In February 2020, Ethical Consumer viewed Walgreen Boots Alliance website for the company's environmental reporting. The Walgreens Boots Alliance CSR report 2019 was downloaded.
The report detailed how the company had taken steps to reduce its environmental impact in relation to energy use, use of refrigerants, transport, waste and plastics. However, the report lacked any discussion on other important issues. For example, there was no real discussion of water usage. Also, the company sold a number of food products but there was no discussion around the production of food, e.g. pesticide use, sustainable agriculture. The company was therefore not considered to have a reasonable understanding of its key environmental impacts.

No dated and quantified future environmental targets were found in the report, the targets the company had included in its 2018 report did not appear to have been carried over into the 2019 edition.

There was some meaningful disclosure of the company’s carbon emissions broken into scopes 1, 2 and 3.
External assurance was provided by Deloitte for key data in the report.
Due to the absence of dated and quantified future environmental targets, Walgreen Boots Alliance received Ethical Consumer’s worst rating for Environmental Reporting and lost a full mark in this category.

In February 2020, Ethical Consumer searched the Walgreen Boots Alliance corporate website for the company's policy on the use of the hazardous chemicals parabens, triclosan and phthalates. A document entitled Walgreens Boots Alliance Restricted Substances List was found, dated 2018.

Some forms or uses of these chemicals were banned or restricted in the EU or the USA.
Triclosan is an antibacterial and a suspected endocrine disruptor. Parabens are also endocrine disruptors and have been linked to breast cancer. They are used as preservatives. Phthalates, usually DEP or DBP, are used in fragrances and are endocrine disruptors.
A strong policy on toxics would be no use of these chemicals or clear, dated targets for ending their use.

The document stated: “The following chemicals are restricted from use in all formulated Walgreens and Boots owned brand and exclusive retail products in the baby, beauty and personal care and household cleaning product categories. It is our intent to work collaboratively with our suppliers to facilitate the elimination of these materials through reformulation of products, by the end of 2021”.

The list included phthalates, triclosan and some (but not all) parabens.

As the company did not commit to phase out all parabens, Walgreens Boots Alliance received Ethical Consumer's worst rating for its pollution and toxics policy and lost a whole mark in this category.

In March 2020, Ethical Consumer searched Boots’ website for the company's policy on the use of microplastics and non-biodegradable liquid polymers. The company had a webpage entitled ‘Microbeads: a sustainable future’. This page stated the in “December 2015, we stopped all manufacturing of Boots Brands and exclusive rinse-off personal care products containing plastic microbeads, and as of 31 December 2017 we made the decision to no longer accept the supply of any rinse-off personal care products which contain plastic microbeads.” This policy did not cover the company’s non-rinse off products. No further information was found.

According to Beat the Microbead, there are more than 500 known microplastics ingredients that can be found in our personal care products such as toothpastes, face washes, scrubs and shower gels. They are tiny plastic particles that are added for their exfoliating properties, but sometimes purely for aesthetic purposes only.

A recent report by Code Check found that non-biodegradable liquid polymers were also prevalent across a wide range of cosmetic products. Like microplastics, these materials degrade with a similar difficulty in the environment and may cause similar harm.

In 2018, the UK government banned the use of microbeads in toothpastes, shower gels and facial scrubs. However, some products classified as “leave on” were not subject to the ban, this would include lotions, sun cream and makeup, as well as abrasive cleaning products. This ban did not extend to non-biodegradable liquid polymers.

Given that the company’s policy did not cover the use of all microplastics in all of the company’s products or the issue of non-biodegradable liquid polymer in its products, the company lost half a mark under Pollution & Toxics.

In February 2020, Ethical Consumer searched the Walgreens Boots Alliance website for a cotton sourcing policy. Although the company sold a range of products which included cotton, such as cotton wool and cotton buds, 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, www.ota.com, 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.

In February 2020, Ethical Consumer viewed Boots' website and found that the company sold a number of own-brand electrical items, including batteries. Ethical Consumer searched the website, along with that of the parent company Walgreens Boots Alliance, for the company's policy on the use conflict minerals. No policy or statement could be found.

Walgreens Boots Alliance appeared not to have submitted Form SD filings with SEC (which reports on conflict minerals).

Conflict minerals are minerals mined in conditions of armed conflict and human rights abuses, notably in the eastern provinces of the Democratic Republic of Congo (DRC). The minerals in question are Tantalum, Tin, Tungsten and Gold (3TG for short) and are key components of electronic devices, including electric shavers.

Ethical Consumer deemed it necessary for any company manufacturing electronics to have a policy on the sourcing of conflict minerals. Such a policy would articulate the company's commitment to conflict free sourcing of 3TG minerals and its commitment to continue ensuring due diligence on the issue. The policy should also state that it intends to continue sourcing from the DRC region in order to avoid an embargo, which would hurt local workers even more.

A company should also demonstrate its commitment to the issue of conflict minerals by supporting conflict free initiatives in the region either through membership of a multi-stakeholder initiative supporting the conflict-free minerals trade (such as Conflict Free Sourcing Initiative (CFSI), Public-Private Alliance for Responsible Minerals Trade (PPA) and industry initiatives such as JEITA Responsible Conflict Minerals Working Group) and / or financially supporting in-region mining initiatives (such as KEMET “Partnership for Social and Economic Sustainability”, Conflict-Free Tin Initiative (CFTI), ITRI Tin Supply Chain Initiative (iTSCi), Solutions for Hope).

A strong conflict minerals policy would also:
- require suppliers to adopt a robust 3TG conflict minerals policy and programme equivalent to the company.
- include details of the steps it will take to identify, assess, mitigate and respond to risks within its supply chain.
- use conflict minerals reporting templates by Conflict Free Sourcing Initiative (or may be referred to as EICC-GeSi) or OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
- include a commitment (from the company and supplier) to only using 3TG minerals from smelters that have been audited and verified as conflict free by the Conflict Free Smelter Program, or an equivalent, as they become available
- list in detail the smelters or refiners (SORs)

Since Boots had none of these things, it received Ethical Consumer's worst rating for conflict minerals and lost a whole mark under Human Rights and Habitats and Resources.

In March 2020, Ethical Consumer viewed the Boots website for the company's timber sourcing. The document, 'GFTN UK FOREST PRODUCT REPORTING SUMMARY FOR 2020', was downloaded. It stated:

"Boots UK undertakes due diligence to assess and mitigate any risk of illegal and unwanted forest products entering into the UK market from our supply chain." The company's policy also referred to the EU Timber Regulation, where the minimum standard was that no illegal timber shall be sold on the market.

"At present, we believe FSC represents the gold standard and a credible benchmark for other forest certification schemes to match. Our preference is to source increasingly from credibly-certified forests or verified recycled sources."

It stated that "Boots UK undertakes due diligence to assess and mitigate any risk of illegal and unwanted forest products entering into the UK market from our supply chain. We collect as much information on supply chain sources as possible, and systematically work to eliminate poor sources".

It had a 2019/20 target for "wood, paper and pulp usage in Boots owned brand products to ensure at least 95% (by volume) comes from FSC or PEFC certified or recycled sources".

It published figures of percentages FSC certified, but these appeared to be "current wood pulp and paper usage in products and goods not for resale(excluding packaging)".

In the WWF Timber Scorecard 2017 the company scored three out of three 'trees', meaning it was performing well against WWF sustainability requests.

Ethical Consumer's timber sourcing ranking required companies scoring a 'best' to cover six of the below issues:
1. Having a timber sourcing policy that covers all timber and timber-derived products
2. the exclusion of illegal timber or that sourced from unknown sources and...
3. ...a discussion on how a company ensures/ implements this
4. clear targets for sourcing timber from sustainably managed sources
5. a discussion of a good minimum standard
6. preference given to certified sources
7. a discussion about tropical hardwoods (THW) and the percentage of THW sourced that are FSC certified
8. involvement with a multi-stakeholder initiative or bridging programme such as the World Wildlife Fund- Global Forest Trade Network
9. use of reclaimed or recycled wood/ paper
10. a high total percentage (50%+) of FSC certified timber sourced by the company.

Boots UK received Ethical Consumer's best rating due to the fact it met the first 6 out of 10 of Ethical Consumer's necessary criteria.

In February 2020, Ethical Consumer downloaded the Boots UK 2018 Annual Communication on Progress (ACOP) to the Roundtable on Sustainable Palm Oil (RSPO) from the RSPO's website and looked at the information provided on the company group's website.

100% of the total palm oil, palm kernel oil and palm oil derivatives used by the company was reported to be certified by the RSPO and a small proportion of this was through a segregated mechanism.

The company picked up additional marks for disclosing the volumes it used. It was not conducting any additional positive initiatives regarded as significant and it did not disclose its suppliers. It received Ethical Consumer's middle rating for its palm oil policy and practice.