In March 2020 Ethical Consumer viewed Bio-D's 'Code of Ethics and Business Conduct' and 'Child Labour and Young Workers Policy 2020' sent to Ethical Consumer by the company, as well as a complete questionnaire and the company's website for information on how the company managed workers' rights in its supply chain.

Supply chain policy (reasonable)

The company's Code of Ethics covered its whole supply chain, and stated that it expected suppliers to comply with the Ethical Trade Initiative (ETI) Base Code.

Adequate clauses were found on the following: forced labour, freedom of association, payment of a living wage, discrimination, and child labour.
It should be noted that these clauses were only considered adequate in tandem with the more detailed explanations of each clause found in the ETI Base Code referred to.

Ethical Consumer expected companies to use the ILO clause on working hours. The ETI Base Code clauses on working hours were based on the ILO working hour clauses, but also included extra clauses which potentially allowed for workers to exceed 60 hours in 7 days. Ethical Consumer only accepted this clause in a company's supplier code of conduct if the company was also a member of the ETI. As Bio-D was not a member of the ETI this clause was deemed inadequate.

Overall the company was considered to have a reasonable 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.

Bio-D did not have any of the above so it was considered to have a poor approach to stakeholder engagement.

Auditing and reporting (poor)

The company's questionnaire stated: "The majority of suppliers we use have been trading with us for many years. Therefore an audit is only conducted if there is an issue. New suppliers are selected according to BRC requirements."

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.

Bio-D did not meet any of the above criteria. It was therefore considered to have poor auditing and reporting.

Difficult Issues (Reasonable)

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.

Bio-D stated in it's questionnaire that "The majority of suppliers we use have been trading with us for many years." This was considered to constitute a preference for long-term suppliers.

The company also had policies around child and young workers. In its 'Child Labour and Young Workers Policy' it stated: "Regardless of the minimum age of employment, no Young Worker shall be employed through a labour agent in any part of the The Bio-D Company supply chain." This was considered a positive policy in regard to the exploitation of young workers.

Overall Bio-D was considered to have a reasonable approach to difficult issues.

It should also be noted that the company produced all its goods in the UK: "Manufactured in Hull, East Yorkshire, Bio-D are proud to produce high quality products right here in the UK." This was considered to be an effective practice of ensuring that workers' rights in the company's supply change were upheld because the UK had relatively robust workers' rights standards and it allowed the company to maintain oversight of production.

Overall the company received Ethical Consumer's best rating for supply chain management as it had a number of positive policies in place, but it also received an exemption for being a small company with a turnover under £10.2m with effective practice of upholding workers' rights in its supply chain.


Code Of Ethics And Business Conduct (2020)