Sainsbury requires that their direct suppliers act in accordance with the policies and processes they have developed – signed off on in their formal governance process – which aim to “avoid causing or contributing to adverse human rights infringements, including any form of modern slavery” (Page 7). Their MSA Statement outlines multiple organizational policies " in line with the International Bill of Human Rights, UN Guiding Principles on Business and Human Rights (UNGPs) and ILO Declaration on Fundamental Principles and Rights at Work” (Page 7). I have selected the actions based on information clearly stated within their Policy expectations:

1) Prohibit use of forced labour (direct / tier 1)

“The first clause - Employment is Freely Chosen - states there should be no forced, bonded, or involuntary prison labour, that workers should not lodge deposits or identity papers with their employers and that workers should be able to leave employers after a reasonable notice period.” (Page 7)

2) Code of conduct or supplier code includes clauses on slavery and human trafficking (direct / tier 1)

“Section five in the policy outlines our position on modern slavery, stating our commitment to the Consumer Goods Forum Priority Industry Principles on Forced Labour in our operations and value chains. It also sets out our expectation that suppliers should prevent and mitigate the risk of workers paying fees associated with recruitment processes.” (Page 7)

3) Contracts include clauses on forced labour (direct / tier 1)

“The first clause - Employment is Freely Chosen - states there should be no forced, bonded, or involuntary prison labour”

4) Suppliers produce their own statement (direct / tier 1)

“We manage policy compliance through contractual terms and conditions and require suppliers to have their own codes of conduct and ethical trade management systems”

5) Prohibit charging of recruitment fees to employee (direct / tier 1)

“It also sets out our expectation that suppliers should prevent and mitigate the risk of workers paying fees associated with recruitment processes.”

It is unclear if there are specific requirements for policy compliance beyond direct suppliers, but Sainsbury acknowledges “the need for further traceability and transparency beyond tier 1 suppliers and to identify forced labor risks where we have indirect supplier relationships and less visibility of conditions for workers, growers, and communities.” (Page 8).