An Open Letter to Ian Moir, CEO of Woolworths
Dear Ian Moir,
Woolworths marketing and brand image has told South African consumers that you care about quality, social justice, animal welfare, the environment, and about your Woolworths customers. We have welcomed and supported your perceived move towards free-range, organic, healthier, ethically sourced and animal friendly products. Your values appeared to reflect our own, and we trusted what you said on your labels and marketing material.
So, for many it has been shattering* ( http://woolies-milk.weebly.com/letters-from-woolies-customers) to discover that some of your labels, signs, adverts, and articles are extremely misleading, and that we have been inadvertently purchasing food containing battery eggs, consuming milk from barn-based cows, and food which contains high percentages of unlabelled GMOs. An example of this chasm between our expectations and the reality was exposed with both your eggs and dairy proclamations.
Regarding eggs, Simon Susman announced in 2004 : “From now on, no Woolworths laying hen will ever have lived or spent any of her life in a cage.” Your in-store signs proclaimed: “we think our hens enjoy having space to behave like hens should.”
Yet despite these statements and the recent Good Egg Award received from Compassion in World Farming – battery eggs, to this day, continue to be used in your processed products.
Woolworths Ayrshire milk marketing consistently implies free-range and pasture-raised. Your TV advert showed Justin Bonello in a field with cows grazing, and your TASTE article stated : “Ayrshire herds…spend their days in tranquil green pastures with access to plenty of good food and fresh, clean water”
Yet it turns out that only 50% of Woolworths Ayrshire cows are pasture-raised, while the other 50% of the cows live in barns for most of their lives, where they are fed GMO feed*. (http://wp.me/p3f3uo-ef)
Woolworths’ Organic milk label said : “Produced from cows that roam freely and graze in organic pastures.” The Woolworths Dairy Team admitted that this is not true either. These cows live and are fed inside barns for most of their lives too.
How can there be such a large discrepancy between what Woolworths says and what Woolworths does? And in light of these examples, going forward, can customers really believe anything that Woolworths says? This continual misleading greenwashing and bait marketing of your food products also undermines the farmers who do achieve higher animal welfare standards and are able to substantiate animal welfare and enviromental label claims.
In this regard we would like to challenge you, as a retailer who has built an image of a company selling high-quality, premium-priced foods where good animal welfare is paramount, to do two things:
a) Apply the high ethical standards that are reflected in Woolworths marketing and brand image, throughout the entire product lifecycle, and not just at the final presentation phase.
b) Be completely transparent, accountable and honest with customers in your labels and advertising.
As the CEO of Woolworths, we ask that you address these issues of integrity in a timeframe to be agreed to restore the broken trust in Woolworths.
Since the current food processes and marketing do not meet consumer expectations, please address the following:
Please refrain from using self-made claims, where there is no legal or regulated definition, such as “no added MSG”, “no additives”, “no animal by-products”, “free range”, “free to roam”, “pastured/pasture-raised”, “rBST free”, “natural” etc. Woolworths have a responsibility for substantiating these claims and therefore third party verification or published detailed protocols and policies thereof, in particular Farming for the Future protocols on ALL farming criteria must be provided.
All detailed protocols (such as references to beak trimming, tail cutting, disbudding, dehorning, calf care, hormones fed, antibiotic use etc, to be published on Woolworths website, where applicable also to specify the number of annual independent audits to obtain third party certification and a link to the certifiers transparent and detailed protocols.
1) The following is a list of examples where we feel you are failing to achieve standards of integrity:
(the definition of a good label is one that meets the following five criteria: 1) meaningful, verifiable standards; 2) consistency of meaning and of the verification process; 3) transaprency, including the public availability of protocols or standards; 4) independence from users of the label by the third party verifier; and 5) opporutunity for public comment.
a) Should therefore inform us accurately about how a product was farmed –
1. organic: third party verification must be supplied and detailed protocols published; (in general, organic production limits use of chemicals, pesticides, hormones, antibiotics etc. All organic animals must be pasture based, living as natural a life as possible. Consumers expect Woolworths to follow global best practice with regard to organic standards, such as those developed by the Soil Association. It is crucial that these protocols are made available on the Woolworths website at all times, so that consumers can make certain they reflect what consumers want, and don’t become dumbed down over time.)
2. barn-raised: If an animal does not spend the majority of its life in pasture then they are barn-raised and not free range. Detailed published protocols must be provided; (such as inside stock density and outside stock density, that there is suitable vegetation in the outside area; along with the number of hours per day if any, animals have access to outdoors through doors or pop-holes; what percentage of ruminants feed is grazing on pasture grass vs GMO grain; does debeaking take place; have animals undergone genetic selection to the point that their welfare is negatively affected such as some broilers being unable to stand etc)
3. free-range: detailed published protocols must be provided (such as do ruminants have continual outdoor access to pasture or instead to dirt lots; non-therapeautic use of antibiotics such as for the purpose of promoting growth or overcoming disease challenges that are inherent in the system of farm management; are animals fed supplement GMO grainfeed; outside range (stock density). For example, free range’ eggs must come from poultry that have ready access to an attractive grassed range area during every day that provides them with shade, shelter, and protection from predators.)
4. pasture raised; detailed published protocols must be provided (such as do animals walk on pasture and graze or is pasture cut and provided for them in barns; what percentage of feed is pasture; use of non-therapeautic antibiotics such as for the purpose of promoting growth or overcoming disease challenges that are inherent in the system of farm management, grain supplement food provided,etc)
5. free to roam: detailed published protocols must be provided (such as do animals walk on pasture and graze or is pasture cut and provided for them in barns; what percentage of feed is pasture; use of non-therapeautic antibiotics such as for the purpose of promoting growth or overcoming disease challenges that are inherent in the system of farm management, grain supplement food provided,etc)
6. grassfed: detailed published protocols must be provided (such as are animals fed in barns and have outdoor access to dirt lots, what percentage of feed is pasture; are animals fed supplement GMO grainfeed; non-therapeautic use of antibiotics such as for the purpose of promoting growth or overcoming disease challenges that are inherent in the system of farm management, etc)
7. factory farmed: detailed protocols must be provided (such as where animals are kept and raised in confined situations; stock density; use of sow stalls or farrowing crates in the case of pigs; feedlots where animals are kept in dirt paddocks and either grassfed or grainfed; are animals fed GMO grains, etc). This includes caged egg production.
b) Country of origin or geographic region to be on label.
c) All labels should accurately state which preservatives, emulsifiers, colourants, flavour enhancers, or additives etc were used. (eg. current regulations makes provision to chemically treat the breast meat of a whole chicken carcass via injection – chemicals need to be stated)
d) All labels should accurately state any processes that food has undergone such as UHT, pasterrsation (including eggs), food that has been irradiated must either have ‘irradiated’ as part of the product name or labeled with the claim “treated with irradiation” and also display the Radura symbol. This includes processed foods and not only whole irradiated fruits and vegetables.
e) Labels to accurately display all ingredients used which should not differ from FOP claims (e.g. Kudu Biltong FOP claim cannot contain Beef unless stated on FOP too).
f) Products which contain 0.9% or more GMO should be labeled accordingly and not just state “may contain GMO”. By choosing not to label GM accurately, Woolworths actively works against the future viability of segregated supply chains. (In Germany meat and dairy from non-GM fed animals is now labeled, and Carrefour in France has taken this move voluntarily).
g) GMO animal feed, when used, should also be stated.
h) Where antibiotics or growth hormones (such as rBST and the synthetic version rBGH) have been used in the production of a product, the label should declare it.
i) The term ‘fresh’ only to be used on products not previously frozen (example Woolworths fresh fruit salad contained previously frozen mangoes).
a) Consumers to have access to your detailed published protocols of ALL animal care standards, including slaughter review assurance, via the Woolworths website. Instore informational materials on ALL proclaimed terms to be available to consumers.
b) Consumers to have access to your detailed published protocols and information on environmental claims such as palm oil use.
2) As a means to achieving the above, we ask that you check every product that Woolworths sells, and ensure that it delivers on what the label, in-store signs, marketing and Woolworths brand promise. If it does not, then please change the practice, not ONLY the label.
For example :
a) Only use “free-range” eggs in Woolworths food, don’t simply remove the sign.
b) When customers queried Woolworths’ Organic milk label, you changed it from: “Produced by cows that roam freely and graze on organic pasture” to “Produced from cows that feed on organic feed.” This is completely unacceptable! Please change the practice, not the label.
3) South African Pork industry standards are lower than EU where sow stalls were made illegal in the UK in 1999 and the rest of Europe in 2013. Please offer Woolworths’ customers the choice of purchasing pasture-raised pork.
Woolworths recently announced that sow stalls will no longer be used for fresh pork products, but have provided no other details, therefore, please provide consumers with detailed protocols of pig farming for Woolworths stores– such as but not limited to:
Are pregnant sows to be kept in groups and managed in a way that promotes a stable social order?
How long with will sows remain in farrowing crates?
Will sows be provided dry bedding that the sow can manipulate?
What is the size of the farrowing crate per sow and litter?
After sows have farrowed, will sows and piglets over the age of 10 days have free access to a ranging and foraging area (the area) outside the housing?
Do pigs have any access to pasture, for dunging, feeding, wallowing and foraging?
What age will piglets be weaned?
Details of immunocastration and other forms of chemical (synthetic or natural) castration or testosterone production imiting methods.
Details of clipping, grinding or filing of the needle teeth of piglets.
4) Kindly make Woolworths animal welfare policy available to customers; at present it is not.
5) Follow best practice with regard to animal and environmental welfare and human health issues. With regard to organic, that would mean adhering to the standards of the Soil Association, which are widely accepted to be best practice. Currently Woolworths adhere to EU standards, which are widely accepted to be minimal and not best suited for South African climate.
6) Insist on best practice from your suppliers:
a) Free-range products should be genuinely so. This means that all free-range hens, cows, sheep and pigs should spend the majority of their lives IN pasture, or large outside fields, and be able to feed outside on suitable growing vegetation.
b) Free-range animals should not be kept in feedlots at any stage of production.
c) Stocking density in barns for all animals (and during bad weather for free-range animals) must be low enough to allow animals to express natural behaviour. This density level should be made known to, and be acceptable to, Woolworths customers and not just to farmers or auditors. Stocking densities in the EU are being tailored to meet consumer demand. There is no reason why SA cannot improve on this trend.
d) Woolworths farmers should provide trees (preferably indigenous as this is something that could contribute to Woolworths environmental policy as most people recognise the value in planting trees) for shade for animals in pasture or use breeds that are adapted to our hot summers.
e) All mutilations must be avoided by better farm management. In a situation where it is for some reason absolutely essential, painful procedures should never be performed without a veterinarian being present, to administer anaesthetics and analgesia. Currently Woolworths dairy calves are disbudded without an anaesthetic, causing needless pain and suffering to these young animals. This is not something which Woolworths customers expect or want from your products.
f) Currently Woolworths dairy calves are removed at 3 days old; this causes extreme distress to both mother and calf, and it is, not what Woolworths customers expect or want from your products. Ensure that all Woolworth’s dairy calves remain with their mothers in the herd, suckling for a minimum of 3- 6 months, until they are gradually weaned, but not before they are taking in adequate solids. (At the very least, they may be weaned by a nurse mother until 4-6 months, but must not be removed from the mother until 3 weeks of age or until the rumen develops). Calves must not be kept in isolated pens, but be allowed to roam & graze in groups during the day, with a nanny cow, and sleep in groups inside barns or when the weather is bad. Male calves should be raised in natural conditions on the farm on which they were born.
g) Woolworths should establish a policy for the “humane” slaughter of day-old male chicks with your egg farmers, or explore using breeds of chickens where male chicks can be raised as broilers, or capons.
h) Transport and slaughter of all animals should be overseen by Woolworths and monitored by CCTV camera so that customers can be certain of best practice.
i) Woolworths should not support farmers who use lethal methods of predator control, such as gin traps, poison, hunting dogs, etc. Woolworths must live up to its claims about both animal welfare and care for the environment by supporting farmers who use environmentally friendly, and non-lethal methods of predator control in caring for their flock.
j) Woolworths currently sells fish on the orange list; Woolworths should make a commitment to cease from selling orange-listed fish or provide detailed protocols and third party verification. Kindly adhere to the SASSI labelling technique and not the Woolworths adapted signs – this is confusing to South African consumers since an industry standard has been set by SASSI – please comply to it.
k) Woolworths should not support fisheries that contribute to environmental destruction by, for example, over-fishing, destroying the ocean environment (e.g. bottom-trawling), killing many non-target species (“bycatch”), including but not limited to other fish, turtles, dolphins, birdlife etc.
7) Please appoint independent assessors to monitor animal welfare standards, and make their findings and contact details accessible to Woolworths customers.
8) Please listen to your customers, we are vital stakeholders in your business and should not be ignored.