Responsible Sourcing and Human Rights in Fashion, Home & Beauty

At M&S, our social audit programme has been running in our Fashion, Home & Beauty 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.

M&S Fashion, Home & Beauty supplier factories are required to be audited regularly 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. 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 Fashion, Home & Beauty products, through M&S ethical site visits and third-party audits, supported by a new custom audit tool and database. This provides us with greater transparency of our Fashion, Home & Beauty 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 to put in place policies and management systems to ensure adherence to the Global Sourcing Principles.

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.
 

While 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.

In 2024, based on the learnings from pilot projects, we introduced a requirement for all Tier 1 production sites to have effective worker voice mechanisms in place. We published our Global Supply Chain Worker Voice Best Practice Guidelines to support them. Our ethical team reviews the worker voice mechanisms during site visits, checking issues raised and how management have responded. 

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. Some examples of previous work include 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; and 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. In 2025/26 we updated our human rights risk indices, supported by a third-party consultancy, to account for emerging risks and to include in-scope sourcing countries in the lower tiers of our supply chains. [new sentence from MSS 2026]

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 standardised 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 manufacturing sites which produce finished M&S branded products and is updated regularly 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 Buying™ Five Principles of Responsible Purchasing™.

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.

We also regularly liaise with our suppliers on purchasing practices and ethical compliance requirements. This includes gathering their feedback annually through Better Buying™, 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 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; and 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 currently reviewing our internal guidance for our team on how to responsibly exit a site or supplier, as part of our approach to responsible purchasing practices. 

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. 
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 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 and 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 2025/26, we expanded the number of sites, workers and countries that can access an external grievance mechanism, and began developing a pilot assessment of on-site grievance mechanisms in collaboration with other brands.  

Our Global Sourcing Principles set clear requirements that supply chain partners must provide a healthy, safe and clean workplace for all workers.

As part of our ongoing commitment to working conditions in our supply base, we were a signatory of the original Accord on Fire and Building Safety in Bangladesh (2013), which aimed for sustainable improvements to working conditions in the Bangladesh garment industry. We have since signed the subsequent Transition Accord (2018), the Interim Agreement (2021), the International Accord for Health and Safety in the Textile and Garment Industry (2021, 2023), and the Pakistan Accord on Health and Safety in the Textile and Garment Industry (January 2023 and 2026). In 2024/25, we also joined the Bangladesh Employment Insurance Scheme (EIS), which provides compensation in cases of work-related injuries and is implemented by the ILO and GIZ.  

We have also supported many worker impact projects relating to worker health and safety, for example female worker health programmes with partners including CARE International and RISE, worker commuting safety programmes such as the Commuting Safety for Cambodian Workers programme funded by USAID, and community health programmes such as a Community Development programme, which focuses on supporting the development of workers in the Indian apparel industry and their families, including through free medical camps. 

Our Global Sourcing Principles outline our requirements for all suppliers on working hours. To support compliance, we have implemented additional activities beyond our monitoring programme, including research in our key sourcing countries. In recognition of the role that purchasing practices play in impacting working hours, we implemented training for internal product-facing teams which includes the impact of purchasing decisions on factories' ability to comply with working hours, and the corresponding impact to workers. We also engage with our suppliers as participants of Better Buying™ to gather feedback on the impact of our purchasing practices. 

All workers are entitled to fair and equal compensation that at least meets the legal minimum wage, industry standards or negotiated wages. Contracts, wages and benefits are among the most important conditions of work.

While M&S does not own any factories, nor pay workers directly, and our suppliers have many other customers, we recognise the importance of using our influence to improve workers' financial situation. To date, we have:

monitored wage compliance through our compliance programme, verifying that workers are paid correctly, on time, and in line with their skill level; 
implemented programmes supporting social dialogue; 
completed wage digitisation programmes in supplier factories, in partnership with the Mastercard Centre for Inclusive Growth and Better Than Cash Alliance, to improve payment accuracy, increase workers' ability to save and improve financial inclusion; and 
continued to roll out financial literacy training for factories (e.g. RISE Financial Health, which supports workers, especially women, to access, use and benefit from financial products and services). 

We are committed to inclusion and diversity and we have a zero-tolerance stance on discrimination, harassment and unacceptable behaviour.

While gender-related issues and discrimination can be difficult to identify through social compliance audits, we use our grievance mechanisms to identify issues wherever possible, and we use worker impact projects to proactively address gender and discrimination-related risks. Past and present projects include: Marks and Start, which aims to support people who face barriers to employment; Gender Equality and Returns (GEAR), an initiative of Better Work which aims to promote women's career progression opportunities (M&S has supported this project for factories in Sri Lanka and Bangladesh); Providing Opportunities to Women for Equal Rights (POWER), which since 2016 has promoted gender equality in India in partnership with the British High Commission and Change Alliance; the Apparel Training and Design Centre (ATDC) Vision Of Individual Career Evolution (VOICE), which aims to facilitate women's empowerment through career progression and capacity building; Mothers@Work, a national initiative led by UNICEF to strengthen maternity rights and protect breastfeeding support in the workplace for young working mothers in Bangladesh; and the Shojag (Awaken) Coalition programme, aiming to reduce gender-based violence in the garment (RMG) industry in Bangladesh.

In Pakistan, we began working with the Federal Ombudsperson Secretariat for Protection Against Harassment (FOSPAH) in 2025/26 to deliver "train the trainer" workshops on forms of harassment, reaching management at Tier 1 sites, with plans to extend training across the wider supply base next year.  

We aim to ensure that everyone in our supply chain has a voice and encourage a culture of open dialogue and continuous improvement between workers and management. Freedom of association, the right of workers and employers to form and join organisations of their own choosing, is an integral part of a free and open society. M&S respects workers' rights to freedom of association.

We promote workplace representation by participating in initiatives which provide capacity building to factories on Freedom of Association, e.g. ILO Better Work and the ETI Social Dialogue programme; verifying worker representation during our ethical compliance monitoring; engaging with external stakeholders, including unions, on a case-by-case basis if allegations or issues are raised; and including information on our interactive map for transparency where suppliers have a worker committee or trade union. 

We recognise that modern slavery is a growing global issue, and we understand our responsibility to prevent, mitigate and remediate in accordance with the responsibility to respect human rights under the UNGPs. Our colleagues and supply chain partners play a key role in helping us to achieve this. Our Modern Slavery Statement sets out our approach to preventing slavery and human trafficking in our operations and supply chains.

Since 2023, we have begun onboarding our cotton supply chain to the Better Cotton Initiative's (BCI) Physical Chain-of-Custody, moving from a mass-balance approach to physically traceable cotton from certified farms to the final product. This transition strengthens transparency and provides further confidence in the country of origin of cotton used in our products.

Alongside tackling climate change from an environmental point of view, we are assessing the links between the climate crisis and the human rights impacts on workers in our supply chain. Climate change is intensifying existing human rights vulnerabilities across global supply chains, particularly for workers in agricultural and lower-tier supply chains, and this will shape our Just Transition approach centred on workers' rights.

A Just Transition should be as fair and inclusive as possible to everyone concerned, creating decent work opportunities, ensuring gender equality, reducing negative impact on workers and ensuring the human rights for the most vulnerable workers are respected and upheld.

To inform our approach, we have commissioned research on the human rights impacts of climate change in garment supply chains, and we are also participating in industry working groups on climate resilience and Just Transition.  

You can also read more about our approach to circularity and sustainability here. 

While we are predominantly an own-brand retailer, licensed and non-M&S branded goods are a growing proportion of what we sell. Brands at M&S launched in 2021 and now includes over 230 Brand Partners, covering Fashion, Home and Beauty products operating through concession, wholesale, dropship and consignment models.

Suppliers of non-M&S branded goods are expected to uphold the requirements of our Global Sourcing Principles, M&S Human Rights Policy and Code of Conduct. The Brands ESG team carries out risk assessments before and during onboarding using a self-assessment questionnaire (SAQ), alongside reviews and interviews, resolving issues prior to contracting. The SAQ is also used for ongoing Brands assessment, improving risk identification, standardising ESG metrics and strengthening data reporting.

In 2025, we updated Brands Plan A and Product Safety policies, continuing alignment with M&S Global Sourcing Principles, Human Rights Policy and Code of Conduct. These policies set minimum requirements for all Brand Partners, including conducting modern slavery risk assessments and prohibiting cotton sourcing from Xinjiang, Turkmenistan and Uzbekistan. Brands must demonstrate a credible social audit programme, visibility of their Tier 1 supply chain, and mechanisms for reporting modern slavery concerns. Brands are responsible for resolving any modern slavery issues within their own operations or supply chains, and for informing M&S of actions taken. 

In Turkey we  implemented a women’s empowerment pilot programme in nine factories with a total worker population of almost 6,000 workers. This three-stage programme includes: gender gap analysis using the UN Global Compact Women’s Empowerment Principles Gender Gap Analysis Tool, employee surveys on perception of gender equality and working environment, and gender equality training.

Read more about our current programmes in our 2024 Sustainability Report.

In response to the Covid-19 health impacts on workers and communities in Bangladesh, we worked with CARE International on a project to address low vaccine uptake by urban marginalised populations. Together, we set out to ensure all 100,000 workers in 34 factories in Gazipur had access to the vaccine. CARE ran awareness training and provided electronic registration and vaccination certificates for the workers.

Read more in our 2024 Sustainability Report.

Our International Marks & Start programme began in 2004. Its aim is to reduce discrimination and provide employment, and in early 2022 a new Marks & Start programme was launched, which aims to establish a Centre of Excellence for the Apparel Industry in Sri Lanka. It supports those with disabilities, or those in other marginalised groups, to access employment.

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, over the last couple of 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 and 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 above learnings, we created Global Supply Chain Worker Voice Best Practice Guidelines.

Our Health Programmes (in Cambodia, Bangladesh, India, Sri Lanka and China), HealthWorks with Project Hope and the Reproductive Health Association of Cambodia (RHAC), the FCDO Vulnerable Supply Chains Facility (VSCF) Bangladesh projects, our Wage Digitisation Programmes, our Workplace Communications Programme, our 2012 to 2015 Factory Safety Programmes with WRAP, our long-running partnership with Emerging Leaders, and our POWER programme with the British High Commission and Change Alliance in India are retained for reference as archive content.