We aim to enhance the lives and support the local communities of the people who work for and with us. We’re committed to sourcing responsibly and we work closely with our suppliers to make sure they respect human rights, promote decent working conditions and improve sustainability across our supply base.
The process is managed by our specialist Sourcing Office compliance teams located in Turkey, India, Sri Lanka, Bangladesh, China, Cambodia and Vietnam. Our Regional Office compliance teams' areas of responsibility cover audit follow up and beyond audit capacity building projects.
All of our first tier production sites (which we define as making whole/finished products carrying an M&S label or are identifiable as an M&S product) are required to have an annual Supplier Ethical Data Exchange (Sedex)
ethical audit and must be registered on Sedex. Sedex is the largest collaborative platform for sharing ethical supply chain data. Each must be linked to the relevant M&S subsidiaries available on the system and are encouraged to complete in full the Sedex Self-Assessment Questionnaire (SAQ) modules on labour standards, health and safety, environment and business ethics.
Anti-Bribery requirements: suppliers are required to sign to say that they will adhere with our anti-bribery requirements.
Financial Health Check: we also request the last 3 years financial statements.
We do not accept production from non-approved factories or sites that differ from our contracts system for each specific contract. Sites unknown or not approved by M&S is considered to be illegal sub-contracting and a breach of our Terms of Trade.
We require audits to be done on a semi-announced basis within an audit window of 3 weeks. We do however reserve the right to conduct unannounced audits.
The audit must cover the entire site. For example, if the factory is part of a multi-storied building, all floors must be audited even if M&S production is only taking place on certain floors. We do not accept shared factories where different floors are occurred by different organisations.
We will also accept second party SMETA
audits undertaken by individuals who have completed the ICRA
registered 3 day auditing course and had 2 successful witnessed audits.
Based on the results of the audit, the relevant Regional Compliance team assign a rating based on the number and severity of issues raised, as follows:
- Critical – any Critical issues more than 10 Major issues
- High Risk – up to 10 Major issues or more than 10 Minor issues
- Low Risk – up to 10 Minor issues
- Minimum Standards – no non-compliances
With the exception of the following fire safety issues (which we consider as critical rather than major) we use the SMETA Non-Compliance Guidance
to assess the severity of issues:
- No locked or blocked aisles/exits preventing use
- Firefighting equipment inaccessible, insufficient, unusable or wrong type or no training on its use
- No fire alarm
- No evacuation procedures, drills or training
- No, or adequate, functioning emergency lighting
- Systematic failures in health and safety systems
We also require all sites with more than 50 workers to have in place an elected worker committee or trade union.
We have specific policies and guidelines to manage instances of child labour and illegal sub-contracting.
New sites rated as ‘Critical’ are either not approved for production and have up to 3 months to resolve the issues. Any existing sites identified as ‘Critical’ are managed in accordance with our Critical Escalation Procedure and may be disengaged if they remain critical after three follow-up reviews (typically 3 – 6 months). Sites rated as High Risk are permitted to produce on a conditional basis for a period of time (e.g. six months).
Corrective Action Plans must be uploaded onto Sedex within two weeks of the audit and all actions completed within the recommended timescales.
We actively track and follow up on our suppliers’ progress towards what they’ve agreed to address within their Corrective Action Plans as shown in Table 1 below.
Table 1: Number of sites and workers on Sedex and location of audits (M&S Clothing and Home Direct Supplier Sites) - 1 April 2019 to 31 March 2020
|Continent||Sites ||Audited sites ||Workers total ||Audited workers||Number of audits ||Number of non-compliance issues ||Average number of non-compliance issues identified per audit |
|Asia ||728||514||678,808 ||439,820||514||3,231||6.29|
The following chart (Figure 1) presents the top 5 ethical trade non-compliance issue areas identified through ethical audits.
Non-compliance issues related to ‘Freedom of Association and Collective Bargaining**’, forced labour (‘Employment is Freely Chosen**’) and ‘Discrimination**’ were less commonly identified. In part, this reflects how difficult it is to identify these more hidden or subtle issues through ethical audits. It is for this reason that we work with suppliers through our Ethical Excellence Factories Programme our Global Community Programme
as well as through collaborative working and advocacy initiatives to improve the performance in identifying and managing ethical trade issues. Find out more about our approach to capacity building
Figure 1: Top 5 ethical non-compliance issue areas identified through audits in 2019/20