About the company

Since its foundation in 2013, C Food Norway has been a pioneer in utilising residual raw materials from whitefish to provide consumer products. We have built up a business model based on developing and selling residues from Norwegian cod, saithe, ling and tusk for food.

Making better use of resources is one solution for increasing global food supply. Residues regarded as unappetising in Norway and the west are considered delicacies in other countries and cultures. We therefore see a big unexploited potential for Norwegian whitefish, which are a limited and valuable resource. Our vision is to develop more food from existing wild and farmed supplies of these species, and our business model will help to improve resource utilisation, reduce food waste and increase output of nutritious seafood. This is in line with several of the UN’s sustainable development goals.


Our head office is in Ålesund, and we have two owners in Norway and one in Hong Kong. We have six employees with broad experience of sales, product development and research in the seafood business. Our company has its own R&D department.

Value chain

We have built up a robust logistics and production chain for residual raw materials from whitefish. Our suppliers are primarily Norwegian trawlers, longline fishing boats, fileting plants and producers of dried and salted cod, but we also buy from foreign sources. Some of our products are processed today in Vietnam, China, Portugal and Spain. An overall goal is to establish further processing in Norway as automated solutions are developed.

Market and products

Our principal activity has been processing and sale of dried cod swim bladders to China. We also have regular sales of fish meat from residues to European processors. Processed fish heads are sold to both European and Asian seafood markets. Together with strategic partners, we are working to develop health food products from residues. We produce pet food sold in Asia and the USA.

Requirements for our own business.

We see a window of opportunity to ensure a sustainable and responsible value chain through dialogue, collaboration and setting requirements. We recognise that the value chain contains challenges, and undertake to work purposefully to address these through due diligence checks at least once a year. This commitment will be entrenched at board level in 2023 as part of our goal for the work.

“Due diligence is the process where we identify risk in the value chain, implement measures to handle possible risk, and monitor whether these measures function.”

Due diligence.

Our starting point is the recommendations and structure defined by the OECD for due diligence. The main aim of our first due diligence check has been to identify where in the value chain the biggest risk of negative impacts is to be found, and what type of risk is present. Four of our six employees have contributed to this work, including the CEO, chair, logistics coordinator and R&D manger, in order to ensure broad entrenchment internally.

Selection criteria.

The due diligence check covers our largest suppliers, which collectively account for 80 per cent of our total procurement. The sample encompasses all the areas where we have business contacts – south-east and central Asia plus Europe. Measures were prioritised on the basis of order size, which says something about the scale of possible negative impacts and about the geographical scope of these effects for assessing risk types and their seriousness.

Risk assessment.


We have assessed risk among international suppliers on a geographical basis, and have used indicators for corruption, civil rights, expected years in school and percentage of children in primary school from the UN’s statistical database. The production stage of the value chain and certain countries where production occurs were assessed here to be more exposed to risk than others.



A large proportion of our suppliers are located in Norway. The e-insight service has been used here to identify possible deviations from the provisions of the Norwegian Working Environment Act. We have identified and investigated unclear conditions at our largest Norwegian suppliers (orders greater than NOK 1 million). A dialogue was established with companies where conditions were unclear, and no conditions have been found which breach our code of conduct. We will nevertheless follow up unclear conditions.

Code of conduct and supplier agreements

During the due diligence check, requirements were identified for improved supplier agreements and updated internal and external codes of conduct. A new policy and supplier agreement between us and our business partners has therefore been established. Remediation of possible damage/negative impacts is part of our code of conduct.

Internal entrenchment

A majority of our employees have participated in work on the due diligence check. Our goal is nevertheless to ensure formal entrenchment of policies (board decisions) in July 2023, and external entrenchment (contracts) with selected suppliers during 2023.

Dialogue and complaints procedures

We have established a goal that our code of conduct will be accessible to everyone working at factories utilised in our production by the end of 2023. The code must be accessible and visible in the local language.

Dialogue with suppliers is conducted today via e-mail, phone and physical/virtual meetings. We will consider more extensive whistleblowing channels in consultation with suppliers.



Several audits were conducted at a subcontractor in Vietnam during June 2023. Their aim was to identify negative impacts/conditions, including child labour and illegal overtime, which would have required further measures by us. An agreed audit (daytime) was conducted, plus two unannounced visits (evening) to assess whether children were present, and to what extent the factory operated outside normal working hours. This was not the case at the relevant times.


Expected effect

Audits can have a temporary effect in sharpening up the individual supplier. We expect that the effect of a single audit will not be long-lasting, but that the combination of new supplier agreements, open dialogue and regular audits will create engagement and dialogue and will contribute in the longer term to improved working conditions at suppliers. After the audit, we have concluded that more regular and frequent audits require tools and routines for follow-up.

Further work and identified measures.

Although no conditions with negative consequences or breaches of human rights or our code of conduct were identified during the risk assessment or audits, we recognise that a risk nevertheless exists for negative conditions at suppliers. We will therefore work continually to ensure a responsible supplier chain.

We have defined the following measures for further work:

  • Entrench the guidelines internally (board decision in July 2023)
  • Establish new supplier agreement and code of conduct for suppliers
  • Translate guidelines for employees and make them available (at suppliers)
  • Investigate and consider adopting reporting tools for audits
  • Extend due diligence checks to more markets and countries, and define measures in consultation with suppliers
  • Measures will be taken in the event of breaches of our code of conduct by suppliers.

Minimum requirements in the Act we must say something about:

  • Whistleblowing channels and complaints procedures which will help to identify negative consequences