In January 2021 Ethical Consumer viewed the Travis Perkins plc website for information on how the company managed workers' rights in its supply chain. "Supplier Commitments" documents covering "Human Rights" and "ETI Base Code" were viewed. The Travis Perkins plc Annual Report 2019 was also viewed.
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 "Human Rights" Supplier Guidance document stated "As our supplier we expect you to protect your workers’ rights, promote good working conditions and support our approach to fostering positive relationships in supply chains. Ethical, safe and legal practices should be established throughout your business, and the subjects of regular employment, working hours, wages, child labour, working conditions, discrimination, freedom of association and freedom from intimidation should be covered within your ethical policy. The Ethical Trading Initiative (ETI) Base Code (see link below) provides a simple and clear structure for you to adopt."
The "ETI Base Code" Supplier Guidance document stated "As a supplier, you commit to meet, or work towards meeting, the principles of the Ethical Trading Initiative (ETI) Base Code." It listed the core elements of the base code as "Employment is freely chosen; Freedom of association; Work conditions are safe and hygienic; Child labour shall not be used; Living wages are paid; Working hours are not excessive; No discrimination is practiced; Regular employment is provided; No harsh or inhumane treatment is allowed."
Though referring to the ETI Base Code and mentioning all of the key clauses, due to it being sufficient for suppliers to "work towards meeting" the standards, none of the clauses were considered strong enough. Furthermore, inadequate detail was provided on the meaning of child labour and excessive working hours. There was no explicit statement that these standards applied to all first tier suppliers as well as some second tier.
Overall the company's supply chain policy was considered to be poor.
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 mention was found of membership of multi-stakeholder inititives or systematic engagement with trade unions or NGOs. Travis Perkins did source a large proportion of timber from FSC and PEFC certified sources, but there was no indication of systematic engagement with these organisations.
The Travis Perkins plc Annual Report stated, in a section on risk mitigation, that: "The Group operates a whistleblowing process that allows the anonymous reporting, through an independent hotline, of any suspected wrongdoing or unethical behaviour, including reporting instances of non-compliance laws and regulations." However there was no mention of it being in suppliers own language or free of charge.
Overall the company's approach to stakeholder engagement was considered to be poor.
Auditing and Reporting (poor)
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.
The 2019 Annual Report stated "The Group began to accept internationally-recognised SMETA ethical audits from its own-brand factory sites. Work is ongoing to transition all own-brand factory sites onto a new ethical audit format (whether SMETA or the Group’s own format). Additional modern slavery checks and requirements were put into place with labour agencies supporting the Group’s distribution centres." The Supplier Guidance document on "Human Rights" also stated "Your performance will be actively monitored through online risk assessments, to make sure our values and minimum standards are being followed and met throughout your business. In addition, all factories producing Travis Perkins Group own brand products will be required to pass an appropriate site audit to assess their ethical performance."
Although the company was increasing the number of own-brand factories covered by SMETA ethical audits, the supply chain verfication tool used for all suppliers was an online risk assessment. No detailed audit results were provided, nor was there an audit schedule. No information was found on the company's approach to supplier non-compliance or audit costs.
Overall the company's approach to auditing and reporting was considered to be poor.
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.
None of the above were addressed. The company's approach to difficult supply chain issues was considered to be poor.
Overall, Travis Perkins plc received Ethical Consumer's worst rating for Supply Chain Management and lost a whole mark in this category.
www.travisperkinsplc.co.uk (6 January 2021)