In March 2020 Ethical Consumer viewed the P&G website for the company's environmental policy or report. The company's 2019 Citizenship Report was downloaded, which contained the following 2020 goals:

- zero manufacturing waste to landfill
- Reduce packaging by 20% per consumer use
- Ensure 90% of product packaging is either recyclable or programs are in place to create the ability to recycle it
-Reduce absolute GHG emissions by 30% by 2020
- Ensure plants are powered by 30% renewable energy

The company had also begun setting goals for 2030, including:
- purchase 100% renewable electricity globally
- reduce scope 1 and 2 greenhouse gas emissions by 50% (baseline 2010)
- Achieve 100% recyclable or reusable packaging by 2030
- Reduce our use of virgin petroleum plastic in packaging by 50% by 2030

Regarding independent verification, the report stated: "Our GHG emissions data has been verified by an external third party, Lloyd’s Register Quality Assurance (LRQA)." However, the other environmental data in the report was not independently verified.

The report covered greenhouse gas emissions, packaging, energy use, palm oil, forestry, water, waste, energy conservation, low-energy washing and circulate supply chains. P&G was considered to have a reasonable understanding of its main impacts.

Given that P&G's report contained multiple future, quantified targets, demonstrated a reasonable understanding of its impacts and was dated within two years, but was not independently verified, the company received Ethical Consumer's middle rating for Environmental Reporting and lost half a mark in this category.

Reference:

Citizenship Report 2019 (2019)

In March 2020, Ethical Consumer searched Procter and Gamble’s website for the company's policy on the use of microplastics and non-biodegradable liquid polymers. Here it was stated that all of the company’s products were microbead free. There was no acknowledgement of other microplastics or non-biogradable liquid polymers.

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 or the issue of non-biodegradable liquid polymer in its products, the company lost half a mark under Pollution & Toxics.

Reference:

www.pg.co.uk (11 March 2020)

In March 2020 Ethical Consumer searched Procter and Gamble's website for its policy on the use of potentially hazardous chemicals such as phthalates, parabens and triclosan. A page entitled 'ingredient questions' was found which discussed the use of parabens and phthalates in P&G products.

P&G's position on parabens and other preservatives was as follows:
"You can rest assured that all of our preservatives comply with the applicable regulations and safe limits wherever they are sold." The company also provided a table showing which preservatives were used in which products.

P&G's position on phthalates was as follows:
"We comply with all phthalate bans globally. In fact, we have removed the only phthalate that was used in our product fragrances even though agencies found it to be safe." A footnote added "We do not use these ingredients [phthalates] in new products and are exiting them from any current products." No timeline or cut-off date was provided.

P&G position on triclosan was as follows:
"We have already eliminated triclosan from our products globally and have an exit plan for our few remaining uses of triclocarban." No cut-off dates for ending the use of triclocarban was provided.

Because it did not use one of the chemicals in question (Triclosan), and had commited to not using phthalates in new products and phasing them out of old products but had no cut-off dates for ending the use of phthalates, and continued to use parabens Procter and Gamble received Ethical Consumer's middle rating on toxics and lost half a mark under the Pollutions and Toxics category.

Reference:

www.pg.co.uk (11 March 2020)

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, 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:

www.pg.co.uk (3 May 2019)

In March 2020 Ethical Consumer viewed Procter and Gamble's conflict minerals policy SEC form SD, available on the company's website.

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, from mobile phones to televisions.

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.

Procter and Gamble made all of the above commitments.

Ethical Consumer also expects companies to demonstrate its commitment by supporting conflict-free initiatives through membership of a multi-stakeholder initiative supporting the conflict-free minerals trade and / or financially supporting in-region mining initiatives. The company stated, "we have engaged with other companies through trade associations and industry initiatives, such as the Responsible Business Alliance-Global e-Sustainability Initiative’s (“RBA-GeSI”) Responsible Minerals Initiative (“RMI”), to improve transparency with respect to smelters and other upstream participants in the Conflict Minerals supply chain." However, the company did not state whether it continued to do this, and was not listed as a member to the Responsible Minerals Initiative, nor other initiatives considered adequate by Ethical Consumer.

With respect to the sourcing of conflict minerals by suppliers, the company said: "We expect suppliers to have a policy in place and implement a system to trace the origin of tin, tantalum, tungsten, and gold supplied to the Company, following the template developed by the Responsible Minerals Initiative.."

Since the company 'expected' rather than 'required' its suppliers to adopt a robust conflict minerals policy and since supplier agreements and contracts were not available on the P&G website, it cannot be confirmed that P&G suppliers are required to follow robust and responsible conflict minerals sourcing protocols.

The SEC filing did include a list of named smelters, the minerals they processed, stating that all listed smelters appear on the RMI smelter list.

Given that Procter and Gamble had reasonable conflict minerals sourcing statements, but because it did not demonstrate its commitments through membership of a multi-stakeholder initiative, and had poor detail on ensuring that these commitments were upheld by suppliers, P&G received Ethical Consumer's worst rating for conflict minerals and lost a whole mark under Human Rights and Habitats and Resources.

Reference:

Conlfict Minerals Report 2018 (2018)

In March 2020 Ethical Consumer viewed P&G's website for the company's policy on timber sourcing. The company's Citizenship Report 2019 was downloaded, which stated that:

-"As part of our procurement practices, we require that all wood used for pulp supplied has undergone a risk assessment in accordance with the Forest Stewardship Council® (FSC®) Controlled Wood standard. The FSC Controlled Wood risk assessments ensure that unwanted wood sources are avoided, and that wood harvesting is done legally per our procurement policy."

- "100% of the virgin wood pulp we purchase for use in our tissue/towel and absorbent hygiene products is
third-party certified by one of our accepted forest certification systems. We give preference to FSC certified pulp when it is available and meets product performance and business requirements."

The company also committed to "Use 100% recycled fiber in our fiber-based packaging by 2025."

The report stated that 43% of the timber / timber derived products in FY18/19 were FSC certified. The remaining percentage was certified by other bodies, which Ethical Consumer regards as weaker standards than the FSC.

The policy covered the company's wood pulp sourcing. However, P&G also sourced wood fiber for packaging. It was not clear if wood fiber was also covered by the policy outlined above.

Overall, P&G met five of the ten criteria for a strong timber sourcing policy. The company therefore received Ethical Consumer's middle rating for its timber sourcing policy.

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.

Procter and Gamble received Ethical Consumer's middle rating due to the fact it had 5 of the above.

Reference:

Form DEF 14A 2019 (11 March 2020)

Forest 500, ‘the world’s first rainforest rating agency’, is a project of the Global Canopy Programme. In 2019, it published its fifth annual ranking. It ranks 350 of the biggest companies in forest-risk supply chains and the 150 biggest investors in these companies.

Tropical rainforests cover 7% of the earth, but contain 50% of global biodiversity. Their ecosystems regulate global water systems and the climate, and they directly support the livelihoods of over a billion people. The social and economic benefits of these services are estimated to be in the trillions.

Over two thirds of tropical deforestation is driven by the production of a handful of commodities including; palm oil, soya, timber, paper and pulp, beef, and leather. These commodities are in products we use every day and are present in more than 50% of the packaged products in our
supermarkets.

Companies and financial institutions had been assessed and ranked in respect to their policies addressing potential deforestation embedded in forest-risk commodity supply chains. The 2018 report stated that "the Forest 500 methodology was updated in 2018 to better distinguish between companies who have set commitments, and those that have taken the next step towards implementation. This new methodology has meant that many companies have received lower scores this year." A document on the 2019 methodology stated that had been updated again to better align with the guidance of the Accountability Framework, a set of norms and guidance on ethical supply chains developed by a coalition of civil society partners. Three new indicators were added and two indicators were updated.

The Forest 500 ranking and analysis will be repeated annually until 2020, to help inform, enable and track progress towards deforestation free supply chains.

Each company was rated from 0-5, across five categories:

Procter & Gamble was one of the 350 companies rated in the 2019 report.

It received an overall score of 3. Its scores in each category were as follows:
Overall Approach 2 out of 5

Commodity Score (palm, paper & pulp) 3 out of 5

Commitment Strength 4 out of 5

Reporting and implementation 3 out of 5

Social Considerations 3 out of 5

The company had signed up to the following collective commitments:

New York Declaration on Forests signatory
Consumer Goods Forum member

As it had scored under 4 overall, it lost half a mark under Habitats and Resources.

Reference:

Forest 500 - 2019 ranking (2019)

In March 2020 Ethical Consumer viewed P&G's 2017 progress report on the Roundtable on Sustainable Palm Oil (RSPO) website. The company had been a member since 2010.

The figures disclosed volumes of palm products (palm oil, palm kernal and derivatives) used in the reporting period and about 34% of its palm products were covered by RSPO certified mechanisms. Its submission was said to cover its global supply chain.

The company had mapped over 98% of its palm oil purchases and published a list of these suppliers.

The company had the following positive policies, listed in its 2019 Citizen's report, related to palm oil:
- "No development of high-conservation-value (HCV) areas and high-carbon-stock* (HCS) forests"
- "No new development of peat lands regardless of depth"
- "If we find a supplier is violating any of the above requirements, and if that supplier does not acknowledge and take action to resolve the concern, P&G will suspend or eliminate palm oil purchases from that supplier."

As Procter and Gamble scored 12 out of 20 on Ethical Consumer’s palm oil rating system it received Ethical Consumer's Middle rating for its palm oil policy and lost half a mark under this category.

Reference:

ACOP 2018 (2018)

In June 2019, Ethical Consumer viewed a petition on the Sum of Us website titled 'It's time Procter & Gamble tackles palm oil exploitation in its supply chain'. It stated:

"Procter & Gamble’s villainous palm oil partner FGV, has been sanctioned over multiple human rights violations, including trafficking and forced labour.

"FGV or “Felda” has been found guilty of human trafficking and forced labour on its plantations...

"Big brands like Procter & Gamble, PepsiCo, Nestlé, and Mars brag about their sustainable palm oil policies, while continuing to profit from FGV’s forced labour."

The company lost half a mark under Palm Oil.

Reference:

It's time Procter & Gamble tackles palm oil exploitation in its supply chain (17 June 2019)

In March 2018 Greenpeace International released its report called “Moment of truth time for brands to come clean about their links to forest destruction for palm oil”.

The report was based on the fact that in 2010 members of the Consumer Goods Forum (CGF) pledged to do their bit to protect forests and limit climate change, with a clear commitment to clean up global commodity supply chains by 2020.

However Greenpeace stated “with less than two years to go until 2020, deforestation to produce commodities such as palm oil shows no sign of slowing down. Corporate commitments and policies have proliferated, but companies have largely failed to implement them. As a result, consumer brands, including those with ‘no deforestation, no peat, no exploitation’ (NDPE) policies, still use palm oil from producers that destroy rainforests, drain carbon-rich peatland and violate the human rights of workers and local communities – making their customers complicit in forest destruction, climate change and human rights abuses.”

At the start of 2018, Greenpeace International challenged 16 leading members of the CGF to demonstrate their progress towards a clean palm oil supply chain. It called on them to disclose publicly the mills that produced their palm oil, and the names of the producer groups that controlled those mills. Eight of the global brands responded to Greenpeace’s challenge and published data revealing where and from whom they ultimately buy palm oil. It said “Transparency and accountability – including the publication of explicit details about who produces the palm oil that companies use – create the conditions for sectoral reform.”

Yet in 2017, Greenpeace assessed the actions palm oil traders were taking to ensure that they were not buying from producers that were destroying rainforests, draining peatlands or exploiting workers and local communities. It said “Although most traders had published NDPE policies, there were serious problems with their implementation: inconsistent standards, questionable enforcement and non-existent deadlines. Not only was the palm oil industry not working to the 2020 deadline set by brands, it did not even have a common timeline for delivering a palm oil supply free from deforestation and other social and environmental harms.”

Procter & Gamble was one of the eight companies which had responded to Greenpeace’s challenge and had provided data on its traders / suppliers and the names of the mills and producers.

Yet in 2017, Greenpeace assessed the actions palm oil traders were taking to ensure that they were not buying from producers that were destroying rainforests, draining peatlands or exploiting workers and local communities. It said “Although most traders had published NDPE policies, there were serious problems with their implementation: inconsistent standards, questionable enforcement and non-existent deadlines. Not only was the palm oil industry not working to the 2020 deadline set by brands, it did not even have a common timeline for delivering a palm oil supply free from deforestation and other social and environmental harms.”

Procter & Gamble lost half a mark under Ethical Consumer's Palm Oil category due to the fact Greenpeace concluded “none of the major traders can yet be relied upon to supply brands with palm oil that meets their NDPE standards; indeed, they are all known to source from forest destroyers... It follows that by sourcing from these traders brands are buying palm oil contaminated by forest destruction.”

The company lost a mark under the Palm Oil category.

Reference:

Moment of truth time for brands to come clean about their links to forest destruction for palm oil (