In November 2020 Ethical Consumer searched Avon Products's website for information on the company's supply chain management. Information was found on the company website and in its Responsibility Report 2019 the most recent available.
Supply chain policy (rudimentary)
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.
Avon Products website had a supplier Code of Conduct (Updated January 2020) available to download which applied to any company, its factories, manufacturers, vendors or agents ("Suppliers") that produced goods and/or provided services for Avon Products, Inc. or any local affiliate. The code of conduct included provisions which prohibited the use of child labour under the age of 15 (or in accordance with ILO), and forced labour, and allowed employees to be free to join unions and to be free from discrimination. However, according to the code of conduct, working hours for employees were restricted up to 72 hours per week "in exceptional business circumstances". These circumstances were not defined and were over the working week limit of 48 plus 12 hours overtime. The code of conduct failed to guarantee payment of a living wage to employees. Due to a lack of commitment on wages and hours Avon Products was considered to have a rudimentary supply chain policy.
Stakeholder engagement (rudimentary)
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 could be found of trade union engagement by the company, and no evidence that Avon engaged with a multistakeholder process. There was some discussion of engagement with NGOs for example, Business for Social Responsibility, but there was no evidence that this constituted systematic independent verification of supply chain audits. The company had a helpline called Avon Integrity Helpline through which to report ethics or compliance violations which could be done anonymously if desired, via email or through the toll-free phone line, which had available interpreters who spoke more than 100 languages. Overall the company was considered to have a rudimentary approach to stakeholder engagement.
Auditing and reporting (rudimentary)
Ethical Consumer deemed it necessary for companies to have an auditing and reporting system. Audit results should be fully disclosed and quantitatively analysed at supplier level. 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.
A search of Avon's Responsibility Report 2019 found a section on supplier audits. It stated that its goal was to ensure that every in-scope supplier was audited every two years. In-scope suppliers were defined as those making finished products for Avon so, while it did have a schedule, it was not considered to have a committment to audit second-tier suppliers. It stated that it had audited 279 sites in 2019 and provided a basic overview of results stating common issues found and numer of suppliers rated red, organge, yellow or green (red being the worst and green the best). However, this was not considered to be a full and complete disclosure of full audit results at supplier level. It did state that it provided remediation plans in reponse to issues of non-compliance. No information regarding who bore the costs of audits was found. It was considered to have a 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.
The company stated that it provided in-person training to suppliers on its social responsibility policies, this was considered to be a positive measure. No further discussion of difficult issues could be found and it was considered to have a rudimentary approach.
Overall Avon Products Inc received Ethical Consumer's middle rating for Supply Chain Management and lost half a mark in this category.
Responsible Business Report 2019 (2019)