In April 2021 Ethical Consumer viewed the Bio-D Company website for information on how the company managed workers' rights in its supply chain. The following documents were consulted: a questionnaire received from the company, and policy documents received from the company in an email.

1. Supply chain policy (reasonable)

Ethical Consumer looked for 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 policy on forced labour was adequate, as it prohibited all forced labour.

The policy required suppliers to respect employees' rights to freedom of association.

The policy required suppliers to pay a living wage to all employees.

The policy on wages was considered to be inadequate, as it did not provide details beyond saying working hours should not "be excessive".

The policy required suppliers to to eliminate all child labour defined the age of a child as 15 unless ILO exempt.

The policy prohibited suppliers from all discrimination by race, sex etc

The code was stated to apply to the entire breadth of the supply chain.

Overall it was considered to have a reasonable supply chain policy.

2. 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 was found that the company was a member of a multi-stakeholder initiative

The following statement was found regarding the involvement of third-party organisations into the verification of labour standards audits: it said Bio-D was a "Member of SEDEX and have SMETA audits conducted to ensure compliance to the Ethical Trading Initiative". However, this was considered to be inadequate because it did not appear to be a member of ETI.

The company stated in its questionnaire that it did not have a complaints process that was anonymous, free, and available to all workers in its supply chain.

Overall it was considered to have a poor approach to stakeholder engagement.

3. 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.

No reporting of the results of supply chain audits was found.

Regarding an audit schedule, the company stated "The majority of the supplies 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." However, this was considered to be inadequate because it did not constitute a scheduled audit plan or publish results.

No statement was found regarding the proportion of suppliers the company had committed to auditing.

No information was found regarding the company's policy for handling instances of non-compliance with its code of conduct

No information was found regarding whether or not the company paid for the costs of supply chain audits.

Overall it was considered to have a poor approach to auditing and reporting.

4. Difficult issues (rudimentary)

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.

The following statement demonstrated a preference for long-term suppliers: "The majority of the supplies we use have been trading with us for many years".

No statement regarding audit fraud could be found.

No other significant measures were found addressing difficult issues.

No evidence was found that the company was taking steps to address the issue of living wages.

Overall it was considered to have a rudimentary approach to difficult issues.

Bio-D was a small company that met several requirements in Ethical Consumer's Supply Chain Management rating. As such, it qualified for an exemption.

Overall, Bio-D Company received a best Ethical Consumer rating for Supply Chain Management and was not marked down in this category.

Reference:

Questionnaire April 2021 (15 April 2021)