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In February 2020, Ethical Consumer viewed Edgewell Personal Care's website for information on how the company managed workers' rights in its supply chain.

Supply chain policy (rudimentary)

A strong supply chain policy would include the following commitments: no use of forced labour, permission of freedom of association, payment of a living wage, the restriction of working hours to 48 hours plus 12 overtime (without exception), no use of a child labour (under 15 or 14 if ILO exempt), no discrimination by race, sex or for any other reason.

Edgewell Personal Care was found to have adequate policies for child labour, forced labour, discrimination and freedom of association. The company's policy on wages was found to be inadequate as it only required the payment of legal minimum wages, not a living wage. The policy on working hours was also found to be inadequate, as it only required that suppliers set working hours "in compliance with all applicable Laws", no mention was found of the ILO convention limits of 48 hours plus 12 hours of overtime per week.

Overall, Edgewell Personal Care was considered to have a rudimentary supply chain policy.

Stakeholder engagement (poor)

Ethical Consumer deemed it necessary for companies to demonstrate stakeholder engagement, such as through membership of the Ethical Trade Initiative, Fair Labour Association or Social Accountability International. Companies were also expected to engage with Trade Unions, NGOs and/or not-for-profit organisations which could systematically verify the company's supply chain audits, and for workers to have access to an anonymous complaints system, free of charge and in their own language.

No evidence was found that the company was a member of a multi-stakeholder initiative, nor that it included third-party input in supply chain audits.

Although the company did have an online form for anonymous complaints, this was only stated be for the reporting of violations of its internal 'code of conduct' rather than to the supply chain code of conduct.

Overall, Edgewell Personal Care was considered to have a poor approach to stakeholder engagement.

Auditing and Reporting (poor)

Ethical Consumer deemed it necessary for companies to have an auditing and reporting system. Results of audits should be publicly reported and quantitatively analysed. The company should have a scheduled and transparent audit plan that applies to their whole supply chain, including some second tier suppliers. The company should also have a staged policy for non-compliance. The costs of the audit should be borne by the company.

The company's 2018 Sustainability Report stated "in 2018, we launched a Supplier CSR Performance Monitoring program with the help of a sustainability management firm." The report included some data showing an average score out of 100 attained by suppliers, however, it was unclear how the data was obtained, or how the scoring system was devised. There was no quantitative analysis of audit findings at the factory or supplier level.

No evidence was found of an auditing schedule, a policy for remediation or a policy committing the company to auditing labour standards across the entire breadth of the supply chain. No mention was found relating to the costs of audits.

Overall, Edgewell Personal Care was considered to have a poor approach to auditing and reporting

Difficult issues (poor)

Ethical Consumer also deemed it necessary for companies to address other difficult issues in their supply chains. This would include ongoing training for agents, or rewards for suppliers, or preference for long term suppliers. It would also include acknowledgement of audit fraud and unannounced audits, and measures taken to address the issue of living wages, particularly among outworkers, and illegal freedom of association.

No mention of the above issues could be found, therefore Edgewell Personal Care was considered to have a poor approach to difficult issues.

Overall, Edgewell Personal Care received Ethical Consumer's worst rating for Supply Chain Management and lost a whole mark in this category.


Supplier Code of Conduct (2018)

In February 2020, Ethical Consumer viewed Edgewell's website for its policy on the use conflict minerals. The company's SEC Form SD submission for 2019 was found, as well as a conflict minerals policy.

1. - The policy stated that Edgewell commited to:
- Ensuring “all 3TG minerals used in our products are “DRC conflict free””
- Working “to ensure that no 3TG minerals that support conflict in the DRC region are used in our supply chain”. However, no clear statement was found committing the company to continuing to source from the region.
- Exercising due diligence using the Organization for Economic Cooperation and Development (OECD) procedures”

2. The company did not appear to be a member of a multi-stakeholder initiative supporting the conflict-free minerals trade. The company’s form SD filing made reference to its “participation in the Conflict-Free Sourcing Initiative (CFSI)”, however, the CFSI became the Resposible Minerals Initiative (RMI) in 2017, and the company was not listed as a member on the RMI website.

As Edgewell Personal Care did not appear to meet the essential criteria of being a member of a multi-stakeholder initiative addressing the issue of conflict minerals or committing to continued sourcing from the region, it received Ethical Consumer's worst rating for its conflict minerals policy and lost a full mark under the Human Rights and habitats and resources categories.


SEC form SD - Edgewell Personal Care Company Conflict Minerals Report (2019)

In February 2020, Ethical Consumer viewed the Edgewell Personal Care list of subsidiaries in its 10-K filing with SEC, which stated that the company had operations in the following countries:

China, Israel and Mexico.

At the time of writing Ethical Consumer considered each country listed to be governed by an oppressive regime.


SEC 10-K Exhibit 21.1 - List of Subsidiaries (2019)