Any of our business? Human Rights and the UK private sector - Human Rights Joint Committee Contents

Memorandum submitted by Associated British Foods/Primark


  Associated British Foods plc (ABF) is a diversified international food, ingredients and retail group with sales of £8.2 billion and over 96,000 employees in 44 countries.

  Primark, a subsidiary company within the Associated British Foods group, is a major value retail group, operating 190 stores with 5.7 million sq ft of selling space in the high streets of the UK, Ireland and Spain.

  Primark sources goods from 36 countries in three continents. We strive to maintain the highest possible standards, and we keep our policies in relation to ethical trading and ethical supply chain issues under constant review.

  We welcome this opportunity to contribute to the important work the Joint Committee on Human Rights is conducting, and we look forward to giving evidence to the Committee on 30 June 2009.


  Our starting point is that trade with and in developing countries is good for those countries, its people and local economies—and that it is good for the UK economy. Indeed, at a time of rising unemployment, ABF/Primark has created 900 jobs in the UK alone.for this financial year

  Primark contributes to the employment of over 630,000 workers, and it is estimated that two million people are supported indirectly. Indeed, between September 2007 and September 2008 ABF/Primark invested £700 million in developing countries and our investment programme is on-going.


A principle based approach:

  Primark do not own the factories it sources from and so we have in place a Code of Conduct to ensure the highest possible standards from its suppliers. We are committed to sourcing ethically and our code states the following within our supply chain:

    — Employment is freely chosen.

    — Freedom of association and the right to collective bargaining are respected.

    — Working conditions are safe and hygienic.

    — Child labour shall not be used.

    — Living wages are paid.

    — Working hours are not excessive.

    — No discrimination is practised.

    — Regular employment is provided.

    — No harsh or inhumane treatment is allowed.

Ethical management:

  Primark takes these responsibilities very seriously: ethical trade is a permanent agenda item at Primark Board meetings; and day-to-day management of ethical issues is driven by our UK-based ethical trade team, working closely with our growing network of regionally-based ethical trade managers.

  Central to ensuring that our supply chain responsibilities are being upheld and adhered to is auditing. In recent years we have intensified the auditing process, prioritising the largest suppliers and products and countries considered to be the biggest risk. We are consolidating our supply base and doubling the number of audits carried out so that in 2008 a total of 567 were completed and in 2009 1,000 factories will be audited.

  Primark also has a commitment to remediate and train directly employed personnel, as well as suppliers. In addition we are developing our network of third party auditors, and we have created a new, online database to help support our internal auditing and tracking processes.

Working with others to make a difference:

  We recognise that we need to work with others to address these challenges. For example, in Bangladesh we work with a respected NGO, NUK, to focus on women's rights; with them we are working with 16 of our contract factories to improve labour standards in those facilities.

  Similarly, in the Tirupur region of India we are working with SAVE, an established NGO, who are conducting an extensive three year survey on our behalf to identify at risk groups in the communities of the factories who supply to us and others in the industry.


  The challenges and issues Primark face in terms of sourcing as ethically as possible are shared problems across the industry. Indeed, more than 95% of factories supplying Primark also supply other international brands, meaning that the issues we face are the same issues that most other retailers face too.

  The need for industry wide solutions to these challenges is widely accepted. In the UK, the Ethical Trading Initiative exists to promote improving standards and to challenge all parts of the industry to improve standards.

  Primark attaches huge importance to its relationship with the ETI, of which we are active members, included in various working groups: ETI UK China Forum, Wages Working Group; Home Workers Group in Delhi, India; UK National Home Workers Group; Principles of Implementation Process Group, and finally we recently joined the Purchasing Practices Working Group.

  Like the ETI, and many others in the industry, we recognise that the only way to successfully ensure that supply chains are ethical, and that standards continue to improve, is through collective action from all parties: retailers, suppliers, NGOs, pressure groups and governments, who have a vital role to play in terms of enforcement of standards in their jurisdictions.

  Associated British Foods and Primark appreciates that these are complex and sensitive issues. We take our responsibilities very seriously. The issue of ethics in a business context is constantly evolving, and we intend to continue to play our part in addressing these issues. We look forward to discussing these important matters further on 30 June 2009.

Paul Lister

Director of Legal Services and Company Secretary

Associated British Foods plc

June 2009

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