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In March 2020 Ethical Consumer searched the P&G website for a cotton sourcing policy. Although the company sold products, such as tampons, made from cotton, no policy could be found.

According to Anti-Slavery international (ASI) website viewed by Ethical Consumer in August 2018, Uzbekistan and Turkmenistan were two of the world’s largest exporters of cotton, and every year their governments forcibly mobilised over one million citizens to grow and harvest cotton. Due to the high proportion of cotton likely to have come from Uzbekistan and Turkmenistan and the prevalence of forced labour in its production, the company lost half a mark in the Workers Rights category.

The Organic Trade Association website,, stated in July 2018 that cotton covered roughly 2.78% of global arable land, but accounted for 12.34% of all insecticide sales and 3.94% of herbicide sales. Due to the impacts of the widespread use of pesticides in cotton production worldwide the company also lost half a mark in the Pollution & Toxics category.

According to the International Service for the Acquisition of Agri-Biotech Applications (ISAAA), a non-profit pro biotech organisation, genetically modified cotton accounted for 80% of cotton grown in 2017. Due to the prevalence of GM cotton in cotton supply chains and the lack of any evidence that the company avoided it, it was assumed that some of the company's cotton products contained some GM material. As a result it lost half a mark under the Controversial Technology category.

Overall the company received Ethical Consumer's worst rating for its cotton sourcing policy.

Reference: (3 May 2019)

In March 2020 Ethical Consumer viewed the Procter and Gamble page on The company and its employees were listed as having given $308,857 to both left- and right-wing US political parties during the 2020 election cycle. The company had also spent $3.54m on lobbying in 2019.

The page also stated that 30 out of 34 Procter & Gamble lobbyists in 2019 had previously held government jobs.

The organization itself did not donate, rather the money came from the organization's PACs, their individual members or employees or owners, and those individuals' immediate family members. Organizations themselves cannot contribute to candidates and party committees. Totals include subsidiaries and affiliates.

P&G therefore lost a whole mark under Political Activities.


Open Secrets generic ref 2020 (2020)

In February 2020 Ethical Consumer updated its list of the members of those groups it considered to be free trade lobby groups, exerting undue corporate influence on policy-makers in favour of market solutions that were potentially detrimental to the environment and human rights.

Procter and Gamble was listed as a member of the following free trade lobby groups:

National Foreign Trade Council (NFTC)
World Economic Forum
Business Roundtable

As a result, it lost a half mark under Political Activities.


Ethical Consumer Lobby Group member list (19 February 2020)

In April 2021 Ethical Consumer viewed P&G's US Securities and Exchange Commission (SEC) filing DEF 14A Proxy Statement August 2020, which included details of executive pay. According to this filing, the lowest-paid named executive officer was paid a total of $6,248,679 and the highest paid (the CEO) received payments totalling $22,905,128.

Ethical Consumer considered payments over £1 million to be excessive. P&G therefore lost half a mark under Anti-Social Finance.


DEF 14A August 2020 (30 April 2021)

In May 2021 Ethical Consumer viewed P&G's US Securities and Exchange Commission filing Exhibit 21 for the financial year 2020, which listed the company's subsidiaries. P&G had multiple subsidiaries in jurisdictions on Ethical Consumer's list of tax havens at the time of writing. Of these, several were holding companies or financial companies, which were considered high risk company types for likely use of tax avoidance strategies:

Gillette Holding Company LLC - Delaware
Gillette Latin America Holding B.V. - Netherlands
Procter & Gamble Amazon Holding B.V. - Netherlands
Procter & Gamble Brazil Holdings B.V. - Netherlands
P&G Hair Care Holding, Inc. - Delaware
Procter & Gamble Finance Management S.a.r.l. - Luxembourg
Procter & Gamble Financial Services S.a.r.l. - Luxembourg

P&G had published a its 'Core Tax Principles' on its website. The summarised principles were:

- Tax follows business substance
- Highest level of compliance with financial and tax reporting requirements
- Robust tax stewardship and governance
- Transparency in relationships with governments and tax administrations
- Support for efficient, consistent, and administrable tax and trade policies

The company made no clear statement which explicitly mentioned tax avoidance or tax havens, nor did it explain the existence of a number of holding companies in countries considered by Ethical Consumer to be tax havens. P&G also did not publish country-by-country financial information.

An internet search using the search terms “[company name] tax policy statement country” found no country-by-country financial information or reporting (CBCR), nor clear public tax statement confirming that it was this company’s policy not to engage in tax avoidance activity or to use tax havens for tax avoidance purposes.

Overall P&G received Ethical Consumer's worst rating for likely use of tax avoidance strategies and lost a whole mark under this category.


10-k filing exhibit 21 (3 May 2021)