pg. 20

'As part of our audit and monitoring programme, we assess the risk of modern slavery in line with our Code of Conduct at firsttier sites both before any Primark production is placed and then on a regular basis (at least annually). All Primark audits are unannounced, apart from the initial pre-production assessment of new sites. COVID-19 has meant that we were unable to consistently audit all sites in our supply chain this year.

All Primark audits include rigorous checks for forced and trafficked labour including a review of relevant documentation, confidential worker interviews, visits to associated production facilities and worker accommodation if provided by the factory. Where our assessments or third-party allegations highlight an extreme risk of forced labour in our supply chain, we work with experts to conduct deeper dive audits which employ worker-centric and forensic auditing techniques. This approach was developed during supply chain investigations into migrant labour in a factory in Malaysia in 2018. We use the ILO indicators of forced labour as a reference within our audit process. We follow SMETA best practice guidance on the number of workers interviewed and our internal auditors are trained to SA8000 standards.

We may also conduct worker interviews off-site if we deem it necessary and may use support from NGOs or other experts. Child labour is a zero-tolerance issue and strictly prohibited in the manufacturing of our products. Within our audit programme, we check that workers meet the minimum age requirements set out in our Code of Conduct. Only when the Ethical Trade team is satisfied that our standards are met do we permit production to start. We then continue to monitor and check our suppliers’ factories on a regular basis (at least annually). After each audit, the supplier’s factory is given a corrective action plan (CAP) which outlines the areas for improvement. Each item in the CAP is timebound and the CAP contains practical guidance to help suppliers implement the recommended action. We verify implementation of the CAP through on-going monitoring including spot-checks, document review and worker interviews. Our suppliers are in turn responsible for compliance and implementation across their supply chain, factories, and contractors, and must make sure they do not source components or materials for use in Primark products that are made using forced or trafficked labour.

Primark is a partner member of the ILO Better Work and Better Factory programmes, a collaboration between the ILO and the International Finance Corporation. In some countries e.g., Vietnam and Cambodia, the ILO conducts an assessment and shares the results with all brands and retailers sourcing from that factory.

If at any point we identify any issues that present a severe and imminent threat to workers’ lives or safety, we prioritise these and the factory is immediately suspended from our purchase order system until we can verify that the issue has been fully remediated and there is no further risk to workers. In cases where suppliers are either unable to make improvements or lack commitment, we have a clear process on termination, and work with the supplier and our Buying and Merchandising and Sourcing teams on a responsibly managed exit plan. We implement the ACT responsible exit strategy guidance to help ensure that when a commercial relationship with a supplier or factory comes to an end, both the brand and supplier have assessed the risks to workers. Primark’s Sourcing team conducts dependency reviews with our suppliers and their factories to indicate relative dependencies and risks on both sides, giving our supply chain partners an opportunity to mitigate any impacts where required."

The evidence above does not respond to this metric. I have changed the answer from Yes to No as the company does not state having reviewed its business performance indicators vis-a-vis modern slavery risks.