In January 2021 Ethical Consumer viewed the Joule UK website for information on how the company managed workers' rights in its supply chain. The company's "Anti-slavery And Human Trafficking Policy" was 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 Anti-slavery And Human Trafficking Policy stated "Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking... We have a zero-tolerance approach to modern slavery in our organisation and our supply chains. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy. We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain."
Though this statement the need to address and manage labour rights issues in the company's supply chain, it did not constitute a n adequately strong commitment to the aforementioned supply chain policy clauses. Therefore 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 evidence of the above was found. 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 Anti-slavery And Human Trafficking Policy stated "As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct. If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships"
No further detail was provided. 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.
No information was found. The company's approach to difficult supply chain issues was considered to be poor.
Overall the company received Ethical Consumer's worst rating for Supply Chain Management and lost a whole mark in this category.
jouleuk.co.uk (8 January 2021)