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Our businesses work with a diverse range of suppliers from large businesses to smallholder farmers. They recognise the importance of the United Nations Guiding Principles on Business and Human Rights (UNGPs) and their guidance on human rights due diligence processes.
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 (ILO) and on the Base Code of the Ethical Trading Initiative.
In their application of the Group Supplier Code of Conduct, our businesses continue to develop and improve human rights due diligence processes. Some of them are guided by the UNGPs, the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidelines for Responsible Business Conduct, and the ILO Decent Work Agenda.
Our devolved business model enables each of our businesses to adopt tailored risk-based approaches based on their specific supply chains and the nature of their supplier relationships. Assessing where potential negative human rights impacts might exist, combined with supply chain mapping, helps some of our businesses to identify, monitor and where they can address actual issues, to seek remedies, or even anticipate and prevent issues before they arise, prioritising those that are most salient.
Our businesses use a number of data platforms to assess and monitor potential human rights risks. For example, most of our Grocery businesses monitor their supply chains and engage suppliers through the Sedex (Supplier Ethical Data Exchange) online database. 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 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 2,000 social audits over the last year. Primark carries the full cost of these audits, which include rigorous checks for human rights issues and 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 factories. Any potential new factories are audited and only if the outcome of the audit is satisfactory can any orders be placed.
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 and Primark have also developed their own human rights policies, and our sugar businesses in Africa have their own Code of Conduct and Business Ethics policy.
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. Some of our businesses have or are developing grievance mechanisms to give workers a voice on the issues they face in the workplace. Primark has multiple approaches to achieving effective grievance mechanisms. As a result, in Bangladesh, India, Turkey and Pakistan, workers’ grievances are routed to specific grievance mechanisms run by local implementation partners such as NGOs or unions. For example, the Amader Kotha Helpline in Bangladesh provides workers in garment factories with a 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 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 who and where our businesses source from is essential to our understanding of human rights risks and, where necessary, enables collaboration to resolve issues both locally and across our industry.
Twinings and Primark both publish sourcing maps to help their customers understand their supply chains better.
Alongside our work to respect human and labour rights, some of our businesses aim to positively contribute to the communities in which they operate. For instance, our sugar businesses in Africa recognise that their sugar estates are a key part of the communities where they operate. This is reflected in their activities to support those communities, such as providing clinics, schools and local services to support their workforce, and in some cases their communities and surrounding neighbours. This year, our sugar businesses in Africa invested in several community support projects across their operational areas. These initiatives focused on providing access to potable water, offering natural disaster relief, improving healthcare, advancing education, and developing infrastructure.