Human rights issues could arise in any part of our business. As a responsible business and employer upholding human rights is fundamental to who we are and what we stand for. We are currently focused on engaging all aspects of our business to strengthen the integration of human rights considerations into our policy and governance framework. This includes the rollout of employee engagement and training initiatives across our business areas and geographies.
For example, during 2015/16 key staff received third party training on Modern Slavery and wider human rights. We have also developed a bespoke training course for our employees on Ethical Trade, which covers human rights. Starting with our Food and Household division this is being rolled out across our entire business. All Food and Household employees will have completed this training by the end of 2016/17.
Our Code of Ethics and Behaviours
is integral to our internal control and risk management systems. All employees and direct suppliers are made aware of the Code. Each year we also require all senior managers and above to confirm their compliance with the Code. We expect and encourage employees and direct suppliers to report any breach of the Code.
All employees can access M&S policies via the M&S Intranet or by contacting our HR Shared Services team as well as via their line manager or HR Business Partner. We have a number of mechanisms in place to monitor adherence to our policies, such as via our regular ‘Your Say’ staff surveys, worker representatives and internal grievance procedures.
We are in the process of developing our Global People Principles which will which underpin our vision of being a responsible employer and establish minimum standards with respect to recruitment, reward, employee relations, employment engagement and how employees can communicate their views. This will apply across all our operations for our direct employees and Joint Venture partnerships. Similar standards are in place in our franchised operations.
We work with a number of franchise partners to help extend the reach of the M&S brand to more customers around the world. This enables us to benefit from our partners local market expertise and gain better access to prime retail locations.
Before entering into any new franchise partnership venture we undertake full due diligence. As part of this process we give due consideration to human rights risks at a country and organisational level and commission specialist external audits where necessary. We use a range of external tools as part of our country level assessment including Maplecroft Risk Indices
and Transparency International Corruption Perceptions Index
As a retailer, serving customers is at the heart of everything we do. We and our partners are fully committed to respecting the human rights of our customers. This includes our approach to handling customer’s data, protecting their privacy, marketing to them responsibly and ensuring they can shop with us safely. Customers are increasingly aware of their personal impact on the world and businesses must work hard to build and maintain their trust. Any customer with human rights concerns regarding the human rights impacts of M&S activities can raise them through Customer Services channels in store and online. We plan to develop a set of Global Customer Principles to provide greater reassurance on protecting customer privacy and responsible advertising.
We’ve established clear roles and responsibilities for respecting human rights at all levels of our business.
Our CEO, Steve Rowe, approved the M&S Human Rights Policy
and oversees our work in this area. He is supported by the M&S Board and Operating Committee
who are responsible for ensuring that every part of our business is clear about the responsibility to respect human rights. Human rights is a standing agenda item on scheduled Operating Committee meetings which generally take place monthly. Our Group Secretary is responsible for providing a central source of guidance and advice on policy, procedure and ethics with support from a small team of legal and corporate governance specialists.
Our Board is accountable for carrying out a robust assessment of the principal risks facing our business. On behalf of the Board, the Audit Committee reviews the effectiveness of the Group risk management process. Each business area is responsible for formally identifying and assessing their risks half-yearly, measuring them against a defined set of criteria, and considering likelihood of occurrence and potential impact. The Group Risk function facilitates a similar exercise with Executive Board members, combining information to provide a consolidated view. Human rights (as with other sustainability risks) feature within Plan A, food Integrity and ethical sourcing risks associated with our Clothing and Home division. During 2015/16, the Audit Committee reviewed management of Clothing and Home ethical sourcing risks, which included labour and human rights. The risk process and outcomes are outlined in our Annual Report
The Directors of each business area (Retail Operations, Group Property, Logistics, HR, IT, Food Group, Clothing & Home, and International) are responsible for activity in their respective areas and for their employee, supplier and customer relationships. In particular, each area is responsible for developing dedicated plans to implement policies of relevance to human rights (e.g. Code of Ethics and Behaviours
) and manage salient human rights issues (outlined above). This includes identifying geographical priorities for each salient issue.
The Directors are supported by a Human Rights Practitioner Committee comprised of representatives from across the business who have day-to-day responsibility for human rights issues.
We’ve recently established a Human Rights Director Steering Group to help ensure a consistent approach to respecting human rights across our business and supply chain. This group reports on progress on human rights to our Plan A 2020 Executive Committee which is chaired by our CEO.
We recognise we have much to learn on human rights and have recently established an independent Human Rights Stakeholder Advisory Group to help inform and improve our identification and management of salient risks. This group includes representation from our Sustainable Retail Advisory Board organisations to ensure there are clear linkages between these two groups.