In April 2021 Ethical Consumer viewed the Reckitt Benckiser Group PLC website for information on how the company managed workers' rights in its supply chain.
1. Supply chain policy (poor)
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.
The policy required suppliers to respect employees' rights to freedom of association.
The policy on wages was considered to be inadequate, as it required suppliers to pay only the national minimum wages set by law rather than a living wage.
Regarding working hours, the company stated that working hours were key area of risk. This was considered to be inadequate because it did not specify that weekly hours were limited to 48 hours on a regular basis, plus 12 hours overtime without exception.
The policy on child labour was considered to be inadequate as it did not define the age of a child. (The company appeared to have specified the age in 2016 but this was in a document that was considered outdated).
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 in a 2020 document titled 'Reckitt: A responsible approach across our global value chain': "Our responsibilities start right at the origins of the raw materials in our products, and end only with a product’s use by consumers. [...] we lay out our global value chain and how we aim to manage it sustainably".
Overall, the company was considered to have a poor supply chain policy.
2. 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.
The company provided an anonymous whistleblowing hotline, available in multiple languages and run by a third party known as 'Speak up' which appeared to be free to use.
The company stated that it was a member of AIM-Progress and the Consumer Goods Forum, however these were not considered multi-stakeholder initiatives as they appeared to have only industry members.
No evidence was found of systematic input from NGOs and/or labour and/or not-for-profit in the country of supply into the verification of labour standard audits.
Overall, the company was considered to have a rudimentary approach to stakeholder engagement.
3. 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.
The company provided significant detail on its audit results and some quantitative analysis "We audited 170 suppliers in 2020, with 69% (117) achieving a pass rating – an improvement of 19% on 2019. Also, we’re seeing tangible improvements in standards at suppliers we’ve supported for a number of years, with the pass rate increasing from 31% to 70%† since their first audit. [...] In 2020, we received 439 cases through Speak Up!, our formal whistleblowing channel. [...] We initially earmarked 173 cases that could raise issues that breach our policy on human rights and responsible business. As of 4 January 2021, 96 of these cases had been closed following internal investigations, with 38 cases being partially or fully substantiated. Of the 38 cases*: 5% relate to disciplinary practices. 76% relate to discrimination, including sexual, moral or verbal harassment, favouritism, or gender and race discrimination. 11% relate to working hours, pay and pay disputes. 8% relate to health and safety (mostly working conditions). [...] Of the remaining 77 cases, 26 have been referred elsewhere for informal review (e.g. employee relations matters) and 51 cases are still pending closure."
This was considered an adequate level of disclosure.
The company was considered to have adequately published a schedule for supply chain audits, stating: "all Reckitt facilities are assessed on the inherent risk associated with their country of operation, product area, sector profile and site function as well as their management controls risk [...] critical and high-risk sites are audited at least once every three years".
Regarding the proportion of suppliers covered by its audit program, the company did not appear to mention second tier suppliers. It stated "In 2020, we also started to review and risk-assess our indirect supply chain to better understand and define how we can increase human rights engagement in 2021."
The company had an adequate policy for handling instances of non-compliance with its code of conduct, which included a staged approach to dealing with violations, stating for example: "Corrective actions – 85% of suppliers and 100% of RB sites audited have an approved corrective action plan in place, with 67.5% of RB site non-conformities addressed."
Ethical Consumer searched the company website for information on who paid the costs of audit. No clear statement was found on a dated policy document, however the document 'Responsible Sourcing and Production - A guide for suppliers' was available on the company website and indicated that the company did not always pay audit costs as a policy. It stated to suppliers "You will need to pay the audit costs."
Overall it was considered ot have a reasonable 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 indicated that the company provided ongoing, scheduled training for buying agents on labour standards in the supply chain: "Each year, all employees and contractors must undergo training on our Code of Conduct and most relevant corporate policies".
A November 2019 document document titled 'Audit Committee' stated under the heading "Whistleblowing, fraud and compliance" that it would "annually review the Company’s procedures for detecting fraud". However, this was considered to be inadequate because no up to date information about how this would be systematically approached, for example through unannounced audits, was identified.
No other significant measures were found addressing difficult issues. In relation to freedom of association, the company stated: "consistent with the law and with Company policy, employees shall have the right to assemble, communicate and join associations of their choice, or not."
No evidence was found that the company was taking steps to address the issue of living wages.
The company was considered to have a rudimentary approach to difficult issues.
Overall, Reckitt Benckiser Group PLC received a middle Ethical Consumer rating for Supply Chain Management and lost half a mark in this category.
Questionnaire response March 2020 (30 March 2020)