"We understand that our biggest exposure to Modern Slavery
is in our product supply chains, where we have undertaken
activity over last decade to minimise the risk of Modern Slavery.
Within these areas, new suppliers and factories/sites are subject
to due diligence checks in the form of ethical/compliance
audits conducted by or on behalf of M&S. Such audits are also
regularly conducted for existing suppliers and factories/sites.
These audits assess compliance with the Global Sourcing
Principles and are, amongst other things, intended to
identify any Modern Slavery practices. If issues are identified,
appropriate investigative and remedial actions will be taken.
During 2015/16, ethical audits identified 14 non-compliances
under the heading ‘employment is freely chosen’, this included
absence of a clear policy on forced labour, reports from
workers that toilet breaks were restricted, deposit payments for
protective equipment, and retention of passports of workers.
All instances have been followed up, for example, by working
with experts on the ground to undertake more detailed visits,
and to identify remedial actions.
Recognising the limitations of ‘mainstream’ ethical audits to
identify Modern Slavery issues, and based on information
received through our Human rights risk assessment process,
we have also begun to undertake a number of additional due
diligence audits with leading forced labour experts. To date,
such audits have been carried out in Vietnam, Indonesia,
Malaysia, and the Philippines."
"Modern Slavery training
We have used training to upskill our product suppliers on the
implementation of relevant policies, in our regular supplier
workshops.
We have trained our key staff in Modern Slavery and human
rights using an expert 3rd party consultancy and then used
that consultancy to support each business area in mapping,
risk assessment and developing mitigation response.
We have developed Ethical Trade training, which covers Modern
Slavery, which is now being rolled out across the business
starting in Foods and all food employees will be trained by the
end of 2016/17.
Further steps to prevent Modern Slavery
in our supply chains:
The Directors of each business area (Retail Operations,
Property, Logistics, HR, IT and International, Foods, Clothing
& Home) are responsible for compliance in their respective
departments and for their supplier relationships. Given
the complexity and changing nature of this issue we have
formalised internal governance of Modern Slavery and Human
Rights at both operational and senior leadership levels.
In addition:
Our CEO has written to suppliers servicing all areas of our
business to raise awareness of the Modern Slavery Act and
Human Rights. This letter affirms our zero tolerance approach
to human rights abuses; updates our Global Sourcing
Principles to address human rights; encourages suppliers to
establish their own risk assessment processes; and informs
them that we will be periodically checking compliance with
our standards.
Ongoing Supplier Engagement and awareness raising
(using Surveys, newsletter, supplier workshops)
Listening to our stakeholders, we have increased our
transparency on human rights and Modern Slavery. In May
2016, we published for the first time an online list of our
first tier food and clothing sites, and began disclosing
additional information on our approach to auditing. We will
also be using our forthcoming human rights report to outline
where we see our biggest supply chain risks on Modern
Slavery, and wider Human Rights.
Recognising the extremely complex nature of Modern
Slavery, we continue to emphasise the importance of
collaboration with others. In the past year, we have been
involved in several supply chain collaborations, including
cross industry involvement through the Consumer Goods
Forum, Ethical Trading Initiative, Freedom Fund, Stronger
Together in the UK, Project Issara in Thailand, Tamil Nadu
and retailer collaborations in Spain and Italy. We have
worked closely with the Ethical Trading Initiative (of which
we have been members since 1999), including participating
in their 2015 research into corporate responses on Modern
Slavery. Within the Consumer Goods Forum, we have been
a key contributor to the development of their focus on
Modern Slavery. We have a long-standing relationship with
the Gangmasters Licensing Authority (GLA), who regulate
the supply of temporary labour into the Food and Farming
industry. We are currently working with the GLA to undertake
a small number of due diligence assessments in non-food
sectors. Governments, both in the UK and internationally,
have an important role to play in tackling Modern Slavery.
We have participated in government consultations on the
Modern Slavery Act, and on the future of the GLA, and will
continue to remain engaged with Government on this issue.
We have run bespoke Modern Slavery training for M&S Food
suppliers. In addition, all UK M&S Food suppliers employing
migrant workers are required to have attended Stronger
Together workshops, and to have cascaded the training
within their supply bases. Over 200 attendees from the
M&S supply base have attended, taken part in this
training to date. In Turkey we have run supplier workshops
on Modern Slavery for 1st and 2nd tier suppliers given
the current risks of Syrian refugee exploitation in the
informal garment industry. 160 attendees participated
from 51 suppliers.