Embedding
A major focus for the past year has been on training and learning. We recently conducted a group wide awareness-raising training session, which was delivered to senior CR and procurement leads. We ensured the businesses were made aware of the scale, scope and pervasive risks of modern slavery and positioned the issue in the broader context of business and human rights, introducing the United Nations Guiding Principles on Business and Human Rights. It also enabled the sharing of best practice within the group and the awareness raising of the broader human rights agenda for business.
In 2017, Primark launched a training course on Forced Labour & Modern Slavery for suppliers. The course is designed to provide suppliers with:
• an understanding of the definitions of forced labour and how to recognise it within the supply chain and operations;
• information on the risks to their business, including imprisonment and fines, commercial and trading risks, and reputational damage;
• guidance on Primark’s Code of Conduct for suppliers and our expectations of them; and
• resources for further guidance and support.
The course was developed with content derived from the ILO including its publication ‘Combating Forced Labour, a Handbook for Employers and Business’. We began this training with a focus upon suppliers within the Goods for Sale supply chain and key suppliers within the Goods Not for Retail supply chain (e.g. logistics and operations).
In 2015, we trained the senior procurement personnel in our businesses on the issue of modern slavery. This included risk assessment, how to develop a response plan and auditing. We are now extending the training programme to the wider buying community including those responsible for cleaning, catering, construction and refurbishment contracts. Some of our businesses, like Twinings, are also planning to conduct a workshop with local HR teams which will include specific guidance on recruitment practices, working with recruitment agencies and labour contractors. In addition, Twinings has conducted training days for its suppliers aimed at raising awareness and providing guidance about modern slavery, specifically around issues relating to agency labour and document checks for new workers.
Ensuring that people understand their rights at work is equally critical in preventing trafficking and forced labour. This is one of our Ethical Trade & Sustainability Strategic Objectives for Primark and they have a range of programmes that seeks to achieve this. A dedicated Project Controller and Project Team manage these programmes, working closely with local teams on the ground and NGOs and other organisations to design and deliver them.
Training for HR is in development.
We recently conducted a group wide awareness-raising training session, which was delivered to senior CR and procurement leads. We ensured the businesses were made aware of the scale, scope and pervasive risks of modern slavery and positioned the issue in the broader context of business and human rights, introducing the United Nations Guiding Principles on Business and Human Rights.2
Furthermore, the entire Sugar division has sought to embed training across multiple functions with senior leadership and the heads of HR and Procurement in each business being trained on modern slavery issues in addition to our Audit and Sustainability teams.4
In 2017, Primark launched a training course on Forced Labour & Modern Slavery for suppliers.2
Some of our businesses, like Twinings, are also planning to conduct a workshop with local HR teams which will include specific guidance on recruitment practices, working with recruitment agencies and labour contractors.2