Private Label Sustainable Seafood Procurement Policy

At Southeastern Grocers Inc. (“SEG”), parent company and home of Harveys Supermarkets and Winn-Dixie grocery stores, our mission is to consistently provide delicious, high-quality fresh and frozen seafood that is responsibly sourced and affordable.

Our commitments and expectations for all private label seafood suppliers are outlined in the below procurement policy. The steps we take to support our mission include:

1. Evaluating our offerings
2. Conveying social compliance expectations to our direct and indirect suppliers
3. Labeling
4. Setting product accuracy expectations with our direct and indirect suppliers
5. Partnering with industry leaders
6. Advocacy efforts
7. Traceability

As sustainability in seafood continues to evolve, we will modify and update our procurement policy to ensure we are taking the appropriate measures to conserve marine ecosystems and the world’s fish populations.

1. Evaluating our offerings:
   Farm raised:
   • All of our farm-raised seafood is certified by a Global Sustainable Seafood Initiative recognized program or, for catfish, by the USDA.
   
   Wild caught:
   • We expect our wild-caught fisheries to:
   • Exclude illegally caught fish
   • Review sourcing of endangered fish species in accordance with the International Union for Conservation of Nature (IUCN) Red List of Threatened Species (Vulnerable, Endangered, Critically Endangered)
   • Exclude the use of especially critical catchment methods (e.g., dynamite, poison)
   • Avoid fish stocks from critical catchment areas
   • Reduce bycatch
   • Minimize impact on the ecosystem
   • Maintain abundant, well-managed fish populations
   • Improve traceability throughout the entire supply chain
   • Comply with minimum social standards on all levels of the supply chain
   • During procurement decisions we evaluate Marine Stewardship Council (MSC) certified wild-caught seafood and seafood from suppliers participating in a fishery improvement project (FIP).
   
   Tuna:
   • Shelf stable – we expect our suppliers to:
   • Supply dolphin-safe tuna – 100% of SEG’s tuna is dolphin safe
   • Be green or yellow rated by the Monterey Bay Aquarium’s Seafood Watch
   • Prohibit transshipment at sea without observer coverage
   • Not source from vessels associated with illegal, unregulated and unreported (IUU) fishing identified on IUU lists published by the Regional Fishery Management Organization (RFMO)
   
   Fresh tuna:
   • We will evaluate tuna from fishing vessels registered to the ProActive Vessel Register (PVR) and from suppliers that encourage longline vessels register to the PVR
   • We expect tuna suppliers to meet or work toward our wild-caught expectations (above)
   • We will request suppliers disclose their catch methods
   
   Banned species:
   • Due to the sustainability threats that arise when fishing the below species, we do not sell:
   • Bigeye tuna
   • Orange roughy
   • Shark
   • Monkfish
   • We will continue to monitor whether other species should be included on this list.
2. Conveying social compliance expectations with our direct and indirect suppliers:
   We expect all suppliers to abide by all local laws and regulations. We also expect our suppliers to respect international human rights standards, specifically:
• The Universal Declaration of Human Rights
• The International Covenant on Civil and Political Rights
• The International Covenant on Economic, Social and Cultural Rights
• The International Labor Organization’s Declaration on Fundamental Principles and Rights at Work


3. Labeling:
   We expect all suppliers to provide the method of catch and country of origin to label all products appropriately.


4. Setting product accuracy expectations with direct and indirect suppliers:
   We expect all suppliers to be able to confirm the accuracy of the products we buy and will request DNA or species identification analysis from suppliers or third parties, when necessary.


5. Partnerships with industry experts:
   Collectively, with our direct and indirect suppliers, we work with the leading organizations to demonstrate our commitments to the sustainability and social responsibility of the seafood sector, including but not limited to:
• The Global Aquaculture Alliance (GAA) to ensure our farm-raised seafood suppliers are adhering to the Best Aquaculture Practice (BAP)
• The Sustainable Fisheries Partnership (SFP) serves as our main sustainable seafood collaborator
• The Marine Stewardship Council/National Marine Fishing Service to certify and manage sustainable practices
• World Wildlife Fund to determine sustainable fisheries


6. Advocacy efforts:
   We will look for advocacy opportunities that support transparent and sustainable seafood supply chains and human rights.


7. Traceability:
   We expect our suppliers to be able to trace the origin of seafood down to the vessel of origin when requested.

Southeastern Grocers supports the advancement of sustainability in the seafood industry and will work to safeguard the ocean’s vital ecosystems. If there is a suspected violation of this policy or laws, promptly report to esg@segrocers.com.