We are long standing members of the Ethical Trade Initiative. Our Responsible Sourcing Code of Practice (RSCOP) mirrors the requirements of the ETI Base Code and international labour conventions. RSCOP details what is expected of all our own-brand suppliers, including terms of pay and working conditions. We seek to build lasting relationships with our suppliers and are committed to upholding human rights throughout our product and services supply chains and only work with suppliers who share our values of fairness and respect for human rights and welfare. Where issues are found we work with our suppliers on remediation and offer them support, for example, as outlined in our Child Labour Remediation Best Practice guidance.
In our own-brand supply chains all tier one supplier factories complete a self-assessment questionnaire (SAQ) on Sedex to allow us to gather vital information for understanding working conditions at the site. Collecting this data enables us to make informed decisions about the level of further due diligence required, as the answers to the questionnaire are used to produce a risk rating of either high, medium or low. For General Merchandise supplier factories, high, medium and low risk sites require an audit every one, two and three years respectively. For Food and Grocery sites, only those classified as high or medium risk require a SMETA audit, every two years and every three years respectively.
Ethical audits are undertaken using an industry-wide and internationally recognised audit methodology, SMETA (Sedex Members Ethical Trade Audit). At a minimum we require a two-pillar SMETA audit that covers the nine key requirements of our RSCOP. We require all social compliance audits to be carried out by an Association of Professional Social Compliance Auditors (APSCA) certified auditor. APSCA is the professional standards body which certifies auditors’ competence and oversees the ethics and integrity of members, both audit firms and auditors. During the audit the auditor will note any good practice examples, plus observations and any non-conformances against the RSCOP. All non-conformances are given a criticality score of either minor, major, critical or business critical. Once complete, the audit is given a green, amber or red rating that determines whether the site is compliant with our Ethical Compliance Policy. Sites with a red-rated audit are non-compliant to our policy and considered in breach of the RSCOP. All sites, no matter the audit grading, must take corrective actions to resolve non-conformances within the timeframe specified on the audit. These actions are verified either online or in-person by the auditor to formally ‘close’ the nonconformances identified in the initial audit..
This process, alongside additional sources of information, such as in-country risk assessments, provide a valuable snapshot of our supply chain working conditions and helps us tailor our ethical trade programmes to address issues in high risk sectors and regions.
The goods suppliers we use for Goods Not For Resale (GNFR) provide products such as: IT hardware; hygiene materials; fork lift trucks and services such as advertising, photography and temporary agency workers. We have an internal supplier on-boarding team who verify that these suppliers have agreed to comply with RSCOP.
GNFR also includes services, and we have a programme of independent third party site based assessments, to assess the experience of our agency workers against the requirements of RSCOP. Where gaps are identified we will collaboratively address these with suppliers.
Despite our comprehensive due diligence programme, we recognise that systemic labour violations still exist throughout global supply chains, especially in situations when local law and its implementation does not adequately protect workers’ rights. Our policies and practices have a strong role to play in ensuring that workers in our supply chains have a positive, fair and safe work experience. Our policies are shared with our suppliers and their compliance against these is regularly reported. We support our suppliers to engage with various programmes such as our Better Jobs Programme, the Bangladesh Accord, the Pakistan Accord and ISSARA’s Strategic Partners Programme.