Responsible Sourcing and Human Rights in Clothing and Home

M&S Clothing and Home supplier factories are required to be audited annually by approved independent third party companies and/or the M&S ethical compliance team, against our Global Sourcing Principles and international standards. Factories are expected to implement remediation plans as a result of any audit findings which require improvement.

The ethical audit process, including grading, escalation and audit follow-up activity, is managed by our specialist Sourcing Office compliance teams located in Bangladesh, Cambodia, China, Hong Kong, India, Pakistan, Sri Lanka, Türkiye and Vietnam. Our regional teams also provide a valuable local presence in risk mitigation and remediation activities.

We are also expanding our evaluation of social compliance through assessments and audits further down the supply chain for Clothing and Home products, through M&S ethical site visits and 3rd party audits. This provides us with greater transparency of our Clothing and Home supply base, and a clearer assessment of human rights risks, social performance and labour conditions in our tier 2 facilities.

We expect our supplier partners to communicate with their own suppliers and sub-suppliers involved in producing or supplying Marks & Spencer products or services, and put in place policies and management systems to ensure that they adhere to the Global Sourcing Principles.

We rolled out our tier 2 ethical compliance policy internally in 2024 and began collaborating with our tier 1 suppliers on implementation of the policy and corresponding due diligence requirements. We also carried out a supply chain mapping exercise to improve our visibility of sites in our supply chain.

We’re also working on responsible sourcing of fibres and fabrics further still down the supply chain - click here to learn more about our approach.
 

At M&S, our social audit programme has been running in our Clothing and Home supply base for over 20 years. We were a founding member of Sedex, which aims to drive improvements and convergence in responsible sourcing practices. The audit programme enables us to monitor compliance with our global sourcing principles, international standards and local law, as well as to identify opportunities for capacity building in our supply base.

Whilst we are confident there continues to be a role for traditional social audit programmes, and we are currently expanding these further down our supply chain, we also recognise their limitations in highlighting certain worker issues. Therefore, in recent years, we have been developing and implementing pilot worker voice programmes to gather more direct worker feedback on their experiences working within our supply chain.

And in 2019, we invited Oxfam to carry out a gap analysis of our supply chains in India and the UK to help us better understand the true worker experience and identify the changes we need to make in our own operations and those of our suppliers. One of Oxfam’s key recommendations was also to scale up our worker voice programmes to help shape a best practice framework for the industry. Since then, we have carried out pilots in over 90 Clothing and Home factories, with a population of over 70,000 workers.

Our key learnings to date are as follows: 

• Worker voice provides a hugely valuable mechanism to identify issues which may not typically be found in audits 
• Different mechanisms and platforms may be successful in different locations and for different worker demographics 
• Programmes should avoid or minimise duplication between brands in shared factories 
• Worker engagement and trust that issues will be addressed is key to the success of worker voice programmes, as is factories’ commitment to action to address worker feedback 
• Feedback enables implementation of an appropriate mechanism for dialogue and/or grievance between workers and management.

In 2024, based on the learnings from the pilot projects, we introduced a requirement for all tier 1 production sites to have effective worker voice mechanisms in place, and we launched our Global Supply Chain Worker Voice Best Practice Guidelines to support them to do so.      
 

In addition to the primary and secondary data we collect from our supply base, we also regularly refresh our research on key issues in our sourcing countries, to inform our risk assessments and due diligence approach. For example:

• Research into living wages, including academic research, benchmarking exercises of actual wages, cost of living, and desk-based analysis of existing information and field research 
• Research into responsible business and implementation of UN Guiding Principles on Business and Human Rights in changing and challenging situational contexts 
• Research into the root causes of excessive overtime in garment factories and how to address them 
• Our risk identification and prioritisation includes desk-based research, data from our audit programmes, supplier surveys and assessments, and discussions with expert stakeholders through multi-stakeholder initiatives.  

Our salient risks are determined at a company level, with input from internal and external stakeholders. For more information on our salient risk assessment process and highest risk locations, please refer to our ESG report and Modern Slavery statement. 

Since 2016, we have publicly disclosed our Tier 1 supply base, as part of our commitment to transparency about where our products are made. The map highlights production countries as well as individual factory locations and profiles for sites used by our direct suppliers, as well as additional data points including those relating to worker representation and gender. In 2024, in order to share our data collaboratively and in a standardized manner with others across the industry, we disclosed our tier 1 supply base through Open Supply Hub. Our disclosure includes 100% of our tier 1 production sites and is updated regularly (minimum twice per year). You can view our site data via Open Supply Hub here. In 2024, as part of our ongoing commitment to supply chain transparency, we also signed the Transparency Pledge.

As part of our Global Sourcing Principles, we commit to keep our buying practices under review to ensure that our behaviour supports supplier partners in complying with these Principles. We created our Responsible Purchasing Practices Guidelines to support and educate our colleagues on the importance of responsible purchasing practices. These guidelines are aligned to the Better BuyingTM Five Principles of Responsible PurchasingTM.

We are very proud to hold strong long-term relationships with our clothing suppliers - over 70% have worked with us for more than seven years and these relationships are built on trust and respect. It has always been a priority to respect human rights and to stand up for our workers across our global supply chains. These relationships allow us to honour supplier commitments when supply chain “shocks” occur, as we did, for example, during and after Covid.  

We also regularly liaise with our suppliers on purchasing practices and ethical compliance requirements.  This includes gathering their feedback through Better BuyingTM, supplier ethical compliance workshops in our sourcing regions, and sourcing summits with suppliers and wider M&S sourcing teams. We also incorporate ethical compliance performance into our supplier performance management scorecard, and increased the weighting of ethical compliance in the scorecard in 2024.

Additionally, in recognition of the role that purchasing practices can play in impacting working hours in the supply base, we have implemented training for internal product-facing teams on the impact of purchasing decisions on factories’ ability to comply with compliance requirements for working hours, and the corresponding impact to workers.

Responsible Factory Exit 

We are committed to taking appropriate steps to safeguard the welfare of workers in our supply chain. We are mindful that any decision to shift production elsewhere or close a factory could have negative consequences particularly if such action happens quite abruptly.

The approach to closure and disengagement of factories, which is outlined in our policy, should be planned, with clear rules, policies and commitments based on: 

• Compliance – with national laws, international labour standards and the terms of any collective bargaining agreements that are in place 
• Consultation between all key internal and external stakeholders 

We encourage all parties to work together to mitigate the negative consequences. For example, workers should be paid their legal entitlements including social security, pensions and severance. 

We are committed to building a culture of trust and transparency within our business and supply chains and to work with suppliers and business partners to remedy adverse human rights impacts. M&S has a strict anti-retaliation policy. We encourage our employees and individuals within our supply chains and wider communities (including those that represent them) to report any wrongdoing without fear of retribution.

There are a number of ways in which grievances can be raised:

1. Supplier partners must provide a grievance mechanism for workers and communities (and their organisations, where they exist) to raise concerns. This grievance mechanism must involve an appropriate level of management and address concerns promptly, using an understandable and transparent process that provides timely feedback to those concerned, without any retaliation against reporters in the form of disciplinary measures or retribution.
2. In addition to suppliers' channels, grievances can also be reported through an independent hotline that we support, Safecall. You can read more about this in the M&S Grievance Procedure. 
3. Allegations and/or grievances relating to our supplier factories and/or more generally to issues in the countries we source from, can be brought to M&S by various stakeholders.  

As Ethical Trade is fundamental to the way we do business, we will always investigate any claims which are raised to us and respond to the stakeholder if possible and appropriate to do so. Where necessary, we will seek the support of an independent party to investigate supply chain grievances / allegations. We also remain open to collaborating in shared initiatives which provide access to grievance and remedy in our sourcing locations.

For example, in 2023, we contributed to a research study entitled “Worker and Management Experiences of Workplace Grievance Mechanisms in Cambodia’s Garment Sector”, alongside other brands. In 2024/2025, we began working with Timby both in India (through the South India Garment and Textiles Supply Chain Programme, alongside SAVE) and with all tier 1 factories in Pakistan. We also supported the Mülteci Destek Derneği / Refugee Support Association (MUDEM) Worker Support Centre grievance programme in Turkey.  

To see examples of our public responses to stakeholder concerns, click here.