Act ethically
While the company has a policy prohibiting bribery and corruption, it could formalize this stance in a public policy document and describe the process for identifying risks and impacts related to bribery and corruption in its own operations. Although the company makes political contributions after approval from the President and CEO, it has an opportunity to clarify if these are exceptional cases and to disclose the criteria used for such contributions. Additionally, the company could disclose its lobbying expenditures and specify that it requires third-party lobbyists to adhere to its lobbying and political engagement policy.
Provide and promote decent work
While the company monitors the health and safety performance of its business relationships, it could disclose the specific methods used for this monitoring. Although the company pays its employees a minimum wage, it has the opportunity to set a time-bound target for paying a living wage. The company could also require its suppliers to pay a living wage and disclose how it supports this. While committed to diversity, the company could formally commit to gender equality and women’s empowerment. Although the median and mean gender pay gap is disclosed for its UK operation, the company has not provided evidence that it discloses the ratio of basic salary and remuneration between women and men across all employee categories, by significant locations of operation.
Respect human rights
The company has a publicly available policy statement committing to specific workers’ rights, but could strengthen this by referencing all ILO fundamental rights at work for both its operations and its suppliers. While the company conducts a materiality risk assessment and addresses modern slavery risks in its operations and supply chain, it has an opportunity to describe its process for identifying human rights risks and impacts in specific locations or activities, extending beyond modern slavery risks. The company could also disclose its method for assessing what it considers to be its salient human rights issues, as well as the results of its human rights risk assessments. Although the company addresses modern slavery risks across its global supply chain, it has not provided evidence that it has a system to prevent, mitigate, or remediate all its salient human rights issues.