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page 10 details the audit process:

 

-" We audit all first-tier sites both before any orders

are placed and then on a regular basis (at least

annually).

 

- All 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. We use

the ILO indicators of forced labour as a reference

within our audit process.

 

- Our own auditors are trained to SA8000 standards

and conduct our audits, with the balance of our

audits conducted by carefully selected third party

auditors."

 

page 9 provides further detail on the 3rd party auditors: "Primark’s local ETES team is one of our most important resources. The team of over 130 local experts are our ‘eyes and ears’ on the

ground. Based in ten of our major sourcing countries, they have been recruited from a range of different organisations including other companies, development agencies and civil society."

 

ETES : Ethical Trade and Environmental Sustainability Team (from Primark)

 

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Pg. 9

“We conduct unannounced audits on all Tier 1 factories and are increasingly assessing Tier 2 sites in our supply chain which provides us with information on risks at a site level.”

Pg. 10

“We audit all first-tier sites both before any orders are placed and then on a regular basis (at least annually).

All audits are unannounced, apart from the initial audit used to gain approval for Primark production. For these sites, production is only permitted once the ETES team is satisfied that Primark’s standards as set out in the Supplier Code of Conduct are met.”

“We may also conduct worker interviews off-site if we deem it necessary and may use support from NGOs or other experts."