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Please note that by clicking on the below link you will download an extract of the Initial Report, which is to be read in light of the Initial Report, the Glossary of terms and Acknowledgements and Legal.
Click below to download the full Initial Report.
Click below to download Glossary of Terms
Click below to download Acknowledgements and Legal.
Our Stakeholder Component discusses the performance and commitment of 36 (or 3 dozen) Selected Stakeholders in relation to enhancing animal welfare, transparency, and corporate accountability in the Egg Supply Chain.
We provide the public with information about who some of the key role-players in the Egg Supply Chain are; and how they are performing in relation to animal welfare, corporate accountability, and transparency in the Egg Supply Chain in terms of ALRSA’s rating system. This Stakeholder Component aims to increase consumer awareness concerning animal welfare issues in the Egg Supply Chain about the attitudes, policies, and practice of the Selected Stakeholders. This awareness could, in turn, empower consumers to make more informed choices, and to demand more from role-players in relation to animal welfare, particularly the Selected Stakeholders. It also aims to promote improved transparency and corporate accountability from the Selected Stakeholders, based on their ratings and the ratings of other Selected Stakeholders.
This Stakeholder Component, to our knowledge the first of its kind in Africa, was prepared in the public interest to advance, among others, the fulfilment of the right to an environment not harmful to health or well-being enshrined in section 24 of the Constitution, as well as the constitutional values of transparency and corporate accountability.
Our intention is to supplement and update this Stakeholder Component following further engagement with the Selected Stakeholders and other role-players in the Egg Supply Chain, and to expand on or amend our Rating Criteria and Indicators as appropriate. Selected Stakeholders and other interested parties are encouraged to raise any questions or concerns about the rating and analysis set out below with us. In the spirit of collaboration and as part of the collective effort to enhance animal welfare and a just transition towards a cage-free Egg Supply Chain, we urge Selected Stakeholders to engage with us and provide further information which could assist in promoting animal flourishing.
The structure of the Stakeholder Component is as follows:
STEP 1: STAKEHOLDER MAPPING, when we identified and mapped out stakeholders in the Egg Supply Chain.
STEP 2: STAKEHOLDER SELECTION, when in view of the Stakeholder Mapping, we identified and selected 36 Selected Stakeholders for analysis and rating in this Stakeholder Component based on three selection criteria.
STEP 3: STAKEHOLDER ENGAGEMENT, which involved locating the PAIA Manuals (statutorily required to be publicly available) of Selected Stakeholders and other necessary information to make requests for access to records from Selected Stakeholders in terms of PAIA (PAIA requests), which were dispatched with letters explaining the rationale for our requests and background to this Project. Thereafter we engaged in correspondence with Selected Stakeholders in relation to their responses or lack thereof.
STEP 4: DEVELOPING RATING CRITERIA AND INDICATORS against which Selected Stakeholders would be rated, as well as determining a scoring system.
STEP 5: RATING the Selected Stakeholders based on an analysis of the information and correspondence received in response to our PAIA requests (or lack thereof).
STEP 6: REPORTING on our findings.
As set out in Section II (Industry Component), the Egg Supply Chain is vast and complex, given the many role-players involved in producing various types of eggs for consumption. Many studies and reports focus on corporate accountability and animal welfare in relation to specific role-players of the Egg Supply Chain, such as retailers and fast food and restaurants. In order to advance Corporate Accountability across the Egg Supply Chain more holistically, and recognising the extensive and complex nature of the Egg Supply Chain, we endeavoured to map out and draw links among a diverse range role-players, including those involved in manufacturing poultry farming equipment and feed for chickens, those involved in breeding and rearing Layer Hens, those involved in egg production, and those who facilitate the sale of eggs or egg products to the public for consumption.
To map the role-players, we conducted extensive desktop research, and identified over 200 entities (playing diverse roles) involved in the Egg Supply Chain.
Our research revealed a vast array of role-players in the Egg Supply Chain from “fertilization to plate” and everything in-between. Whilst we identified over 200 role-players, our mapping was focused predominantly on identifying large Corporations (as opposed to smaller operations) involved in the Egg Supply Chain. This is because the activities of large Corporations potentially impact on the welfare of the most significant number of chickens and Chicks, given the size of their market share.
Given that our focus was on the Egg Supply Chain, and had the goal of identifying those Corporations who impact on animal welfare the most, or have the most influence on animal welfare, we grouped role-players as participating in three core stages in the Egg Supply Chain:
Having mapped out the Egg Supply Chain comprehensively, we were able to identify Selected Stakeholders with whom we would engage to obtain information for purposes of our Stakeholder Component.
Given the aims of our Initial Report, 36 (or 3 dozen) Selected Stakeholders were identified for rating in this Section IV of our Initial Report. Three selection criteria informed the identification of the Selected Stakeholders, namely: (a) size of market share; (b) Corporations identified by OWA as significant for their work; and/or (c) apparent popularity. Other role-players were identified as potentially meeting one or more of these selection criteria but are not reported on given the scope and time constraints in respect of our research. These include, but are not limited to, Country Bird Holding Ltd, Crown Chickens (Pty) Ltd, Alzu Ondernemings (Pty) Ltd, and Food Lovers Holdings (Pty) Ltd. We may report on these and/or additional role-players in future.
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Having identified 36 Selected Stakeholders, we set out to engage with them based on constitutional obligations owed by Corporations to everyone in South Africa pursuant to the horizontal application of the rights in the Bill of Rights. We invoked the right to access information to engage with the Selected Stakeholders on the basis that the information requested is required for the exercise and protection of the environmental right provided for in section 24 of the Constitution. We did so using PAIA, the legislation intended to give effect to the right to access to information. PAIA empowers those seeking access to information to complete requests for access to information and imposes obligations on those to whom requests are made.
With reference to Corporations’ PAIA manuals (where available), we drafted PAIA requests and dispatched these to the Selected Stakeholders. PAIA Requests were dispatched during the period from 16 November 2022 to 28 February 2023.
This Stakeholder Component only takes into account information provided or furnished directly to ALRSA as part of the PAIA process and subsequent correspondence (not information otherwise in the public domain). Information and documentation provided was not independently verified and no additional sources were consulted. Accordingly, the information that follows including the rating is informed by that which was supplied.
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.
In order to analyse and rate Selected Stakeholders on their efforts related to animal welfare, transparency, and accountability, alongside our stakeholder engagement, ALRSA developed 10 Rating Criteria, each with one or more Indicators against which to evaluate Selected Stakeholders, as set out below.
Based on the information we received from each Selected Stakeholder, and their correspondence with us, we then assigned a colour-rating to each Selected Stakeholder, namely, green, orange, red, and/or grey, as explained in more detail below. In essence, green was awarded to illustrate compliance on the part of a Selected Stakeholder, orange illustrates partial compliance, red illustrates non-compliance or a refusal, and grey indicates Non-responsiveness.
As set out in the table below, a colour-rating for each Criteria was based on the Selected Stakeholder being rated a particular colour for 50% or more of the Indicators relative to the relevant Criteria (e.g., a Selected Stakeholder would be rated green for Criteria 1, if they achieved a green rating for three or more of the six Indicators for Criteria 1, etc.).
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.