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Our Group Supplier Code of Conduct is the foundation of our businesses’ work with respect to working conditions and labour standards in their supply chains.
A farmer near Eminabad, Pakistan, growing basmati rice for Westmill Foods to the Sustainable Rice Platform Standard
Our businesses work with a diverse range of suppliers from large businesses to smallholder farmers.
Our Group Supplier Code of Conduct is an essential requirement of the responsible business conduct of our businesses. This Code is based on the core conventions of the International Labour Organization and on the Base Code of the Ethical Trading Initiative.
In their application of the Group Supplier Code of Conduct, many of our businesses continue to develop and improve human rights due diligence processes. Some of them are guided by the United Nations Guiding Principles on Business and Human Rights (‘UNGPs’), the Organisation for Economic Co-operation and Development (‘OECD’) Due Diligence Guidance for Responsible Business Conduct, and the ILO Decent Work Agenda.
Our devolved business model requires each of our businesses to adopt approaches based on their specific supply chains and the nature of their supplier relationships. Assessing where potential negative human rights risks and impacts might exist, combined with supply chain mapping, helps some of our businesses identify, monitor and, where applicable, manage risks and impacts related to workers and communities in the supply chain.
Our businesses use a number of platforms to help assess and monitor potential human rights risks including the Verisk Maplecroft’s risk assessment tool, which provides country risk data for 150 commodities, the Sedex (Supplier Ethical Data Exchange) online platform and EIQ, the risk assessment tool from LRQA, which covers social and environmental risks for countries and a range of commodities. In some of our businesses, risk monitoring is conducted through audits carried out by internal teams or third parties. Some businesses also engage workers and their representatives directly outside of the audit process to understand what issues they face.
For example, Primark’s ETES team has over 130 people predominantly based in 10 of its key sourcing markets. The work of the team ranges from risk assessment to supporting suppliers and their factories in implementing the Primark Supplier Code of Conduct. Where inherent risks and more systemic issues are identified, Primark works with suppliers and their factories, as well as with partners and other brands, to support suppliers to address these issues through longer-term solutions and projects.
Primark’s Ethical Trade and Environmental Sustainability (‘ETES’) programme is one of the key elements of how human rights due diligence is implemented in its product supply chains. Through this programme, Primark conducted over 2,300 Supplier Code of Conduct audits in its suppliers’ factories over the calendar year 2025. Primark carries the full cost of these audits, which include rigorous checks for human rights issues against the requirements of the Primark Supplier Code of Conduct, based on first-hand assessment of the working environment, reviews of relevant documentation and confidential worker interviews. At the end of each audit, supplier factories are issued with a time-bound corrective action plan that outlines any areas for improvement. Primark uses these audits in the approval process for all new tier one factories1. Any potential new factories are audited and only if the outcome of the audit is satisfactory can any orders be placed.
1.Primark tier one: factories manufacturing finished goods.
A tea worker at a tea estate in Assam, India
The chief executives and senior leaders of each business are accountable for managing risks related to human and labour rights in their businesses' supply chains.
The Group Supplier Code of Conduct underpins any relevant policies that our businesses may choose to follow. Twinings Ovaltine, Primark and ABF Sugar have also developed their own human rights policies based on the Group Supplier Code of Conduct.
Our businesses seek to use the leverage they have with their suppliers to cease, prevent or mitigate the risk of negative human rights impacts on workers in their supply chains, where appropriate. Some of our businesses have or are developing grievance mechanisms to give workers a voice on the issues they may face in the workplace. Others make it a requirement that such mechanisms are present in the workplaces of the suppliers they work with. Primark has multiple approaches to achieving effective grievance mechanisms. As a result, in Bangladesh, India, Türkiye and Pakistan, workers’ grievances are routed to specific grievance mechanisms run by local implementation partners such as non-governmental organisations (‘NGOs’) or unions. For example, the Amader Kotha Helpline in Bangladesh provides workers in supplier factories with confidential and accessible means to raise concerns. Where issues are raised through grievance mechanisms linked to our businesses, they will endeavour to follow up and investigate accordingly, with the interests of those affected front of mind.
Different stakeholders including NGOs, trade unions, governments, other businesses (subject to relevant competition and anti-trust laws) and industry bodies such as AIM-Progress, provide inputs into the approach adopted by some of our businesses on human rights due diligence. They work with these organisations due to their expert knowledge and we acknowledge the value that their contribution brings.
Transparency about where our businesses source from, and from whom, is essential to their understanding of human rights risks and, where necessary, enables collaboration to resolve issues both locally and across the industry.
Twinings and Primark both publish sourcing maps to help their customers and other external stakeholders understand their supply chains better.
Alongside their work to respect human and labour rights in their supply chains, some of our businesses aim to positively contribute to the communities in which they operate or from which they source. For instance, our sugar businesses in Africa recognise that their sugar estates are a key part of the surrounding community. This is reflected in their activities to support those communities, such as providing clinics, schools and local services to support some of their workforce, and in certain cases the wider community and surrounding neighbours. In 2026, some of our sugar businesses in Africa continued to invest in several community support projects across their operational areas. These initiatives focused on helping provide access to potable water, offer natural disaster relief, improve healthcare, advance education and develop infrastructure.
A pump station provided by Illovo Sugar Malawi to supply potable water to communities outside the Nchalo estate.
