association commit to work towards:

   1. Establishing an internal monitoring system to periodically monitor and verify to identify and address child labour and
forced labour situations among its members and among their suppliers

   2. Promote and participate in advocacy against child labour and forced labour 3. Continue to work towards better safety
and health, working conditions and overall wellbeing of young workers 15 to 17 year of age in the industry.

d. Measure against violators

   1. A boycott by our trade partners who sign the MRA.

   2. A sanction according to article 12 of TFFA bylaw, for causing a Serious Damage to the Industry.

e. Implementations

TFFA position on child labour is as follows:

   1. TFFA will assist and help competent authorities to regulate child labour issues in its member plants and their
affiliated peeling sheds. TFFA collaboration with ILO is concentrated on addressing child labour and forced labour
in the Shrimp industry.

   2. TFFA shall strongly encourage its member plants and their affiliated peeling sheds to ensure that the treatment
of workforce is in full compliance with Thai labour laws.

   3. TFFA shall strongly encourage the member plants and their affiliated peeling sheds to comply with the rules
and regulations of the Department of Fisheries on manufacturing standards (GMP, HACCP).

   4. TFFA has specified the following measures to regulate labour issues:

Peeling Shed’s Labour Reform Programme

   - Every peeling shed shall be listed with a member plant who acts as a mentor to them on action against child
labour and forced labour.

   - The member plants shall provide TFFA with a list of peeling sheds from which their purchase raw materials; be
it those already registered with the Department of Fisheries and/or is in the process of doing so;

Terms and Regulations for Member Plant

   - All member plants who are manufacturer and exporter shall enroll with the Labour Reform Programme

   - The member plants shall issue a letter of confirmation that the plant and their affiliated peeling sheds –do not
employ child or forced labour.

   - The member plants shall produce a list of their affiliated peeling sheds as per the forms specified by TFFA and
shall monitor and regulate their own plant and affiliated peeling sheds to ensure non-existence of child and forced
labour usage.

   - The member plants shall provide TFFA with a list of their affiliated peeling sheds for the purpose of recording.

   - The member plants will inform changes in the number of their affiliated peeling shed quarterly.

   - TFFA will regularly inspect the compliance to these arrangements and will issue a “Mentored Peeling Shed for
Exportation” certificate.

Action against non-compliance

TFFA will work together with relevant government authorities to enforce these policies and shall inspect each
affiliated peeling shed of the member plants. Should child and forced labour be found, the following measures
shall be implemented:

   - First detection, TFFA shall issue a warning letter and direct the member plant to comply with rules and regulations
set forth by TFFA.

   - Second detection, TFFA shall deny selling the Health Certificate form for exportation to EU and DS 2031 form
to non-comply member plant until proper corrective action is taken Without these forms, exporters are unable to
ship their products to EU and US. TFFA is currently the sole authorized seller of both forms.

   - Third detection, TFFA shall suspend and terminate the membership of the member plant.



Reference materials:

Worst Forms of Child Labour Convention, 1999 (No. 182)
Convention concerning the Prohibition and Immediate Action
for the Elimination of the Worst Forms of Child Labour


Minimum Age Convention, 1973 (No. 138)
Convention concerning Minimum Age for Admission to Employment

Minimum Age Recommendation, 1973 (No. 146)
Recommendation concerning Minimum Age
for Admission to Employment


ILO Declaration on fundamental principles and rights at work
(Adopted by the General Conference of the International Labour
Organization during its Eighty-sixth Session which was held
at Geneva and declared closed the 18 June 1998.)




Scope of Child Labour

1) Child Labour refers to a worker at the age of 15 and over but not fully 18 (as per Thailand Code of Labour).

2) Hazardous work for child refer to any work that is considered as potentially hazard as per the Labour Protection
Act 1998, namely,

   - Welding, blasting, molding or metal forming work

   - Metal pressing

   - Work with exposure to heat, coldness, vibration, noise and lighting at abnormal level which may be hazardous
(work within a working environmental temperature exceeding 45ºC/ work within refrigerated room in frozen food
manufacturing or preserving industries/ work requiring the use of percussion drill/ work with continuous level of noise
over 85 dBA for an 8 hour working day);

   - Work related to hazardous chemical (carcinogen manufacturing or transportation/ cyanide related work/firework,
firecracker or other explosive substance manufacturing or transportation/ exploration, drill, refinery, loading or unloading
of petrol or gas, except work at petrol station);

   - Work related to toxic micro-organism be it virus, bacteria, fungus or others (work in diagnostic laboratory/ medical
care for communicable diseases as per laws on communicable disease/ cleaning of tools or patient garment within
hospital/ collection, transportation and disposal of clinical waste or sewage);

   - Work related to toxic, explosive or flammable substance, except work in petrol station;

   - Work related to driving or controlling forklift or crane as per the ministerial regulations;

   - Work using electric or engine saw;

   - Work carried out underground, under water, in cave, tunnel or crater;

   - Work related to radiation as per specified in the ministerial regulations;

   - Work related to cleaning of machine or engine while in motion;

   - Work performed on scaffolding over 10 metre above the ground.

3) List of working environment proving hazardous for children including:

   - Daily work performed during 22:00 – 06:00 hrs.

   - Work in refrigerated room in frozen food manufacturing or preserving industries;

   - Work in diagnostic laboratory;

   - Work in slaughterhouse;

   - Work in gambling establishment;

   - Work performed underground, under water, in cave, tunnel, crater or confined space;

   - Work performed on scaffolding over 10 meter above the ground;

   - Work in position requiring suspension or rappel;

   - Work in entertainment facilities as per laws on entertainment facilities such as dance hall, folk dance hall, ronggeng
or karaoke;

   - Work in marine fishing boat, loading or unloading goods for marine liners; and

   - Work engaging children in begging, obscene show, prostitution or drug dealing.

4) Workplace prohibited for child under 18 year of age to work in as per Clause 50 of the Labour Protection Act,
1998 includes:

   - Slaughterhouse;

   - Gambling establishment;

   - Entertainment facilities as per laws on entertainment facilities;

   - Other places as specified by the ministerial regulations.