"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."

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"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.