In February 2021 Ethical Consumer viewed the Sainsbury's website for information on how the company managed workers' rights in its supply chain. Several documents were viewed, including: 'Supplier Policy on Ethical Trade –Sainsbury’s Brand'; Modern Slavery Statement 2017/18; Human Rights policy; Sainsbury's Fairly Traded Report 2019/20. A questionnaire received from the company in March 2021, and a company document linked in this titled 'Sourcing with integrity code of conduct' was also viewed.
Supply chain policy (reasonable)
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.
Sainsbury's had adequate clauses on forced labour, living wages, freedom of association and discrimination. The clause on child labour did not define the age of a child restricted from working, but it stated "Under the code of conduct, all our suppliers must comply with the ETI Base Code", and was a member. For this reason it was considered adequate.
It stated that working hours should not be excessive but did not clarify what twas considered excessive.
Overall Sainsbury's was considered to have a reasonable 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.
Sainsbury's was listed as a member of the Ethical Trading Initiative.
Sainsbury's had a service called Rightline which was acessible on the Riskavert website. This stated that you could use Rightline to report wrongdoing. It said reports could be made anonymously but that "doing so can limit the scope of the investigations". It was unclear if this whistleblowing service was available to all workers in the supply chain, or if it was translated into several languages. The questionnaire stated "We ask our global food suppliers to advertise our hotline called Rightline to workers. We are also sponsors of the UK’s Modern Slavery and Labour Exploitation Helpline through Unseen. We are also currently piloting a worker voice program in India and Turkey. Workers from the factories can scan QR code on posters distributed around the factories or through IVR technology and answer a short questionnaire. The questionnaire has been designed to highlight any grievances that the workers may have." Although the question specifically asked whether this service was available at no cost and in the workers own language these aspects were not addressed in the company's response. No further information was identified.
Overall the company was considered to have a rudimentary approach to stakeholder engagement.
Auditing and Reporting (reasonable)
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.
Sainsbury's 'Supplier Policy on Ethical Trading', which stated: "We recognise the importance of being aware of labour practices in our supply chains and the need to monitor, evaluate and act on information about our suppliers’, sites’ and growers’ performance. To do this, we use a range of tools including independent, third party audits of suppliers and sites, self-assessment questionnaires and confidential mechanisms for workers to highlight issues. We view worker and supplier communication as critical for identifying and resolving supply chain issues."
It stated that all suppliers must:
"Ensure all production sites have a 2-pillar SMETA ethical audit according to their risk rating carried out by a Sainsbury’s approved audit body and other Sainsbury’s requirements:
High risk: every 12 months
Medium risk: every 24 months
Low risk: at TM discretion
New site: within 12 months prior to being registered on Evolve
Suppliers must directly commission any audit. We also accept Social Accountability International (SA8000) and SIZA audits." The policy included definitions of high, medium and low risk, based on previous compliance with the policy.
Although this constituted a transparent plan for medium and high risk companies, low risk sites were only inspected at the company's discretion, therefore there did not appear to be a clear or transparent plan for these suppliers.
However, in a questionnaire response the company stated "100% of Tier 1 sites that we work with must conduct an annual semi announced SMETA (Sedex Members Ethical Trade Audit), one of the most widely used ethical audit formats in the world. These audits need to be conducted by one of our 4 selected audit bodies and must cover the whole site. The audit is then uploaded onto the Sedex platform. If the audit result does not meet our requirements then the site will be asked to improve and action feedback within a set timeframe." This was considered to be a transparent audit plan.
The policy also stated that the company would implement corrective action plans for non-compliance, and outlined time frames within which any non-compliance or whistleblower complaint had to be referred to the company.
No information about auditing costs or audit results were identified. No further information was identified. Overall the company was considered to have a reasonable approach to 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 meeting labour standards, 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.
Sainsbury's stated that it had a "strong heritage of building long-term relationships with our suppliers, farmers and producers". The questionnaire stated "The team conduct unannounced visits to sites to ensure the third-party audit is reflective of the situation on site."
The questionnaire further stated "We provide training to all new colleagues within Sainsbury’s Argos (including buyers) on our ethical code of conduct, including the process of onboarding a new site and responsibly exiting a supplier. Existing colleagues receive annual modern slavery training and the ethical team support with sharing any relevant ethical updates. We hold annual ethical workshops / webinars for all of our non-food suppliers to ensure they are kept up to date with our code of conduct, our requirements as well as any country / industry updates."
"We recently conducted a ‘sub-contractor amnesty’ in China and India to encourage our suppliers to declare sub-contracting sites too us without fear of reprisal, which has been successful. This allows us to have better visibility of our supply chain and work with suppliers on remediating any issues."
Overall the company was considered to have a reasonable approach to difficult issues.
Overall J Sainsbury plc received Ethical Consumer's best rating for Supply Chain Management and was not marked down in this category.
www.about.sainsburys.co.uk (26 February 2021)