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.
Our Global Sourcing Principles
set out our minimum global supplier standards on health and safety, labour standards, environment, business ethics, equality and community human rights topics. These standards apply across our entire business.
The process is managed by our specialist Sourcing Office compliance teams located in Turkey, India, Sri Lanka, Bangladesh, China, Cambodia and Vietnam. Our Sourcing 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
ethical audit. The majority of sites use Supplier Ethical Data Exchange (Sedex) ethical audit methodology and are registered on Sedex. Sedex is the largest collaborative platform for sharing ethical supply chain data.
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. 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.
We may in certain circumstances consider accepting Better Work assessments, FastForward, WRAP, ICTI, SA 8000 and Business Social Compliance Initiative (BSCI) audits (if, for instance, they have conducted within the last year) and the full reports are made available to us for review.)
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 critical, high risk or low risk.
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:
- 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 inadequately, 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.
Newly proposed sites that are rated as 'Critical' will not be approved for set-up and production, until all the critical issues have been resolved. As a minimum, the factory will be rejected for 12 months. 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 2020 to 31 March 2021
|Continent||Supplier sites ||Audited supplier sites ||Workers at supplier sites||Audited workers||Number of audits ||Improvement Required ||Improvement Required per audit|
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 collaborative working and advocacy initiatives to improve the performance in identifying and managing ethical trade issues.
Figure 1: Top 5 ethical non-compliance issue areas identified through audits in 2020/21