Act ethically
The company has a monitoring system to identify bribery and corruption but could disclose details of this identification process. While there is a mechanism for stakeholders to report concerns, it’s unclear whether it’s available to all stakeholders and if complainants can choose anonymity.
Moreover, the company can demonstrate ethical practices by disclosing a policy setting out its approach to lobbying and political engagement, clarifying its non-participation in political contributions, and adding requirements to third-party lobbyists to adhere to its guidelines in lobbying and political engagement activities.
Provide and promote decent work
The company has an opportunity to strengthen its commitment to workers’ health and safety by providing evidence of monitoring suppliers’ compliance. Furthermore, it could set a time-bound target for ensuring all workers receive a living wage and describe the living wage determination methodology for the regions where it operates. While it has set expectations on the wage paid by suppliers, it could add a requirement for them to pay a living wage and to disclose how it supports the payment.
While the company has a statement on gender equality and women’s empowerment, it has an opportunity to solidify this into a public policy document and to disclose time-bound targets. The company discloses the gender pay gap ratio of whole group employed in Great Britain except one of its subsidiaries, Primark, which reports separately. However, it could disclose the ratio of the basic salary and remuneration of women to men across all employee categories by significant operation locations.
Respect human rights
The company has an opportunity to strengthen its commitment to human rights in its operations by referencing all the ILO fundamental rights at work in its commitment statements in respecting workers’ rights. It could consolidate its public statements on respecting human rights and workers’ right into a formal policy document and outline the methods it uses to identify human rights risks, including the results of its human rights risk assessment.
While the company discloses its approach to assessing modern slavery risks among suppliers or in specific regions, it lacks a comprehensive process to determine which human rights are most at risk in its overall operations, allowing prioritizing the most salient ones. Moreover, the company could establish a global system to act on, prevent or mitigate its salient human rights issues.