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All of our businesses operate within a clear governance framework defined by the Group. Our devolved business model gives businesses autonomy to manage their own ESG impacts, risks and opportunities within this framework. We adapt our governance process as required to cover all relevant ESG issues, including climate change.
The ABF Board (the Board) has oversight and overall responsibility for ESG across the Group, including climate-related matters. The Board holds our businesses accountable for their management of ESG impacts, risks and opportunities, which includes an annual review of material ESG matters. The Chief Executive and Finance Director have responsibility for assessing and managing material ESG matters across the Group, including in relation to climate change, and reporting this to the Board.
In carrying out its duties the Board is also supported by:
The Corporate Responsibility Hub (CR Hub) is a central resource available to all of our businesses, which provides guidance and support on environmental and social issues. It facilitates a network that brings together professionals across the Group working in these areas so that expertise, experience and best practice can be shared.
From this year, the Finance Transformation team which is part of the Group Finance team also oversees all non-financial data reporting, collaborating closely with the CR Hub to ensure timely and accurate reporting. It coordinates with other finance teams within the businesses across the Group to ensure robust and consistent data collection aligned with assurance requirements. Additionally, dedicated teams covering specific areas such as DEI, health, safety, environment and procurement, ensure the businesses have a comprehensive level of support across ESG matters.
The Board receives regular updates each year on material ESG matters, including climate-related matters. This year these included updates on the following:
In addition to these regular updates, in October 2023, two Non-Executive Directors Dame Heather Rabbatts and Annie Murphy spent time with our Group Corporate Responsibility Director visiting the Primark Cotton Project in India to see the social and environmental impacts of the programme.
Since 2022, we have included strategic ESG key performance indicators (KPIs) in our short-term incentive plan (STIP) for executive directors. We report to the Remuneration Committee on progress against these KPIs three times each year. The measures that applied this year, and how we assessed progress against them, are disclosed in the Directors’ Remuneration Report in our 2024 Annual Report.
This year, we have further strengthened our governance of ESG matters by creating an ESG Policy and Reporting Group. This Group meets regularly and is responsible for overseeing the ESG reporting strategy, for allocating resource, prioritising activities, and reviewing Group ESG reporting or policy as needed. This Group is supported by subject matter experts (SMEs) across the Group as required.
Under ABF’s devolved structure, each of our businesses is required to understand its material ESG impacts, risks and opportunities, and is given the independence to put in place the necessary measures and policies that it believes will effectively manage such matters.
In addition to individual business leaders, divisional chief executives are accountable for their businesses taking the appropriate action in relation to ESG impacts, risks and opportunities, including assessing, managing and mitigating the impact of climate change on their businesses.
Across most of our divisions, ESG measures are part of the personal objectives of the divisional chief executives, with appropriate KPIs to reflect the nature of their business. In addition, since the start of this financial year, all Primark directors have ESG measures for a significant part of their short-term incentive performance targets.
Divisional management presents quarterly to the Chief Executive and Finance Director on business performance including relevant material ESG issues and where appropriate on significant climate-related matters. They have also other regular touch points with the Chief Executive where these matters are also discussed as needed. Additionally, the operating businesses periodically present significant ESG matters to the Board.
Identifying, assessing, and managing ESG risks and opportunities resides with the business where the risk or opportunity sits. This is the same process for all other business risks. Annually risks are collated and reviewed at the individual business and divisional level.
The Board is accountable for risk management, which includes agreeing the principal risks facing the Group, both existing and emerging, and ensuring these are successfully managed by the businesses. Further details on risk management can be found in our Annual Report.
We recognise that climate change presents a material risk throughout our businesses’ operations and supply chains, resulting in challenges as well as opportunities for our businesses. While each business is responsible for identifying and managing its climate risks, we also undertake an annual risk assessment at Group level, which covers climate risk. Individual businesses may also include climate-related matters in their regular updates to the Board. Divisional chief executives are responsible for managing and mitigating the impacts of climate change on their divisions.
Our Task Force on Climate-related Financial Disclosures (TCFD) reporting is overseen by a cross-functional steering committee, which briefs the Board and the Audit Committee. As part of this year’s disclosure, we have included a summary of transition plans for the Primark and ABF Sugar businesses, our top contributors to Scope 1, 2 and 3 emissions. For more information on our TCFD reporting, see our 2024 Annual Report.
We maintain and keep under review a series of group-level policies and position statements. Ranging from Health, Safety and Wellbeing, Environmental, Animal Health and Welfare, and Board Diversity (which also applies to the Group approach to DEI) to our Supplier Code of Conduct, our policies and position statements articulate the Group’s requirements and set expectations for the actions of our businesses, employees, suppliers and partners. It is the responsibility of the chief executive of each business to ensure that the business is compliant with both relevant legislation and Group policies.
Our Group policies, position statements and Supplier Code of Conduct can be accessed online.
Our approach to governance is to respect not simply the letter, but also the spirit, of our Anti-Bribery and Corruption Policy and always act with integrity. To ensure the effective implementation of our policy and procedures, each business has its own designated Anti-Bribery and Corruption Officer and we have monitoring systems in place at various levels within the Group including global risk assessments. In addition, all relevant employees are required to complete an e-learning course on the subject when they join the Group and at regular intervals thereafter, and those who work in higher-risk roles are required to attend regular face-to-face training. A copy of the policy is available online.
We are committed to always acting with integrity. We proudly promote and protect a culture of trust, fairness and accountability. Our Speak Up Policy empowers our people to raise a grievance or tell us whenever they encounter anything inappropriate, improper, dishonest, illegal or dangerous and ensures that their concerns will be handled confidentially and professionally. Speak Up includes both a telephone line and a web reporting device, managed by an independent provider.
We encourage all individuals working for the Group, in any of our businesses, in any country and in any capacity, to use Speak Up, including employees at all levels, directors, officers, part-time and fixed-term workers, casual and agency workers, seconded workers and volunteers. Speak Up also enables issues to be raised by third parties.
In the year to 30 June 2024, 276 notifications were received, of which:
A copy of the ABF Speak Up Policy is available online.