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Selected Stakeholders

Section III: Ruffling Feathers: Stakeholder Component

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.

Introduction

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.

Part B: Methodology and Process (High-Level)

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.

Stakeholder Selection

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.

  • Size of Market Share
  • OWA Global Cage-Free Campaign
  • Popularity: Well-known/ prevalent players/ familiar and iconic brands in ZA to the general public

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):

  • Whether the stakeholder is a Multinational Corporation with its headquarters in Africa or a presence in SA
  • Whether the stakeholder claims to have made a Cage-Free Commitment; and
  • Whether the Stakeholder presents itself as an entity that is sustainable / environmentally and/or animal friendly, and/or as being a responsible corporation, and / or being committed to health and social welfare, and/or consumers have the perception of them being any of these
 

Fast Food Outlets and Restaurants

13

Restaurant Brands International Inc. and its associated company Burger King SA (Pty) Ltd (Burger King)

Selected Stakeholder 13

Wholesalers and Manufacturers

15

Pioneer Food Group (Pty) Ltd (Pioneer Food Group)

Selected Stakeholder 18

Obtaining of Information

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.

Development And Application Of The Supplementary Rating Criteria And Indicators

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.

Our Colour Rating

Part C: Rating Of Selected Stakeholders

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:

Notes about specific Stakeholders

GOOD EGGS

  • KAUAI AND CITY LODGE
    During our stakeholder engagement and rating, only two of the 36 Selected Stakeholders stood out as demonstrating a reasonable commitment to animal welfare and Progressive Measures given Cruel Practices. Kauai evidenced that it sources free range egg products, providing proof of their suppliers’ free-range certification, which includes explicit reference to free-range egg sourcing, the rationale therefore, as well as potential health benefits related to free range eggs as opposed to cage produced eggs.
  • Although Non-Responsive in some respects, and despite being awarded a grey rating overall, Kauai’s transparency about sourcing free-range eggs, and general openness in their communications with us, renders them a “Good Egg”.
  • City Lodge was colour-rated green overall, due to their attitude to animal welfare, transparency and corporate accountability. Our engagements with City Lodge are exemplified by their statement:
    • There has been much discussion around the subject of Layer Hens and the environment in which they are kept, specifically in respect of whether the Layer Hens are kept in cages. Eggs that are not cage-free are often cheaper and are more easily sourced, but the conditions in which the hens are kept are unacceptable to City Lodge Hotel Group and to support the suppliers of non-cage-free eggs goes directly against the values of the group. Our guests demand food that is safe, healthy, and grown sustainably. We acknowledge public concern and the wishes of our guests and are determined to ensure that our product supply chain is ethical and transparent…In January 2020, the group publicly committed to only serving 100% cage-free eggs throughout its operations by 2025. We partnered with Humane Society International-Africa (HSI-Africa) on its journey towards offering eggs and egg products sourced in this way. City Lodge currently serves approximately 1.4 million eggs annually of which 55% are cage-free.

BAD EGGS

  • SPUR, ROCOMAMAS, NANDOS, PAPACHINOS, TIGER BRANDS, BAKERS, BID CORP, AFGRI, BIG DUTCHMAN, AND MEADOW FEEDS
  • Whilst 20 out of 36 Selected Stakeholders were awarded a red colour-rating overall, some stood out as particularly problematic in relation to their commitments to animal welfare, transparency and/or corporate accountability. These were deemed “Bad Eggs”. 
  • Spur, Rocomamas and Nandos threatened legal action against ALRSA should we mention them in our Initial Report and claimed that we needed their consent to report on their commitments to animal welfare, transparency and corporate accountability. They not only denied that ALRSA was entitled to
    request access to information, but also sought to impinge upon ALRSA’s right to freedom of expression in the public interest.
  • Tiger Brands and Bakers were forthcoming regarding their sourcing of egg-related products but denied any involvement in the Egg Supply Chain. Tiger Brands claimed that it does not source whole eggs and only sources powdered eggs, often with other ingredients, while National Brands Limited in
    respect of Bakers reasoned that they merely “purchase egg pulp and spray-dried egg albumen powder”. ALRSA finds it concerning that role-players in the Egg Supply Chain who purchase such egg products do not view themselves as having a role to play in advancing animal welfare issues, given that millions of chickens and Chicks are involved in the production of such egg products.
  • Bidcorp was the only Selected Stakeholder that requested a request fee in terms of PAIA (in the amount of ZAR140). ALRSA paid this fee despite requesting an exemption from this required fee as it is a non-profit organisation, only for Bidcorp, a major Corporation, to refuse access to any of the records requested on spurious grounds and with limited justification. Upon ALRSA making this payment, and providing further substantiation for our request, Bidcorp acknowledged receipt of the requested payment and undertook to respond to our request but did not do so beyond this acknowledgement.
  • AFGRI and Big Dutchman denied involvement in the Egg Supply Chain despite being the manufacturers and distributors of cages and feed. Big Dutchman made this denial despite conceding: “that the majority (approx. 90-95%) of our customers produce Pullets and eggs in our cages, with free range and barn eggs making up the balance, i.e. birds on the floor with feeding, drinking and nest boxes”.
  • Meadow Feeds: Meadow Feeds refused to provide access to the records requested in our PAIA request and denied any involvement in the Egg Supply Chain despite being “regarded as the market leader in the southern African animal feed industry” and producing “a variety of specialised diets and
    custom feed mixes for the livestock and game industries”, including for chickens. Instead of responding, Meadow Feeds stated that “ALRSA has not properly explained how the information being requested is applicable to Meadow Feeds’ business in the feed sector. This is despite ALRSA making it very clear that feed manufacturing has a direct bearing on the welfare of chickens, for instance with reference to the quality of feed.

Part D: Analysis in respect of rating exercise

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 statement made by a Selected Stakeholder available in the public domain and provided to ALRSA in response to a request for access to information in which it discloses its sourcing practices in respect of the Egg Supply Chain (as a distributor or user thereof) and/or its production system in respect of eggs (as applicable). It does not include statements not provided to ALRSA.

A Public Statement was viewed as “Comprehensive” if it:

  • addresses Progressive Measures and Cruel Practices of the Selected Stakeholder in detail, with full disclosure and the utmost transparency, for instance, not only disclosing Progressive Measures aimed at eliminating Cruel Practices, but also the extent to which the Selected Stakeholder remains complicit or a participant in Cruel Practices.

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.

Read Our Report

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