It’s important to us that we can monitor the coverage and effectiveness of the steps we take to maintain respect for workers’ rights and the environment in our supply chains. That’s why we have a range of measures in place to hold our business and sites in our supply chains to high standards and drive continuous improvement. ### Reporting back and measuring progress Following any audit, our team gives the factory a Corrective Action Plan. This plan details any non-compliance issues with our Code of Conduct and lays out a mutually agreed, time-specific action plan to resolve the issues identified. This plan is signed off by the factory at the end of the audit. We know that many workers depend on our business for a living. That’s why we prefer to work with suppliers and their factories to help them address any issues identified in an audit. But, if we find anything critical, we take swift action. We’ll stop placing new orders until we’re confident the changes have been made. We always seek to remedy issues of non-compliance with our Code of Conduct in a way that will benefit the workers. We do everything we can to support factories to improve, but in the most extreme cases, where we feel our trust has been misplaced and a supplier is unwilling to make the necessary changes, we will walk away. ### We listen and take grievances seriously Our goal is that any and all workers anywhere in our supply chains, and any other relevant stakeholders, can report grievances and receive effective remedy through effective workplace grievance mechanisms. Our approach must be fully comprehensive and go beyond using access points, such as hotlines and suggestion boxes. It needs to be comprehensive. Grievance mechanisms (GM) can be government or industry led or may be focused on improving communication to help develop a more formal, factory-level GM. They can be managed internally by the factory or provided by a third party. Whatever the GM model, we’ve developed tools to help implement our approach across our supply chains. Where possible, we seek to support workers to access existing grievance mechanisms, often by raising worker awareness. We may invest in an existing GM, or design and implement independent GMs if workers can’t access effective factory or independent mechanisms. Our approach is driven by the following principles: 1. Adherence to best practice frameworks, particularly the UNGPs. 2. Appropriate response to supply chain risks. 3. Interventions should not undermine effective factory grievance mechanisms but support their development and implementation. 4. Interventions are sensitive to, and appropriately engage with, existing dialogue structures. ### Taking a tailored approach Our methodology is tailored to meet country specific needs and circumstances, for example we prioritize access to remedies for more vulnerable groups. As factories’ abilities to build GMs and their willingness to deliver interventions varies, depending on business leverage, factory capacity and willingness to implement interventions, and the presence/efficacy of legally required grievance mechanisms, where necessary we will help to develop solutions to address workers’ grievances. Bangladesh We’re already embedded into the grievance procedures of the Accord (RSC) in Bangladesh, established following the collapse of Rana Plaza. In 2020 we also signed up to the Amader Kotha hotline, which covers 68 factories in our supply chains and we’re working to train and support factories to use this service. To date, twelve grievances have been escalated to us via this channel, most of which relate to harassment and bullying. UK In 2020 we worked with a UK consulting firm, Impactt, to launch a pilot hotline in our UK warehouses and logistics operators. We currently have 10 sites involved in this pilot and eight have seen grievances raised so far. We’re currently finalizing a review of the pilot in order to decide how to take this forward. Turkey We’re part of a collective hotline run by the Turkish NGO, MUDEM, set up to support Syrian workers. All our Turkish suppliers have been made aware of this hotline and we’ve delivered training to 24 factories where refugees are recruited. To-date we have had one case raised to us via this channel, which involved discrimination. ### Taking action. Resolving issues. For any potentially critical issues we take immediate action to investigate thoroughly. And if we find a problem we take steps to solve it , while protecting the confidentiality of victims and those affected. Our team of local experts is critical to ensuring remediation is effective and appropriate. We also work with specialist organizations and civil society partners who are experts in their field. Because we have built trusted relationships with our partners over many years, we can draw on their expertise and support quickly. Wherever possible, we seek to ensure that any provision of remedy is satisfactory to those affected. We regularly share information on our experiences and the challenges of providing effective remedies within our sector. These can be found on our website, through reports to stakeholders and via industry forums such as the ETI and the OECD. ### Partnerships and Capacity Building We run a global portfolio of programs, projects and collaborations to help build the capacity of factories in the supply chains to provide a better environment and experience for workers. We believe that if we help workers better understand what they can and should expect from their employer, we can help empower workers and further improve working conditions in factories. These projects are often developed and implemented with a range of external partners. Some examples are listed below. In Bangladesh we’ve partnered with the Ethical Trading Initiative on its Social Dialogue Programme. Bangladeshi law requires all factories with more than 50 employees to have a Participation Committee made up of elected worker representatives. The project helps factories set up these Committees. We also work to ensure that the workers who sit on these committees are chosen by their peers and able to communicate between colleagues and management. The Programme trains committee members on key aspects of their role, including understanding labour law, handling grievances and effective communication. Alongside this we run a number of other worker empowerment programs to help strengthen workers’ understanding of their rights and responsibilities in the workplace and address workers’ needs, particularly those groups who may be more vulnerable. We’ve learned that the most effective way to deliver these programs is through strong partnerships. Many of our partnerships are with grassroots civil society and development organizations as they bring many years of experience and build trusted relationships with factories and workers through our teams on the ground. Our partners are critical to ensuring our programs are meeting the needs of workers and are appropriate for the local context. We work with a number of invaluable partners to implement the India Worker Empowerment Programme (IWEP). This Programme consists of several projects, with a focus on female and migrant workers in South India. Through partnerships with international NGO Women Win and local implementation partners, including SAVE, St John’s Medical College, and the Naz Foundation, we’ve created a portfolio of projects designed to train vulnerable workers on basic life skills and educate them about their rights and responsibilities in the workplace. You can find out more about these projects under People. ### Gender-Based Violence & Sexual Harassment We recognize that women face increased risks in the supply chains. We also acknowledge the important role that Primark, our industry, and business overall can play in helping to meet UN Sustainable Development Goal 5: “Achieve gender equality and empower all women and girls”. We’ve learnt that the pervasive nature of gender inequality requires a gender focus across all our work, from auditing factories against our Code of Conduct, to training our team on gender issues and collaborating with key stakeholders that are focused on women’s rights and women’s empowerment. With the advent of the #MeToo movement, it became clear that gender-based violence (GBV) was prevalent in many parts of the global garment industry. We want to strengthen our approach to this serious and complex issue, which is now embodied in ILO Convention C190: Violence and Harassment in the World of Work. In 2019 we partnered with Business Fights Poverty in the development of a toolkit to identify and share examples of best practice from within and beyond the garment sector. ### Putting a stop to sexual harassment In 2019, we started working with international NGO and experts in GBV, CARE International, to implement the STOP project. STOP was already underway in Cambodia and, as part of our collaboration, we decided to expand to Vietnam. The objective of STOP is to reduce sexual harassment in the workplace, allowing women workers in garment factories to feel safer at work and enjoy improved working conditions. The project takes a holistic approach, combining factory interventions and community outreach. It employs a broad range of initiatives to tackle sexual harassment including improving factory policies, management’s attitudes, and grievance mechanisms, alongside building workers’ awareness, understanding and trust. We’ve helped to implement STOP in seven factories: five in Cambodia and two in Vietnam. The project delivers support and training to help factories prevent and respond to sexual harassment. The project has delivered training to sensitize factory leadership and middle management to issues of sexual harassment. It has also run worker awareness-raising campaigns, using leaflets and training and sessions to empower female workers to report sexual harassment. ### Looking to the future Our collaboration with CARE International was designed as a year-long pilot, which is now complete. We’re currently assessing the positive impact of the STOP project and incorporating what we’ve learned into our future plans. The project has successfully led to the implementation of the CARE Sexual Harassment Prevention (SHP) Policy in all five factories in Cambodia, as well as the establishment of Sexual Harassment Prevention Committees (SHPC) with representatives from HR, trade unions, workers, nurses and line leaders. Capacity building exercises and training have reached 887 workers in total, 622 of whom were women, and factories now have systems in place to report cases of sexual harassment. We’re looking at ways to scale up projects like STOP beyond Cambodia and Vietnam. We’re aware of the complexity and sensitivity of this issue and appreciate the limitations of a one-size-fits-all approach, so we’re exploring how to develop a scalable approach that can adapt to each local and cultural context. We recognize the need to continue to drive change across multiple areas related to the topic. Through ongoing monitoring and evaluation of our activities, dialogue and partnerships with experts, and encouraging greater ownership of these issues among the business partners in our supply chains, we will continue to identify gaps, expand and deepen our approach, and strengthen our impact on this critical issue.