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Please note that by clicking on the below link you will download an extract of the Supplementary Report, which is to be read in light of the Initial Report and Supplementary Report, the Glossary of terms and Acknowledgements and Legal.
Click below to download the Supplementary Report.
Click below to download Glossary of Terms
Click below to download Acknowledgements and Legal.
While the Research Component in Section II outlines research related to selected environmental impacts and consumer protection as it relates to the Egg Industry, this Section III is our Stakeholder Component (Component 2 of the Phase 2 Project). It discusses the performance and commitment of 36 (or 3 dozen) Phase 2 Selected Stakeholders in relation to enhancing animal welfare, environmental protection, consumer protection, transparency, Corporate Accountability in the Egg Supply Chain, based on our specific Rating Criteria and Indicators.
Part B details our methodology, including our approach to stakeholder selection, engagement methods, development of Rating Criteria and Indicators, and our rating system. In Part C, we present the results of our ratings for the 36 Phase 2 Selected Stakeholders across six main criteria. Part D provides an in-depth analysis of our findings, examining trends in compliance, transparency, and corporate practices across different segments of the Egg Supply Chain. Finally, in Part E, we offer observations on key issues that emerged during our assessment, including areas where information gaps persist and notable inconsistencies and/or irregularities in stakeholder responses.
We aim to provide insights that equip consumers to make more informed choices, promote the importance of Corporate Accountability, and ignite broader discussions on issues relating to animal, environmental and consumer protection in the Egg Industry.
STEP 1: STAKEHOLDER SELECTION, which involved making use of the Stakeholder Mapping exercise undertaken in preparation of our Initial Report to identify and select 36 Phase 2 Selected Stakeholders for analysis and rating in this Supplementary Report based on selection criteria. 30 of the Phase 2 Selected Stakeholders were rated in our Initial Report.
STEP 2: STAKEHOLDER ENGAGEMENT, which involved locating the PAIA Manuals828 (statutorily required to be publicly available)829 of Phase 2 Selected Stakeholders and other necessary information to prepare and submit requests for access to records of Phase 2 Selected Stakeholders in terms of PAIA. The PAIA requests were dispatched with letters explaining the rationale for our requests. Thereafter, we engaged in correspondence with Phase 2 Selected Stakeholders in relation to their responses or lack thereof.
STEP 3: DEVELOPING RATING CRITERIA AND INDICATORS and creating a rating system against which Phase 2 Selected Stakeholder would be rated.
STEP 4: RATING the Phase 2 Selected Stakeholder based on an analysis of the information and correspondence received in response to our PAIA requests or lack thereof.
STEP 5: REPORTING on our findings.
In this Supplementary Report, we revisited our Stakeholder Mapping process detailed in Section IV of our Initial Report, where we mapped over 200 entities involved in various stages of the Egg Supply Chain in South Africa, focusing primarily on large Corporations.
Stakeholder Selection Factors
In the Initial Report, a 3 (three) component Stakeholder Selection Criteria system was developed and utilised in order to select stakeholders for analysis and rating.
In selecting stakeholders for Phase 2, and this Supplementary Report, we took into account the following additional factors (these were considerations rather than strict criteria):
Selected Stakeholder 2
Selected Stakeholder 3
Selected Stakeholder 8
Selected Stakeholder 9
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Selected Stakeholder 11
Selected Stakeholder 13
Selected Stakeholder 14
Selected Stakeholder 18
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Selected Stakeholder 20
Selected Stakeholder 21
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Selected Stakeholder 20
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Selected Stakeholder 35
We requested information from these Phase 2 Selected Stakeholders by submitting PAIA requests. We encountered challenges such as refusals and non-responsiveness as further expanded on herein. This lack of transparency highlights the need for a culture of accountability and justification within corporate practices, as outlined by the courts and required by constitutional values.
Our requests comprised two groupings: animal protection / welfare-related requests (Part A) which largely mirrored the requests sent in Phase 1, and environmental and consumer protection -related requests (Part B). We requested Phase 2 Selected Stakeholders to provide the necessary documents through two Google forms designed to streamline the process and allow stakeholders to provide records, grounds for refusals, or an affidavit in accordance with s 55 of PAIA in the event that the requested documents were not in their possession or did not exist at the time of our request, and which confirmed the stakeholder and/or their suppliers’ efforts to locate or obtain the documents, including from third parties.
Furthermore, in acknowledging that certain requests did not apply universally, Selected Stakeholders were free to indicate when the requested information was not applicable to their business practices. Our Google forms included a disclaimer stating, “[t]he entirety of [our PAIA request] may not be applicable to your company and/or each of its suppliers, but to the extent that it is, we kindly request that you provide the necessary records.”
Any and all Internal Policies were requested to inform our understanding of Selected Stakeholders’ attitudes in respect of animal welfare, specifically related to Layer Hens and Chicks.
We requested any and all records evidencing compliance or a lack thereof with Relevant Legislation. We further requested any and all records evidencing inspections conducted by any Relevant Authority. This request was intended to provide insight into a Selected Stakeholder’s understanding of their legal obligations in terms of Relevant Legislation.
We requested records evidencing that a Selected Stakeholder has signed on to an Animal Welfare Commitment and, if so, the progress towards meeting such commitment. Requests were made for access to Environmental Commitments as well as records evidencing progress towards the fulfilment of such Environmental Commitments.
We requested records evidencing membership of Selected Stakeholders to Industry Associations, on the basis that Industry Associations offer some degree of guidance, training and leadership to role-players in the Egg Supply Chain (including in relation to animal welfare). Industry Associations further impose codes of practice, internal standards and other requirements on members, including certification requirements. Furthermore, Industry Associations often represent stakeholders in the Egg Supply Chain.
In the spirit of analysing corporate transparency and accountability, we included transparency as one of our rating criteria. For transparency, we analysed whether Selected Stakeholders website contained a readily available and easily accessible PAIA Manual. We further analysed whether these PAIA Manuals designates an Information Officer and explicitly mentions animal welfare as a relevant subject or category of information/records and lists Animal Legislation. Lastly, we analysed whether the Selected Stakeholder demonstrated an understanding of, willingness and ability to comply with ALRSA’s request for access to records.
We requested Annual Reports from Selected Stakeholder to gain insight into the Selected Stakeholders’ reporting on animal welfare issues (including Progressive Measures to address Cruel Practices and beyond) in their Annual Reports.
Selected Stakeholders’ assets and stocks registers relevant to their egg supply or production were requested to assess the number of eggs sold or produced by a Selected Stakeholder and suppliers of eggs.
We requested any and all records evidencing Adverse Findings against Selected Stakeholders by any Relevant Authority. The purpose of this request was to assess whether there had been non-compliance with Relevant Legislation and enforcement measures taken against a Selected Stakeholder.
We requested records evidencing Public Statements made by Selected Stakeholders to assess whether Selected Stakeholders’ engagement with the public aligned with their animal welfare practices, and willingness to engage openly with ALRSA. We also wished to establish whether Selected Stakeholders are engaging in Greenwashing and/or Humane-washing.
We requested any and all records illustrating SABS/AGW Certification or Other Certification. AGW certifies role-players in the egg and other animal and agricultural industries in respect of their sustainability practices. This includes an “animal welfare approved” food label awarded to Companies that comply with the requirements or certification of AGW. SABS certification and accreditation is the process of certifying that a product has passed performance and quality assurance tests stipulated in a standard or regulation or that it complies to a national and international standard or regulation governing quality and minimum performance requirements.
In the spirit of analysing corporate transparency and accountability, we included cooperation as one of our rating criteria. For cooperation, we analysed whether the Selected Stakeholder was cooperative and transparent throughout ALRSA’s engagement.
Building on the criteria and indicators developed in Phase 1, and based on engagements with Phase 2 Selected Stakeholders, we refined our Supplementary Rating Criteria, Indicators and corresponding colour rating system. We awarded colour-ratings to each Phase 2 Selected Stakeholder linked to specific Indicators and Criteria. The colours are: GREEN, ORANGE, RED, BLUE, and GREY. We explain below what each colour represents in relation to each specific Criterion and Indicator. The final colour-rating for each Phase 2 Selected Stakeholder is based on their performance in relation to the records and information provided and nature of their engagements with us, as specified below with reference to the thresholds for colour-ratings. We did not rely on information in the public domain or additional research for purposes of the ratings. The ratings are thus based solely on ALRSA’s interactions with the Phase 2 Selected Stakeholders and their representatives during the period 23 November 2023 to 26 August 2024.
Having evaluated the information relative to the Selected Stakeholders obtained through the Project against the Criteria and Indicators, the Selected Stakeholders’ overall colour-rating was as follows:
GOOD EGGS
BAD EGGS
As set out above, ALRSA’s rating Criteria focused on the following:
1. Animal Welfare-centred Internal Policies
2. Annual Reporting on animal welfare and asset and stock register
3. Compliance with Relevant Legislation
4. Adverse Findings
5. Relevant Commitments
6. Public Statements
7. Membership to Industry Associations
8. Certifications
In the spirit of analysing corporate transparency and accountability we further included:
9. Transparency
10. Cooperation
ANIMAL WELFARE-CENTRED INTERNAL POLICIES
The majority of Selected Stakeholders provided access to Internal Policies Reports (26 out of 36). However, only 15 of these 26 the Internal Policies provided included animal welfare relevant content. Further, only 6 Selected Stakeholders provided Internal Policies that expressly address Progressive Measures, specifically related to the phasing out of cage egg sourcing. These were Famous Brands on behalf of Mugg n Bean, Wimpy and Steers respectively, Kauai, KFC and City Lodge.
ANNUAL REPORTING ON ANIMAL WELFARE AND ASSET AND STOCK REGISTERS
Just over half of the Selected Stakeholders provided access to their Annual Reports (19 out of the 36). Only the Annual Reports of KFC and Hilton address Progressive Measures or Cruel Practices in any manner, whilst in addition to these two Selected Stakeholders, Pick n Pay and City Lodge address animal welfare generally in their reporting.
COMPLIANCE WITH RELEVANT LEGISLATION AND ADVERSE FINDINGS
Most retailers, wholesalers and hotels provided records confirming compliance or otherwise with Relevant Legislation and records relating to Adverse Findings. However, some fast-food outlets and restaurants refused to grant access to these records. Tiger Brands denied the applicability of Relevant Legislation to them.
RELEVANT COMMITMENTS
While only Nandos and City Lodge provided documentation expressly confirming that they have undertaken Animal Welfare Commitments, various other Selected Stakeholders, while not providing such records have committed to transitioning to cage-free egg sourcing in policies or otherwise. This includes Famous Brands Ltd on behalf of Mugg n Bean, Wimpy and Steers, Kauai, KFC, McDonalds and Hilton Hotels. Only 9 Selected Stakeholders provided records confirming that they are party to an Environmental Commitment. They include Pick n Pay, Shoprite, Spar, KFC, Rhodes Food Group, Bidvest, Sun International, City Lodge, Southern Sun, and Hilton Hotels.
PUBLIC STATEMENTS
We define “Public Statements” as:
A Public Statement was viewed as “Comprehensive” if it:
The majority of Selected Stakeholders did not provide Public Statements. Ideally, Public Statements would disclose to consumers current sourcing and production activities these Selected Stakeholders were undertaking within the Egg Supply Chain. Only Famous Brands on behalf of Mugg n Bean, Wimpy and Steers, Kauai, and City Lodge provided access to Comprehensive Public Statements. The multinational corporation, Hilton, provided access to Public Statements addressing its transition to cage-free egg sourcing.
INDUSTRY ASSOCIATION MEMBERSHIP AND CERTIFICATION
Very few Selected Stakeholders provided confirmation of membership of Industry Associations. Members of Industry Association include Shoprite, Quantum Foods, and AFGRI. Pick n Pay claimed to “subscribe to SAPA which is an industry body which guides and assists with self-regulation within the Poultry Industry” but did not provide proof of membership. Many Selected Stakeholders viewed Industry Associations as not applicable to them. Some Selected Stakeholders confirmed that their suppliers are members of Industry Associations, however, did not confirm any such membership in respect of themselves. These include McDonalds, Tiger Brands, and Bakers. Other Selected Stakeholders confirmed that they are not a member of any Industry Association. They include Bidvest, Sun International, City Lodge Hotel Group, Hilton Hotels and KFC.
Environmental and Consumer Rights in the Egg Industry in South Africa