RightShip recently picked up the Analytics – Shipping+ award for their “ground-breaking” Crew Welfare Self-Assessment Tool at the 2023 Singapore Business Review Technology Excellence Awards.
However, the RightShip Crew Welfare Self-Assessment Tool, as part of the Crew Welfare Code of Conduct initiated by the Sustainable Shipping Initiative (SSI), still does not meet basic tests for public transparency, accountability, or remediation, while the self-certification process includes the failure to identify and report egregious abuse – and abusers – through transparent public disclosure.
SSI launched its Code of Conduct and integrated Self-Assessment Tool on 12 October 2021. It was developed to protect the human rights and welfare of the world’s nearly 2 million seafarers by industry group SSI and the Institute of Human Rights and Business (IHRB), in association with the Rafto Foundation. This initiative promotes a safe, healthy and secure onboard work environment, and goes beyond the ILO Maritime Labour Convention (MLC) to focus on the full spectrum of seafarers’ rights and wellbeing, from fair terms of employment and minimum crewing levels to the management of grievance mechanisms.
As an integral part of the code’s promulgation, RightShip introduced its version as the Crew Welfare Self-Assessment Tool. Its platform aims to provide guidance on how to adopt the Code of Conduct, as well as how to track progress against three levels of accreditation, those being: basic, intermediate, and excellent. This results in their clients submitting data and receiving a “crew welfare badge”, which is stated as being able to “showcase crew welfare commitment”. Unfortunately, this badge accreditation is meaningless without independent oversight and reported benchmarking, publicly evidencing client improvements on a case-by-case basis. The accreditation cannot be deemed credible if it cannot – and will not – address cases of human or labour rights abuse.
Flawed data submission and collection
In its current form, the Self-Assessment Tool collates data submitted by client company employees. It is highly unlikely that a client’s representative will submit any issues of concern, including abuses of human and labour rights, due to a clear conflict of interest, internal concerns over adverse publicity, and the protection of commercial reputation. It is not clear as to the levels of training, awareness, or experience of those submitting reports as to their human and labour rights competencies.
Lack of public transparency and accountability
Factually, RightShip makes it clear on their website that “data submitted via the RightShip Crew Welfare Tool is not reviewed nor verified and will not affect your RightShip Safety Score, GHG Rating, Vessel Vetting process or Dry Bulk Inspection outcomes.” And “results will be stored in the Self-Assessment Tool, but the full content of the results nor data will be visible to third parties.” At the Self-Assessment Tool public launch webinar on 19 October 2021, these very issues were raised in relation to transparency, reporting, routes to effective remedy and accountability. Notably, ITF also questioned the validity of self-assessment.
In short, there is a lack of corporate transparency and accountability due to the lack of review or verification by independent human rights experts outside of the involved stakeholders. This is compounded by adverse welfare data not impacting on any other aspect of vessel operation, vetting, or inspection as stated by RightShip.
Points of concern and clarification
Human Rights at Sea (HRAS) has previously raised several points for clarification to SSI, and still awaits clarifying responses and assurances for addressing improvements.
- Why do SSI and/or IHRB not publish an annual list of all entities who have completed the Self-Assessment questionnaire through RightShip and received RightShip badged accreditation?
- In the 18 months since its inception has the Self-Assessment Tool identified any human rights abuses? If so, what remedial action has been taken?
- How does SSI and/or IHRB provide accountable oversight and access to victim remediation for any direct reporting or other indications through RightShip of human, labour, or social rights abuses in the supply chain?
- How does SSI and/or IHRB record and hold accountable any entity’s failure to improve year-on-year through the annual IHRB report?
- ITF’s articulated concern about the credibility of self-assessments was noted in the inaugural online video recording, so why was this point not highlighted in the platform profiling? Should this not be corrected to fairly avoid potential perception around misinformation?
- Does SSI and/or RightShip hold to account RightShip clients who are found to have fallen short? If so, how? And is RightShip not unavoidably conflicted between their paying current (and potential future) clients and the reporting of any related abuse(s)?
- How does SSI and IHRB demonstrate that those persons who completed the Self-Assessment form are themselves not conflicted in their reporting as employees of the company?
- The MLC 2006 does not explicitly mention human rights in its text. Which fundamental human rights (not labour rights) are being referred to under what human rights convention(s)? And how do those persons filling out the Self-Assessment form know the difference and/or made aware of the applicable rights?
- How are seafarers’ voices included and represented in the self-assessment process?
- What impact do adverse port state control MLC-related deficiencies/ detentions or RightShip inspection findings have on the crew welfare accreditation badge?
- How are the self-assessments independently validated and verified, thereby avoiding conflicts of interest in the development and assessment process?
Call to action
The development of the SSI Code of Conduct is a welcome initiative. HRAS was engaged by SSI at the start of the drafting process.
In comparison, the RightShip Crew Welfare Self-Assessment Tool can only be currently viewed as a refined corporate ESG exercise that provides highly restricted access to stated non-reviewed and unverified self-assessment statements made by employees of the very companies being awarded a crew welfare badge accreditation. The conflict of interest is unambiguous.
Unless SSI members, including RightShip, can categorically and publicly state that the Self-Assessment Tool will become transparent and accountable in its reporting, this initiative can only be viewed as a data collection exercise conveniently framed as supporting the human and labour rights of seafarers.
To become trustworthy, the RightShip tool and accreditation must focus on public transparency, accountability, and facilitating the bringing of violators of human rights abuse to justice without delay through existing legislative protections. Operating behind a closed-door approach encourages an environment of impunity under a semblance of respectability.
The work undertaken on the Code of Conduct is supported, but the Crew Welfare Self-Assessment Tool as it currently stands cannot be supported without undermining the vision of ending human rights abuse at sea.
Recent statements made by Andrew Stephens (FCMA), Executive Director at The Sustainable Shipping Initiative appears to support this view when he says:
“[Since 2021, The Sustainable Shipping Initiative had] numerous discussions around assurance and the need for verification and transparency, in order to build trust and create a strong foundation upon which companies can work together to respect seafarers’ rights and improve wellbeing. Credible assessments that are independently verified and made freely available to interested parties are critical for the delivering on seafarers’ rights project to succeed.” (TALKING POINT: Securing seafarers’ rights for a sustainable future, 23 May 2023)
I concur. No transparency = no accountability = no remedy.
