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 key Food and Household employees will have completed this training by the end of 2018/19.
We want people to enjoy coming to work and for the workplace to be free from discrimination, harassment and victimisation. Employing people in different countries means responding to different cultural and social norms and different employment law and commercial considerations. However, regardless of where they work or the job they do, we want everyone employed by Marks & Spencer to be treated with dignity and respect and have pride in our brand.
Our People Principles
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. These apply across all our operations for our direct employees and Joint Venture partnerships. Similar standards are in place in our franchised operations. Our conditions of employment are explained during the recruitment process, in individual contracts and during induction. Find out more about our People Principles
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 employee grievance procedures.
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. During 2017/18, we developed a set of Responsible Marketing 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 is chaired by our CEO and generally take place monthly. The Operating Committee were provided with a full update on M&S' human rights programme in February 2018 including the need to make further improvements on grievance management, governance and transparency. They also reviewed and approved the Modern Slavery Statement 2017/18 in May 2018.
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. Salient human rights issues (as with other sustainability risks) feature within Plan A, food integrity and ethical sourcing risks associated with our Clothing and Home division. During 2017/18, the Audit Committee received detailed updates on several human rights matters including ethical sourcing and modern slavery as follows:
- Updated on the controls in place to ensure an uncompromising approach to maintaining M&S's ethical standards in an increasingly competitive international sourcing environment.
- Discussed how risks are mitigated through supplier selection, appraisal criteria and regional improvement programmes supported by a strict Internal Audit and monitoring approach.
- Updated on the approach to supplier inspections and the different processes adopted in Food and Clothing & Home, noting the regular independent ethical audits on all factories used by M&S. This included a formal Internal Audit of our Food ethical sourcing process and controls to manage the risks around new and existing suppliers’ compliance with ethical trading legal requirements and achieving M&S ethical trading standards.
- Updated on the ways in which the business proactively supports the human rights of colleagues across all business operations, including compliance with the Modern Slavery Act and the steps taken to prevent modern slavery throughout the business and its supply chain.
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, monitoring implementation plans and implementing corrective action plans if necessary.
The Directors are supported by a Human Rights Practitioner Committee comprised of key staff from across the business (Food, Clothing & Home, Logistics, Property, Marketing, International, Retail, Human Resources and IT) who have day-to-day responsibility for human rights issues in our business and supply chains. The Human Rights Practitioner Committee meets monthly to monitor our human rights implementation plans, track actions taken and evaluate their effectiveness and identify where a different approach may be needed.
Our Human Rights and Modern Slavery Steering Group helps ensure a consistent approach to respecting human rights across our business and supply chain. This senior group is co-chaired by our Director of Food Technology and Director of Sustainable Business/Plan A has been delegated responsibility for human rights matters by our Plan A Committee which reports directly into our executive Operating Board.
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. An overview of the group's activities is provided above.