Our StandardsWe’re going to make it possible to buy better – to give Primark customers the opportunity to make more sustainable choices at a price they can afford.
To do this, we are threading sustainability through our own operations and across our supply chains. We also want to make it easier for everyone to see what a more sustainable approach looks like in the products we sell and in how we do business.
To help us achieve this we’ve put policies and procedures in place to ensure that our suppliers meet our high standards. And that if issues or concerns arise, they’re quickly brought to our attention.
Our Code of Conduct
Our Code of Conduct is the backbone of our Ethical Trade and Environmental Sustainability Programme. This robust set of requirements forms a key part of the Primark terms and conditions of trade.
We don’t own any of the factories that make the products we sell, but we’re very selective about who we work and we only do so if they agree to standards set out in our Code of Conduct. These standards must be met in every site producing products for Primark and we have rigorous processes in place to check that they are upheld.
The 13 clauses in our Code of Conduct cover a range of issues including our zero-tolerance approach to child labour and bribery, workers’ rights to form a trade union and ensuring people don’t work excessive hours. It also includes our expectation that every factory supplying Primark is maintaining appropriate environmental practices.
Each factory has to be approved by our Ethical Trade team, before any orders are placed, and only if the required standards are met. Once approved, it’s the job of this team, a group of more than 130 experts on the ground in our key sourcing markets that carry out around 3,000 social audits every year and monitor ongoing compliances. Working with a small number of carefully selected third parties, our teams audit every factory at least once a year, sometimes more, to check whether international standards are being met. Where issues are found, the team will engage with suppliers and their factories to support with remediation to help them find solutions, training and setting up collaborative projects to protect and promote worker welfare.
We’ve been a member of the UK Ethical Trading Initiative (ETI) since 2006 and since 2011 we’ve been regarded as having leadership status. The ETI Base Code, which is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice, forms the basis of the Primark Supplier Code of Conduct.
Our commitment to the environment
Becoming a more sustainable business is a journey and we’re not starting from scratch. But we know we need to go a lot further and a big part of that is about reducing the impact our business has on the planet.
We have a global team of environmental sustainability experts who work directly with our suppliers and their factories, and in partnership with external organisations.
Our Environmental Policy sets out our environmental intentions and outlines our commitment to sustainability. It explains our expectations that our products are manufactured in a more sustainable way. This means responsible sourcing of raw materials, such as cotton.
We believe in honest, open communication
We encourage an open culture in all our dealings and support effective and honest communication. As a subsidiary of Associated British Foods Plc (ABF), we’ve adopted their Whistleblowing Policy to provide guidance for anyone who wants to raise any issues with Primark. This ensures they can voice their concerns in confidence safe from retaliation or detriment. We also have a programme of support to help ensure that workers can access effective grievance mechanisms.
We want people to feel safe at work
Our highest priority is to keep workers safe. Since 2013 we’ve implemented a structural integrity programme. This helps us to identify potential risks in countries where building standards are not implemented properly, these factory building surveys are undertaken against country-specific national standards.
We undertake comprehensive and rigorous factory building surveys for all of our first and second tier sites in Bangladesh, Pakistan and Myanmar. If these identify areas that require improvement we work with a team of structural and civil engineers from international engineering firms, including Mott MacDonald and Aecom, to provide factories with technical support and guidance to remedy any issues identified.
Find out more about the various standards we hold our business and our suppliers to below.
Risk identification and action
We continuously conduct due diligence to identify risks across our business. The process we use is the result of in-depth benchmarking and consultation with human rights organisations. It aligns with the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector.
Our approach consists of four main components:
1. COUNTRY RISK ASSESSMENTS:
We conduct research using existing external reports and publicly available, credible information sources to build assessments for every country we source from. This includes political, economic, social and legal analysis and risk-mapping. Assessments look at both the garment and footwear sector as well as additional sectors and industries. This helps us to:
- Build a comprehensive picture of the risks in each country in our supply chains, including some of the most salient risks, such as forced and child labour.
- Understand the deeper root causes of these risks.
- Identify key stakeholders and initiatives working on these issues that we can engage with and learn from.
2. ANALYSIS FROM PRIMARK INTERNAL DATA:
Our local Ethical Trade and Environmental Sustainability teams are one of our most important resources – they’re our ‘eyes and ears’ on the ground. Our team of over 130 local experts, based in our major sourcing countries, were recruited from a range of different organisations including other companies, development agencies and civil society.
The teams are responsible for monitoring the supply chains to ensure our workplace standards and policies are being met and for helping our supply chains to better prevent and manage risk. They’re able to engage directly with workers in our supply chains and our external partners and experts on the ground.
We’re also able to draw from intelligence and analysis of over 34,000 audits conducted on Primark’s suppliers since 2007, which are held in our central audit database.
3. STAKEHOLDER CONSULTATION:
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. Their insight and knowledge is invaluable.
External stakeholders also assist in the development of strategies and approaches to prevent or resolve issues. Stakeholders can include civil society groups, trade unions, governments, international agencies, intergovernmental agencies, multi-stakeholder initiatives (MSIs) and legal experts.
We’re an active member of a number of industry collaborations. We were one of the founding members of the ACT initiative on living wages in 2015; have been a member of the UK Ethical Trading Initiative (ETI) since 2006; and were one of the first brands to sign the Accord on Fire and Building Safety in Bangladesh following the Rana Plaza tragedy in 2013.
We care about the livelihoods of the people who make our products. We’ve worked really hard with our suppliers in the last ten years to improve the factories we use in terms of working conditions, treatment of workers and pay.
We follow and support legislation to address risks across the garment industry and are supportive of such measures. We took part in UK Government consultations on the development of the UK Modern Slavery Act 2015 and provided feedback and insights from our programme. As the UK is due to review its modern slavery strategy in 2021, we will continue to provide relevant information and support.
We’ve also engaged with the UK Government’s Environmental Audit Committee, as well as the Department for Business, Energy and Industrial Strategy and Department of Foreign Affairs Committee, to feed into their inquiries and identify focus areas.
In the EU we’ve contributed to consultations on the introduction of mandatory due diligence legislation at regional level and within Member States and we support moves to introduce such a framework.
4. RIGHTS HOLDER CONSULTATION AND WORKER ENGAGEMENT:
Workers in the supply chains have clearly defined rights yet are often excluded from the due diligence process or face obstacles in getting their voices and views heard. We have worked at building trusted partnerships with local and regional stakeholders to give us ongoing insight into the needs of workers. Our local teams also regularly engage with factory management and workers. This not only provides important feedback about the issues they face, but also into the impact of our work with them.
For example, in the wake of the Covid pandemic we partnered with Microfinance Opportunities, a US-based NGO, and SANEM, their local partner in Bangladesh, to establish a six-month project called Soromik er Kotha. It was set up to collect data to help us understand workers’ views and experiences in the workplace. The project was modelled on the Worker Diaries project in Bangladesh. We established a sample of 400 workers from across various factories in Primark’s supply chains, all recruited via community networks and paid for their time engaging with the project. We collected their answers to a set of questions at defined intervals to gain an understanding of their views on a range of areas including health and safety in the workplace, payment of wages and bonuses, and retrenchment. Our aim for the project is to generate valuable data and insight to help us understand and be better able to respond to the challenges being faced by workers in Bangladesh.