Responsible Sourcing and Human Rights in Food

As part of our risk assessment process for our supply chains, we map our exposure to high-risk areas with systemic risks in the areas of governance, security, human rights, or environmental challenges. To identify the countries with the highest risk, we use the following sources of information:

• the Sedex Radar portal to understand country-level human rights-related risks; 
• information and intelligence from third party audit, our worker voice programme, our Human Rights Due Diligence review programme, our projects on the ground and impact assessments we may carry out; 
• for ingredients and raw materials of most importance to M&S, our third party risk assessment by Ergon, which is then combined with an environmental risk assessment by Sancroft.  Refreshed in 2023 and 2026; 
• information received through our memberships including Ethical Trading Initiative (ETI) and FNET. 

Our suppliers must have in place established and comprehensive management systems, as this is key to ensuring they are capable of complying with all legal and relevant M&S obligations. Within our supply chain, we require that all workers are paid at least the national minimum wage. Overtime work should always be compensated at a premium rate, and where piece work is used, suppliers must be able to demonstrate that the minimum wage is always met.

We expect our suppliers to engage their workers in line with legal requirements. They are required to check that all workers have a right to work in a particular country and are of legal working age. This applies even if workers are supplied through labour providers, agents or gangmasters. For example, in the UK suppliers are expected to ensure that labour providers they work with have a valid licence from the Gangmasters and Labour Abuse Authority (GLAA).

We routinely carry out technical audits of suppliers to ensure our expectations on worker health and safety and integrity are met. All suppliers are required to be audited frequently by M&S by approved independent third-party companies, and they must commit to taking action as a result of any findings.

In addition to technical audits, we request that all high-risk suppliers (country and product area) undertake semi-announced SMETA (Sedex Members Ethical Trade Audits) bi-annually and share them with M&S. We operate under the latest SMETA 7 methodology, which includes "Collaborative Action Required" findings alongside traditional non-compliances. Since 2021, we have been using the Sedex Radar Agricultural Risk Tool to determine high-risk countries, and we have determined our high-risk industries to be Protein, Horticulture and Produce.

We recognise that ethical audits are only one tool among several to identify areas where human rights may be at risk or best practices not followed. Whilst ongoing monitoring of compliance is necessary and useful, solely focusing on individual non-compliances can result in underlying issues being missed, may not identify emerging issues, and may not support the development of a continuous improvement culture within our supply base.

As a result, in 2021 we developed a new M&S Food Human Rights Standard as a requirement for all our food supplier partners. It aims to protect the customer, maintain brand integrity, and uphold our human rights commitment. It defines six demonstrable outcomes to be achieved by supplier partners in areas such as due diligence, enabling supplier partners to assume responsibility, and training those who need help. It encourages a "beyond compliance" approach with the aim of working with our suppliers to define areas of continuous improvement, and it sets out our ethical audit requirements alongside several supporting policies and guidelines on ethical trade, including our procedure for managing instances of child labour found within our supply chain.

We updated our Foods Human Rights Standard in 2025 to reflect changes in the Sedex country risk classifications, which define our requirements of high-risk origins. We also clarified our requirements in high-risk industries, such as protein, basic produce and seafood, and signposted supporting guidance to the supply base. 

There is no place for modern slavery in any business. Employment must be chosen freely. We recognise that modern slavery is a growing global issue, and we understand the responsibility to prevent, mitigate and remediate as understood and carried out in accordance with the responsibility to respect human rights under the UNGPs. M&S colleagues and supplier partners play a major role in helping us to achieve this.

We have a zero-tolerance approach to forced labour of any kind within our operations and supply chain. We take any incidents very seriously and work with the relevant authorities and experts to ensure that individuals are protected.

We partner with several initiatives that support our suppliers and workers in our supply chain to identify and report risk of modern slavery, including Unseen, MSIN and Stronger Together. Unseen’s Helpline Business Portal, for example, alerts us to reports of potential labour exploitation within the supply chain.

M&S is a founding member of the Modern Slavery Intelligence Network (MSIN), a pioneering non-profit collaboration in the UK food and agriculture sector, created in 2020 in response to the findings of Operation Fort, the UK's largest ever modern slavery investigation. Members are coming together to achieve effective ways of working and to ensure, as far as possible, that robust mechanisms are in place to safeguard those who may be impacted by modern slavery and worker exploitation.

You can read more about our current programmes tackling labour exploitation and modern slavery in our Modern Slavery Statement. 

At M&S, we are committed to inclusion and diversity and believe everyone should feel comfortable to come to work and be themselves. We have a zero-tolerance approach to discrimination and unacceptable behaviour.

As part of our Human Rights Strategy in Food we have committed to undertake human rights impact assessments (HRIA), which provide an in-depth analysis of the salient risks to people in our supply chains. They include desk-based research and field research including interviews with stakeholders, rightsholders (workers and smallholders), and our own business.

In 2022 we completed an HRIA within our Kenyan tea supply chains, working in partnership with our supplier partners and another retailer with whom we share the same Fairtrade-certified supply chains. The assessment particularly focused on the challenges faced by smallholder farmers and women in Kenya. We have since worked alongside key stakeholders in the Kenyan tea sector to develop and deliver actions addressing the assessment's recommendations, see our "Cup of Ambition" programme above. 

M&S has a long history of working with NGO and development partners such as Emerging Leaders across the globe with the aim of enhancing livelihoods in our supply chains.

CASE STUDY: KENYAN FLOWER INDUSTRY 
The Kenyan flower industry is worth $1.15bn annually, employing 150,000 people and 2 million more indirectly. But the Covid-19 pandemic devastated the industry, with up to 50 tonnes of flowers a day being destroyed in March 2020. 50,000 people lost their jobs instantly, and had no financial safety net. Those who kept their jobs often lacked PPE and access to water. Women – around 65% of the workforce – were disproportionately affected. To support the industry, we worked alongside MM Flowers, the Fairtrade Foundation, Coventry University, Co-op and Tesco for 12 months to improve the situation. 68 farms were covered by this collaborative project, with 6,000 workers offered health packs that could protect them from Covid-19. The project also worked on improving food security and enhancing worker voice, and helped workers to diversify their farms and undertake other income-generating activities. Retailer roundtables included procurement and growers, and recommendations on policy were delivered to the Kenyan and UK governments, proposing action in four areas to build up the resilience of Kenya’s flower industry: emergency preparedness, living wages, climate change and gender equality 
  

We are committed to ensuring workers in our banana supply chain earn a living wage by the end of 2027 and continue progressing towards that ambition in partnership with IDH. This builds on our broader commitment to improving incomes in high‑risk agricultural sectors, recognising that fair pay is central to reducing vulnerability to exploitation and supporting livelihoods. Read more about our progress in the UK Banana Commitment 

Ethical Trade Initiative (ETI): we are a member of the ETI, a leading alliance of companies, trade unions and NGOs that promotes respect for workers' rights around the globe. As a member, we have adopted the ETI Base Code of labour practice, which is based on the standards of the International Labour Organisation (ILO).

Fairtrade: M&S is one of the UK's leading Fairtrade retail supporters; we have worked in partnership since 2004 and were the first major retailer to switch all our coffee and non-speciality tea to Fairtrade in 2006. Across M&S Food, we sell a wide selection of Fairtrade wines, chocolate and flowers, as well as biscuits and jams made with Fairtrade sugar. We have a commitment to 100% Fairtrade tea and coffee and sell more own-label Fairtrade tea and coffee combined than any other UK retailer. M&S has raised millions of pounds of Fairtrade Premium for farmers and workers over the course of our partnership; the Fairtrade Premium is an extra sum of money, paid on top of the selling price, that farmers or workers invest in projects of their choice, including housing, clean water, education and tree planting.  

Stronger Together: we continue to work with Stronger Together, a multi-stakeholder business-led initiative aiming to reduce modern slavery by providing guidance, training and resources in the UK, Spain and South Africa. Since 2013, through our sponsorship of the Consumer Goods Programme, 2,963 individuals have attended "Tackling Modern Slavery in Business, UK and ROI" training, representing 1, 954 sites and 707 unique businesses that have supplied M&S Food since the programme began.

Responsible Recruitment Toolkit: we are a founding sponsor of the Responsible Recruitment Toolkit (RRT), which provides support to our supply chains in ensuring responsible recruitment. Since 2019, 514 individuals have taken up at least one RRT benefit, representing 241 unique businesses that supply M&S Food.  

Emerging Leaders: we have worked with Emerging Leaders to provide leadership training to supply chain workers in Kenya, Rwanda, Malawi, Peru, Brazil, East Africa and South Africa, India, Sri Lanka and Bangladesh. The training takes participants on a journey to a new mindset and empowers them to take others on the same journey as leaders in their communities.

Sedex: we were founding members of the Supplier Ethical Data Exchange (Sedex), which aims to drive improvements and convergence in responsible sourcing practices.

Food Network for Ethical Trade (FNET): FNET is a key vehicle to drive ethical trading down the supply chain and work with industry partners and suppliers on challenging ethical issues. M&S was a founding member in 2016, and continues to play an active role

Fair Labour Association: in collaboration with the Fair Labour Association and other brands, we are part of the Harvesting the Future programme supporting our sultana and raisin supply chain partners in Türkiye to ensure good working conditions for their seasonal workforce.

Leadership Group for Responsible Recruitment: we are a member of the Leadership Group for Responsible Recruitment and are committed to the Employer Pays Principle. 

Groceries Supply Code of Practice (GSCOP). 

We are committed to building strong relationships with our suppliers. This is reinforced by the systems and controls we have put in place to comply with the Groceries (Supply Chain Practices) Market Investigation Order (the Order) and the Groceries Supply Code of Practice (GSCOP).

We have reflected the requirements of GSCOP into our Terms of Trade Supply Agreement, which governs the trading relationship between M&S and our suppliers of food and household products. 

We have appointed a Code Compliance Officer who is supported by our in-house legal department, and we provide training on the requirements of GSCOP including refresher programmes and training for new starters. We believe we are in full compliance with the Order and GSCOP and work closely with our suppliers to resolve any concerns. If you would like to know more about GSCOP, watch this brief video introduction from our Code Compliance Officer. Each year we prepare an annual compliance report which we submit to the Competition and Markets Authority and Groceries Code Adjudicator, and we include a summary in our Annual Report. 

GSCOP Contacts

If you are an M&S supplier and have a GSCOP related query, please contact our Code Compliance Officer [email protected]

If you are an M&S supplier and have an invoice or payment related query please contact our Vendor Support help desk [email protected]

The Groceries Code Adjudicator (GCA)  

Contact details for the GCA and more information can be found on the GCA website Groceries Code Adjudicator