Policies

The M&S Code of Conduct (the “Code”) sets a floor of minimum commitments for our business conduct. It is important that we all know and own our part in complying with the Code. Our colleagues can find information on our commitments, and their responsibilities for fulfilling them, in our Group Policies. Where relevant, individual members of our family of businesses will also have Standards & Procedures available to support our colleagues to comply with the Code.

Although our Code sets the floor of minimum commitments, we know that our businesses often go above and beyond to deliver for our customers, colleagues, suppliers and the community. Whilst we all must comply with the Code, we should also be guided by ‘The M&S Way’ – our values for making the everyday remarkable and delivering success for M&S: All in for the customer; Make every penny count; Talk straight; Do the right thing; and, Own it and get it done.

Specific Guidance

M&S is committed to respecting internationally recognised human rights in line with the principles and guidance contained in the United Nations (UN) Guiding Principles on Business and Human Rights.

M&S will not tolerate or condone any abuse of human rights within its operations, supply chains or business partners. M&S has a legal responsibility to publish an annual online Modern Slavery Statement detailing our actions in addressing slavery in all its forms.

Specific Guidance

M&S does all it can to act with integrity in all its business dealings and commercial relationships.

We are committed to the highest standards of ethics and honesty and we operate a zero-tolerance approach to bribery and corruption. The giving or receiving of bribes, and any other form of corrupt payment, in any course of conduct involving M&S, is unacceptable.

Specific Guidance

We are committed to protecting our customers, shareholders, fellow colleagues and our brand from fraudulent activity – in whatever form it takes.

We establish policies, procedures and controls to mitigate the risk of fraud in our day-to-day activities but recognise these may not always prevent all fraudulent acts.

We therefore also rely on all of our colleagues to identify and report suspected fraud, either through their line management or the confidential reporting process.

We will fully investigate whenever fraud is suspected, irrespective of monetary value, due to the corrosive nature on our values and expected behaviours.

Where confirmed, we will enforce appropriate sanctions including disciplinary action that may lead to dismissal, civil recovery proceedings to recover losses and report criminal acts to the police or other authorities.

Specific Guidance

In our commercial business activities, our commitment is to ensure tax is properly considered so we remain compliant with relevant tax laws.

Specific Guidance

M&S has established, and is committed to maintaining compliance with, a framework to identify, assess and facilitate the management of business risks effectively, consistently and in line with the company’s risk appetite.

Our Risk Management Policy underpins this methodology and is applicable to all parts of M&S’s wholly owned business activities, in both the UK and Overseas.

Specific Guidance

M&S is an equal opportunity employer, committed to inclusion and diversity.

We believe every one of our remarkable colleagues should feel comfortable being themselves and experience a culture that’s inclusive and diverse, a place where we understand and respect each other’s differences, where everyone feels they are valued and that they belong. Our colleague networks bring our diverse communities together and help create a safe space for colleagues to speak out and share their views.

We strongly believe that our colleagues ought to reflect the diversity of the communities in which we operate. We’re clear that any form of discrimination, bullying, harassment or victimisation will not be tolerated in any part of the business. Everyone is different and everyone is welcome at M&S.

Specific Guidance

M&S is committed to ensuring the health, safety and wellbeing of all colleagues, customers and others who visit or work on our premises. We maintain the quality of our health & safety at work controls through communication and the raising of awareness.

Specific Guidance

All products sold under the M&S brand (on our websites or within our stores) will be safe for their intended consumer and sourced, manufactured and supplied in line with M&S standards (which are in line with or above legal requirements). We have a robust process for monitoring and reporting compliance to these standards to ensure our supplier partners are in control, legal standards are being met and all claims can be substantiated.  

We will create, manage and evolve our governance and monitoring to allow end to end visibility of compliance to our standards.

All integrity claims we make through our packaging and customer communication will be substantiated.

We will ensure that our food and product technology teams are equipped to maintain the highest standards.

Specific Guidance

M&S is committed to complying with all applicable data protection and privacy legislation including the:

• UK General Data Protection Regulation
• Data Protection Act

We will take all appropriate measures to keep personal data safe, secure and protected against unauthorised access. M&S will only use personal data of customers, employees and others in a fair, lawful and transparent manner.

We also respect and comply with individuals’ data protection and privacy rights.

Specific Guidance

We are committed to trading safely and legally and ensuring that we put the customer at the heart of everything we do.

We achieve the above by complying with all applicable legislation and regulations on trading standards and consumer protection.

Specific Guidance

M&S works to ensure that our suppliers’ employees are provided with good working conditions – we expect high standards and work together ethically. We achieve these objectives by developing agreed standards with our suppliers through Global Sourcing Principles, supported by regular site visits and a policy of continual improvement. Suppliers must always apply these principles and demonstrate that they are doing so.

If a significant risk is identified in supply chains (for example Ethical/Integrity Food safety) we will work to develop effective risk management and monitoring methods.

Where appropriate, we will have agreed contracts in place and a joint business plan (Food only).

Specific Guidance

Just as customers expect high standards from M&S in terms of quality and service, they also expect us to treat our suppliers fairly and lawfully. M&S seeks fair, sustainable and mutually beneficial relationships with all its suppliers. As part of this relationship we must comply with specific laws that protect our grocery suppliers in the markets in which we operate, including the:

• Groceries Supply Code of Practice (GSCOP) for groceries sold in the UK
• Republic of Ireland (ROI) Grocery Regulations for groceries sold in ROI
• European Supply Chain initiative for groceries sold in the European Union

Specific Guidance

M&S is committed to complying with its legal obligations relating to trade sanctions and export controls.

We take appropriate steps to ensure we are not:

• doing business with individuals or entities which are subject to sanctions regimes involved or implicated in the movement of goods which are subject to export controls

These steps include:

• standard contractual terms with suppliers/service providers monitoring jurisdiction of origin and dispatch for all imports

Specific Guidance

M&S aims to make a positive contribution to society by championing causes that matter to our customers and supporting communities where we operate.

The conduct of any charity and business partnership is high profile and reflects on our brand and so it is important these relationships are professionally managed.

Specific Guidance

M&S is committed to managing, measuring and reporting our energy and greenhouse gas emissions, improving energy efficiency, purchasing 100% renewable energy and maintaining carbon neutrality for the company’s business operations.

Specific Guidance

To reduce food wastage whilst maximising sales through accurate forecasting, good stock control, maximised salesfloor availability and reduced price sales where required. Remaining surplus food will be made available to charities and good causes through our partnership with Neighbourly and any remaining product after this is sent for energy generation. We will continue to operate a zero waste to Landfill policy across our estate.

Specific Guidance

M&S aims to safeguard our brand reputation by delivering packaging that is safe, legally compliant, 100% widely recyclable, frustration free and minimises waste.

As required under legislation, we will measure and report how much of each packaging substrate we use and pay a commensurate ‘producer responsibility’ (or recycling) levy.

Product Packaging