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MSA policy applies to beyond tier 1 supply chain
Does the company’s statement detail specific, organisational policies or actions to combat slavery in beyond tier 1 supply chains?
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About the data

Establishing effective policies to combat modern slavery is listed as one potential component of a modern slavery statement within the UK Modern Slavery Act and is recommended by the Home Office guidance accompanying it. Clear organisational policies help to set the tone in assessing, preventing and mitigating the risk of, and working to influence and remedy, modern slavery in organisations and their supply chains. It also helps to demonstrate a company’s commitment to tackling modern slavery.

For further information on policies use the Home Office Guidance, pp. 28-30

Does the company’s statement detail clear, organisational modern slavery policies that cascade down their supply chains and apply beyond tier 1? These policies must be explicit and go beyond vague statements.

Beyond Tier 1 includes the use of sub-contractors, and any non-direct suppliers.

Policies include:

  1. requiring all suppliers and contractors to comply with local and international laws, and company’s policies,

  2. prohibiting contractors or suppliers from using forced labour, involuntary labour, debt bondage or human trafficking,

  3. the ability to terminate contracts based on violation of supplier code, or violation of modern slavery policies,

  4. requiring contracts to include clauses on forced labour or supply chains, or

  5. requiring suppliers to produce their own statement on modern slavery and forced labour.

Please note this metric refers to organisational polices that are clear and explicitly tackle modern slavery. It does not measure supplier engagement such as supplier audits, questionnaires, site visits, etc., this is measured by the metric: ‘Continuous engagement with suppliers.’
Please select as many policies as apply. These policies apply to beyond tier 1 suppliers if the company has a mechanism in place through which their policies “cascade” down the supply chain (e.g. by requiring direct suppliers to ensure that their suppliers also adhere to the company’s relevant policies).

Unless there is specific mention of a mechanism through which the company's policies are applied to suppliers beyond Tier 1, please fill out details under the previous metric.

If no such policy exists, then please select “No”.

If the business indicates it is developing a modern slavery supply chain policy or planning to implement one in the future, please indicate “In Development”.

For each value, please include a comment that copies relevant information from the statement. If the policy that you wish to include is not listed, please add a comment and flag the section for review.

Marks and Spencer

“M&S internal policies include our Human Rights policy and our Code of Ethics where we confirm that we will not tolerate or condone abuse of human rights within any part of our business or supply chains and will take seriously any allegations that human rights are not properly respected…

…All suppliers are required to comply with our Global Sourcing Principles, and with business-area specific ethical policies, which require them to:

  • Participate in ethical trading audits assessments;

  • Provide employees with good working conditions, fair treatment and reasonable rates of pay; and

  • Respect workers’ human rights and comply fully with all applicable laws.

The above policies also require that:

  • All work must be voluntary, and not done under any threat of penalties or sanctions

  • Workers must not pay any deposits for work, and employers – whether labour users or recruiters – must not keep original copies of identity documents.

  • Indentured labour is prohibited, and workers must be free to leave work at any time, with all salary owed to be paid.

The Global Sourcing Principles have applied to product suppliers since 1998, and as of May 2016, have been extended to all suppliers – including goods not for resale. As of May 2016, we have also strengthened the Global Sourcing Principles on forced labour, and agency labour, by adding a new statement prohibiting the payment of direct or indirect recruitment fees to secure a job, and requiring suppliers to have adequate due diligence in place to ensure this does not happen…

This year M&S has amended its standard supplier contractual terms to include obligations on suppliers to: comply with the Modern Slavery Act, conduct regular Modern Slavery risk assessments within their own supply chains, implement appropriate controls to prevent Modern Slavery, and notify M&S immediately if they become aware of any Modern Slavery within their supply chains. Suppliers which breach these obligations will face appropriate actions which could include termination of contracts.”

Value Type
Suppliers comply with laws and company’s policies
Prohibit use of forced labour
Code of conduct or supplier code includes clauses on slavery and human trafficking
Contracts include clauses on forced labour
Suppliers produce their own statement
In Development
Research Policy
Community Assessed
Report Type
Modern Slavery Statement