In February 2020, Ethical Consumer viewed Walgreen Boots Alliance (WBA) website along with its 2019 CSR report for details of how the company managed workers’ rights in its supply chain.

Supply chain policy (poor)

A strong 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.

The company’s CSR report contained the following statement:

“Using the Ethical Trading Initiative Base Code and International Labor Organization conventions and recommendations, we have created our core principles and policy on ethical sourcing, which we require all vendors and subcontractors to comply with when supplying merchandise and services to WBA”.

It further stated that the policy: “the prohibition of any form of bonded, forced, indentured or other illegal labor and of any form of slavery or human trafficking; opposition to discrimination in any form; fair and reasonable reward for workers; working hours that do not exceed applicable legal requirements; the prohibition of child labor; safe and healthy conditions; the prohibition of corruption and bribery”.

However, the policy itself did not appear to be publicly available.

The information found in the CSR report fulfilled Ethical Consumer’s criteria with regards to forced labour and discrimination.

The statement on child labour was considered to be inadequate, as it lacked any detail regarding the age of a child; the statement on working hours was considered to be inadequate as it did not specify the number of hours; the statement on wages was considered to be inadequate as it did not specify the payment of a living wage. No mention was found of workers’ right to freedom of association specifically in relation to supply chain workers.

Overall, Walgreen Boots Alliance was considered to have a poor 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 of the company’s engagement in any of the above; it was therefore considered to have a poor approach to stakeholder engagement.

Auditing and reporting (rudimentary)

Some reporting was given in the company's CSR report: "In fiscal 2019, we conducted more than 1,200 ethical compliance assessments on new and existing suppliers for our Walgreens and Boots UK owned brands. Where we identified critical non-compliance issues, we worked with our suppliers on remedial action plans to help ensure issues were addressed and corrected." Figures were supplied and analysed regarding ethical compliance of the company's suppliers.

The company had a staged process for addressing instances of non-compliance.
Ethical Consumer also expected the company to have a scheduled and transparent audit plan that applies to their whole supply chain, including some second tier suppliers. Ethical Consumer expected the company to cover the costs of an audit, but no statement could be could be found on whether this was the case.

Overall the company was deemed to have rudimentary 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 published discussion was found relating to any of the above issues, therefore the company was considered to have a poor approach to difficult issues.

Overall, Walgreen Boots Alliance received Ethical Consumer's worst rating for Supply Chain Management and lost a whole mark in this category.

Reference:

Corporate Social Responsibility Report 2019 (2019)

In January 2016 the Chicago Tribune reported that Walgreen's refused to stop selling tobacco. However executives told shareholders in January that it would maintain its focus was trying to help people kick the habit.

"We do deliberate this on a regular basis," said Executive Chairman James Skinner. "Our main focus is to try to get people to quit smoking, and we provide a lot of opportunities in stores to do that," he said, adding, "We also provide (products) for consumers who decide they want to smoke."

In February 2020 the company was still found to be selling tobacco.

The company lost a whole mark under Irresponsible Marketing.

Reference:

Walgreens will keep selling tobacco products (27 January 2016)

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.

Reference:

www.boots-uk.com (3 November 2016)

In February 2020, Ethical Consumer viewed the Walgreens Boots Alliance (WBA) Annual Report 2019 and the company's 10K SEC filing, which lists all of the company's subsidiaries. According to this document, WBA had subsidiaries in Egypt, Turkey and Mexico.

At the time of writing Ethical Consumer considered each country listed to be governed by an oppressive regime. The company therefore lost a half mark in the Human Rights category.

Reference:

SEC 10-K Exhibit 21 (2019)

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.

Reference:

walgreensbootsalliance.com (2020)

In March 2020 Ethical Consumer searched Boots' website for information on the company's cocoa sourcing policies. The website showed a number of products with cocoa as a key ingredient and it was considered a significant part of the company’s offering. The cocoa used did not appear to be certified by either Soil Association, Fairtrade, Rainforest Alliance or UTZ, and the company did not demonstrate knowledge of supply chain to source.
Due to the fact that the company was still sourcing some uncertified cocoa, and the issue of child and slave labour in cocoa supply chains had been known since before 2000, it was marked down in the Workers' Rights category.

Reference:

boots.com (2020)