2.4 Supply Chain Transparency, Audit, Reporting and Purchase Requirements

Processors, traders, importers, transporters, marketers and others involved in the seafood industry shall:

1. For purchases from fish trading organizations that trade 10,000 tons or more of tuna annually (not directly from fishing vessels), purchase all round; gilled and gutted; or headed, gilled and gutted albacore, skipjack, yellowfin and/or bigeye tuna from:

1. ISSF Participating Companies;  or
2. Companies designated by ISSF as Data Check Companies that have a published compliance audit report with respect to ISSF Conservation Measures 2.2, 1.1, 4.1, 4.2, and 5.1, as determined and reported by the ISSF external auditor

2. If purchasing from processing organizations that purchase and process more than 12,500 round tons per year, purchase all frozen loins or processed, shelf-stable, canned or pouched products of albacore, skipjack, yellowfin and/or bigeye tuna from:

1. ISSF Participating Companies; or
2. Companies designated by ISSF as Data Check Companies that have a published compliance audit report with respect to ISSF Conservation Measure 2.2, 1.1, 4.1, 4.2, and 5.1, as determined and reported by the ISSF external auditor

3. ISSF Participating Companies will be exempt from compliance with this measure until December 31, 2025, if they publish annually before 15 March of each year:

1. The percentage of their purchases (measured in round ton equivalents) for each of the following Fishery Source categories:
   • MSC-certified fisheries eligible to use the MSC label
   • Comprehensive FIPs that are publicly listed and have achieved progress within at least the past 36 months or are in their initial year of listing
   • Comprehensive FIPs that are publicly listed but have not achieved progress in the prior 36 months
   • Fisheries that have entered full assessment for MSC certification, but are not in a comprehensive FIP that is publicly listed
   • None of the above
2. The percentage of their purchases (measured in round ton equivalents) for each of the following Supplier Source categories:
   • ISSF participating companies
   • Data Check Companies
   • Direct from vessels
   • None of the above
3. A statement of intent that includes a time-bound implementation plan to decrease purchases from the “none of the above” categories in 3(a) and (b) above.

General Provisions

1. The classification of a “Data Check Company” is available to processors, marketers, and traders of tuna. 
2. The “Data Check Company” classification is not available for any company that is an ISSF Participating Company on December 31, 2019.

Terms and Conditions
A company seeking to be classified as a “Data Check Company” for the purposes of ISSF CM 2.4 must make a written request to ISSF in which it agrees to the following terms:

1. Data Check Companies must submit data for all tuna purchases following the requirements of ISSF CM 2.2.
2. Data Check Companies must undergo annual audits by the ISSF external auditor for their compliance with ISSF CMs 2.2, 1.1, 4.1, 4.2, and 5.1, using the same audit protocol that is applied to ISSF Participating Companies for Conservation Measure 2.2, and for the other CMs, from this data. A processor or trader in the IATTC convention area will not need to undergo an annual audit for compliance with ISSF CM 2.2 if it provides evidence of quarterly data submission to IATTC.
3. An initial compliance audit will be conducted by the ISSF external auditor after two quarters of data reporting and continually annually thereafter.
4. The audit reports of Data Check Companies will be made public on the ISSF website and must develop a remediation plan for any major non-conformances reported to retain Data Check Company status.
5. Data Check Companies are required to pay a fee of $6,300, determined by the ISSF Board of Directors and subject to annual review, in order to cover the audit costs.
6. Failure to pay the fee within 60 days of invoice receipt will result in loss of Data Check Company status.