Our Responsible Sourcing Standards
We continue to push for fair and safe working conditions for the people making our products, driven through our Ethical Trade and Environmental Sustainability Program which is now over 15 years old. In 2021, we launched the Primark Cares strategy to build on this strong foundation.
We've set policies and procedures that define the standards we expect and mandate from our suppliers and team members. Our approach is centered on our commitment to human rights through our Supplier Code of Conduct and Supply Chain Human Rights Policy.
Supplier Code of Conduct
It’s our responsibility to respect human rights and the environment in our supply chain. Our Supplier Code of Conduct is the foundation of our Ethical Trade and Environmental Sustainability program. Our Supplier Code of Conduct covers areas of workers’ rights like payment of wages, health and safety, and freedom of association, in addition to prevention of key risks like forced labor and discrimination. It applies to any supplier making our products.
Supply Chain Human Rights Policy
Our Supply Chain Human Rights Policy sets out our approach to human rights due diligence and our commitment to protect the rights of the people who make our products, as well as those providing the goods and services to help us run our business.
Environmental Policy
Our Environmental Policy sets out our key environmental focus areas, including: responsible sourcing, chemicals management, resources and waste, energy efficiency and greenhouse gas (GHG) reduction, water efficiency and conservation, and animal welfare and biodiversity, which guide our approach to reducing our environmental impact.
Speak Up Policy
We’re committed to providing confidential reporting channels to team members working directly for Primark in addition to Primark shareholders, agents, contractors, external consultants, third-party representatives, business partners, and sponsors, so they can report anything they believe to be inappropriate, improper, dishonest, illegal or dangerous. Our Speak Up mechanism can be accessed anytime online or by phone.
Tell Us Policy
We’re committed to providing confidential reporting channels to management and workers in our supply chain, so they can report anything they believe to be inappropriate, improper, dishonest, illegal or dangerous. Our Tell Us mechanism can be accessed anytime through the website, a QR code or by phone.
UK Modern Slavery Statement
In line with the UK Modern Slavery Act, we publish a Modern Slavery Statement annually. This sets out the measures we have taken during the past year to mitigate against the risks of modern-day slavery and human trafficking in our supply chain or within our operations.
Our Social Audit Program
Any Tier 1 factory approved to make our products for resale is audited at least once a year. Like most brands, we don't own the factories where our products are made, and these audits check whether our suppliers and their factories meet our Supplier Code of Conduct requirements.
They're managed by our teams in sourcing markets who understand local regulations and are trained to identify risks and work with suppliers and factory management to drive workplace improvements. We bear the full cost of these audits, which are undertaken by Primark or a third party on our behalf, and most of which are unannounced.
Any new factory must undergo a social audit as part of our onboarding process. No orders are placed until the factory has been audited and approved. Following an audit, supplier factories are issued with a corrective action plan (CAP) that outlines areas for improvement. In some cases where we have identified particular risks to workers, we implement additional human rights due diligence activities. These include many of the social impact programs that come under our Primark Cares commitments, like our My Life program for vulnerable migrant workers in India.
These social audits provide a detailed report of factory conditions. We assess fire and machine safety, review documentation, and conduct confidential interviews with workers to hear about their experiences firsthand. These interviews are crucial for understanding workers’ realities and addressing any issues they may face.
Additionally, we are a member of the ILO’s Better Work Program which incorporates audits and advisory services for Tier 1 factories.
Our Risk Assessment
We conduct due diligence to identify risks throughout our business, aligned with industry best practice. Our approach focuses on the following:
Country risk assessments
We use independent external databases and publicly available, credible information sources to build assessments for every country we source from. This helps us understand the risk profile of our sourcing countries and root causes of the risks, in addition to identifying stakeholders we can engage with locally.
Analysis from our own data
Our local teams monitor our supply chain to ensure our workplace standards and policies are being met, and to help prevent and manage risk. Data from our social audit program is central to this.
Stakeholder engagement
External stakeholders are a vital source of information and guidance. They help us understand the risks in our supply chains, how to identify them, and which groups may be most vulnerable. Read more here on our engagement.
Rights holder consultation and worker engagement
We have built trusted partnerships with local and regional stakeholders to give us ongoing insight into workers' needs. Our local teams also regularly engage with factory management and workers. This provides important feedback about the issues they face, and the impact of our work with them.
Our Worker Engagement and Grievance Mechanisms
Direct engagement with workers is fundamental to supporting our commitment to decent, safe workplaces. Our local teams speak directly with workers during audits and through our social impact programs. This lets us better understand and respond to their workplace needs and experiences. Grievance mechanisms which let workers raise issues in the workplace are an important aspect to protecting workplace rights, and is part of our Supplier Code of Conduct.
Our widely available, Primark-funded grievance mechanism called Tell Us has been progressively rolled out and is accessible to all workers in our supply chain. We launched Tell Us in Bangladesh in December 2023, and it has been rolled out to a further countries by the end of August 2024 to suppliers making goods both for resale and not for resale.
We also receive grievances through other channels, including the customer services section of our website, confidential worker interviews during social audits, and workers having direct contact with Primark team members and our partner organizations. When issues or grievances are raised, we take steps to investigate thoroughly while protecting the confidentiality of those raising the complaint, and anyone else who might be affected. We do not tolerate any retaliation against those who have raised a grievance or against any affected stakeholders.
Key partners supporting us in this work:
ACT Dispute Resolution Mechanism
Since 2015, we’ve been a member of Action, Collaboration, Transformation (ACT). The Interim Dispute Resolution Mechanism, launched in November 2020, has played a crucial role in addressing worker grievances in Bangladesh, Cambodia, Myanmar and Türkiye related to rights such as Freedom of Association, retrenchment, and wage payments.
Amader Kotha
The Amader Kotha Helpline is a collaboration among three project partners: Clear Voice, a project of The Cahn Group that operates hotlines and builds effective grievance mechanisms in supply chains; Phulki, an established civil society organization working to improve the lives of workers and their families in Bangladesh; and LRQA, the supply chain risk and sustainability solutions provider globally. Each partner brings years of experience building labor compliance programs in supply chains.
Hamary Awaz, Pakistan
The Hamary Awaz Helpline is a collaboration between Baidarie, a Pakistan-based civil society organization addressing the grievances of women workers in the formal and informal sectors; LRQA, a business risk and sustainability solutions provider, and The Cahn Group, a corporate responsibility solutions provider building effective grievance mechanisms in supply chains. Training and other support is provided by Phulki, an established civil society organization working to improve the lives of workers and their families in Bangladesh.
The Handshake Workers’ Hotline, China
In 2024 we joined the Handshake grievance mechanism in partnership with local partner INNO. Inno launched the Handshake Worker’s Hotline in 2007, which has since developed into Asia’s largest non-judicial grievance mechanism, benefiting over 2.4 million individuals in 1,040 factories including international locations. This program facilitates open communication between workers, suppliers, and buyers in labor-intensive industries.
Our Structural Integrity Program
Workers who make our clothes have the right to a structurally safe working environment. The Primark Structural Integrity Program, established in 2013, helps us assess the safety of our suppliers’ factory buildings against international standards. We survey the Tier 1 sites of our supplier factories in Bangladesh, Pakistan and Cambodia, and Primark Cotton Project mills in Bangladesh, Pakistan and India, as well as providing ad hoc support as needed in other sourcing countries.
Primark is also a signatory to the International Accord for Health and Safety in the Garment and Textile Industry, which currently operates in Bangladesh and Pakistan.
Our Traceability Program
Supply chain traceability is a complex area that's always evolving. We keep advancing our processes in this context. Our online Global Sourcing Map covers the Tier 1 factories that make our products, in addition to showing the number and gender of workers at each site shown. The map is updated annually and is also added to the Open Supply Hub.
Global Sourcing Map
Traceability is an important part of making sure the fibers used in our products meet our standards, and since 2022, we've been rolling out our Traceability program. We've partnered with the TrusTrace platform and are using its software to map our products’ supply chain, from raw material to finished product. We started with cotton-based products, because it's our most used fiber. We've since expanded the program to include more suppliers, fibers and products, and it covers the four main materials Primark uses: cotton, polyester, nylon and MMCFs like viscose.
We've also built traceability into the Primark Cotton Project (formerly the Primark Sustainable Cotton Program) to help identify the origin of our cotton, and to help us meet growing legislative requirements around fiber transparency. We use Cotton Connect’s digital traceability platform, TraceBale, to track the cotton from farmers in the Primark Cotton Project as it moves through our supply chain, from ginners to spinners. To give us greater assurance, we partnered with Oritain, a specialist verification firm which uses forensic science techniques to confirm the cotton’s origin.
Read about the Primark Cotton Project here.
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