Our Q&A blogs with conservation experts explore shared priorities for sustainable tuna fisheries and marine ecosystem health, including how ISSF’s work contributes to these efforts. The views expressed by the experts we interview are their own.
As part of its commitment to foster transparency and accountability in the fishing industry, ISSF engages third-party auditor MRAG Americas to assess ISSF participating seafood companies’ compliance with ISSF conservation measures according to a rigorous audit protocol. This is an update of a 2022 conversation between ISSF President Susan Jackson and MRAG Americas Vice President Dr. Graeme Parkes about the ISSF audit and compliance process.
Susan Jackson, President, International Seafood Sustainability Foundation (ISSF)
Dr. Graeme Parkes, Vice President of Project Management, MRAG Americas
Susan Jackson: How long has MRAG Americas audited ISSF participating companies’ operations, and what is the value of this continuous engagement?
Graeme Parkes: For 14 years now! We have been providing auditing services to ISSF since 2012, starting with the vessels on the PVR and adding the participating companies’ activities in 2014. This continuous engagement has provided a high level of consistency and stability, without which reliable tracking of program progress over time and participants’ level of compliance would be highly challenging. The longevity of the program and resulting uniformity in methodology and implementation have provided enhanced credibility to the auditing process and outcomes.
Susan Jackson: Why is an independent audit an important part of the ISSF audit and compliance process? What is the value of ISSF commissioning a third-party audit rather than ISSF performing this function internally?
Graeme Parkes: Independent auditing adds value to the ISSF compliance process in several important ways. First and foremost, it adds credibility in a way that an internal audit cannot. Participants and other stakeholders need to have confidence that conformance with ISSF conservation measures is being assessed accurately and consistently. Of course, this can be done internally, but an external, independent process undertaken by a qualified provider with an established track record in rigorous conformity assessment provides a highly visible level of integrity and reliability.
Additionally, MRAG’s many years of experience in fisheries and supply chain auditing enables ISSF to understand the auditing implications of new conservation measures at an early stage, helping them to grow the program as effectively and efficiently as possible.
Susan Jackson: From the auditor’s perspective, what are the challenges of auditing seafood companies on multiple measures? Can you explain how MRAG audits a particular commitment?
Graeme Parkes: The auditing challenges arise in part from the number and range of ISSF conservation measures, but also the variety of ISSF participating companies’ sourcing practices. The sourcing of tunas by the companies covers a broad range of species, gear types, geographic regions, and hence RFMO jurisdictions.
Among other things, the audit team needs to be familiar with the differing requirements for fishing licenses, transshipment declarations, captain statements and catch certificates to assess accurately the validity of the documents presented as evidence of conformance. We spend significant time and effort on maintaining audit program consistency. This requires multiple levels of scrutiny by the whole audit team, including reviews of prior audit reports, to ensure uniformity in grading of compliance within and between years. The resulting stability in audit outcomes has helped companies to understand the evidence requirements for audits, that information requests for auditing are fair, and that the program is equitable for all participants.
Traceability audits are a good example to consider. The traceability exercises demonstrate a participating company’s ability to trace its products from can code or sales invoice back to a vessel and trip, enabling our audit to assess its conformance along the supply chain. The auditor reviews recent mock recalls, if available, and selects a sample of can codes or sales invoices by label and destination from which the company will conduct traceability exercises. The traceability exercises also enable the auditor to cross-reference evidence provided in connection with other conservation measures.
Susan Jackson: Over the years, participating companies have maintained consistently high levels of conformance with ISSF Conservation Measures. The July 2026 compliance report showed that the 24 ISSF participating companies achieved a 98.8% conformance rate across 32 ISSF conservation measures. Does this positive performance mean the audits have become easier to conduct?
Graeme Parkes: ISSF has more than 30 Conservation Measures now. They have grown in number and complexity, so over time the audits have actually become more difficult. But this complexity didn’t increase overnight, and as the audit process has evolved, the established participating companies have learned how it all works and developed systems and procedures for meeting the evidential demands each year. So, in this sense, the audits have become more efficient, but assessing the conformance with newer measures can be harder while both the auditors and the companies get used to how this can be done most effectively.
Not surprisingly, companies that have participated with ISSF since the early years tend to find current audits easier overall than do the newly joined companies being exposed to the material for the first time. Nevertheless, when there are structural or procedural changes within companies, we sometimes see new obstacles that need to be overcome no matter how long they have been part of ISSF.
Annual audits are a two-step process. Participating companies receive a Preliminary Compliance Report (PCR), which includes comments from the auditor where applicable, and a final Compliance Report (CR) after a 30-day remediation period, when companies have an opportunity to address deficiencies. Most PCs, even those that are very familiar with the process, need to provide some additional evidence of conformance following receipt of their PCR. The audit will never be a rubber stamp.
Susan Jackson: We hear a lot about “transparency” in the fishing industry today. What does this mean in practice for an auditing process like the ISSF one?
Graeme Parkes: Transparency is essential to explain how the audits are undertaken and what they show about individual company conformance with the conservation measures. This is why the conservation measures, audit protocols, and participating company annual audit reports are publicly available.
However, this transparency must be applied with forethought and foresight; it cannot extend to all levels of the program. With much of the detailed information provided for audits being confidential and commercially sensitive, participating companies must have confidence and trust in the independent auditor. They must be assured that while the results of their audit will be made public, irrespective of the audit findings, their proprietary information used in the assessment of conformance remains protected and confidentiality is not compromised.
Susan Jackson: How do insights and findings from audits inform ISSF conservation measures — expanding existing measures, for example, or suggesting a need for additional measures?
Graeme Parkes: Our experience from auditing the ISSF program, and other independent auditing activities, enables us to counsel ISSF regarding the auditability of proposed new conservation measures and amendments to existing ones. However, as independent auditors, we do not advise ISSF on the need for these measures – this is up to the organization itself.
Susan Jackson: Is auditing like this common with sustainable fishing commitments, or is there something unique or important about the ISSF-MRAG model?
Graeme Parkes: The types of conservation measures implemented by ISSF are not necessarily unique; they may overlap with some of the key requirements of other fisheries sustainability initiatives. But the combination of ISSF’s adopted conservation measures with MRAG Americas’ independent conformance assessment using a comprehensive series of audit protocols is ground-breaking.
ISSF is a cross-sector organization that draws on state-of-the-art environmental and scientific expertise to develop conservation measures with which participating companies commit to conform. The ISSF conservation measures are consequently meaningful, transparent, and enduring, and there is a high level of cooperation with the independent auditing procedures established by MRAG Americas.
If companies receive non-conformances during their audits, they know there are real consequences, and they typically are quick to remedy their practices to ensure these non-conformances are mitigated and not repeated. The results have been, and continue to be, transformational in the sustainability performance of the canned tuna supply chain and have the potential to make similarly far-reaching advancements in other seafood sectors.
Susan Jackson: What should stakeholders take away from more than a decade of independent auditing of ISSF participating companies?
Graeme Parkes: A decade of consistent, independent auditing has shown that ISSF’s conservation measures for the seafood industry work and remain as important and relevant today as they were at the start.
Independent auditing provides transparency and demonstrates the credibility of the ISSF model. It enables progressive and responsible participating companies to show policymakers, customers, and other stakeholders their continuing commitment to sustainable fishing and responsible sourcing, with the backing of high-quality verification recognized across the industry and NGO community.
Through ISSF, the participating companies along with vessels listed on the PVR and/or VOSI also gain a stronger footing to engage in tuna conservation and management discussions with stakeholders, their flag states, and the Regional Fisheries Management Organizations (RFMOs). The transparency and knowledge that come with the audit program (audit policy documents and public audits results) — together with feedback mechanisms via the ISSF Environmental Stakeholder Committee (ESC) and Scientific Advisory Committee (SAC), the vessel community, and the Implementation Team — allow stakeholders to remain engaged, receive answers to their questions, and offer suggestions on how the initiative can be improved and strengthened over time.
