In July 2021, Ethical Consumer viewed the Guardian website for information on how the company managed workers' rights in its supply chain. A ‘Corporate policies and reports’ page was found which contained a document titled ‘Modern Slavery Statement 2020’. Within this, the company stated that it had a document called ‘Guardian Sourcing Values’ which “requires suppliers to comply with applicable legislation and regulations and be aware of the key risks to human rights in their operations and supply chains”. There were no other policy documents found relating to the company’s supply chain management.

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.

In the Guardian Sourcing Values document, it was stated that Guardian News and Media Limited and its suppliers were expected to live up to and adhere to the principles of the Guardian Sourcing Values. It stated that its supply chains related mainly to: “printing and publishing; distribution of print products; retail products; events services; building services; IT, infrastructure and transport; recruitment and training; customer services; and marketing and advertising”.

In its Modern Slavery Statement, the company stated that as it was a B Corp, it was therefore expected to declare that its “significant suppliers do not have practices or outcomes that produced and/or produces substantial negative impacts regarding human rights, labour conditions or local communities”. Whilst the company stated a policy on child labour, it did not state a specific age limit. The company reported that it was a Living Wage accredited employer and that the minimum salary was reviewed on an annual basis, however this did not appear to apply to its entire supply chain but to its employees.

Regarding forced labour, the company did not mention the term as such- only that it had an ethical assessment process which aimed “to evaluate risk and verify suppliers, including in relation to human rights and modern slavery." It also stated that "where appropriate, contract signatories are informed that modern slavery must be considered before signing any supplier terms and conditions".
The company did not provide any policy related to non-discrimination, freedom of association, or the number of working hours.

Overall, due to the lack of adequate policies on child labour, and the lack of any policies relating to non-discrimination, freedom of association, or the number of working hours, The Guardian was considered to have a poor Supply Chain Policy.

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 labour standards, and for workers to have access to an anonymous complaints system, free of charge and in their own language.

The Guardian provided some information about its policy on stakeholder engagement, including that it had a strong relationship with its recognised unions, The National Union of Journalists and Unite. The company also stated that it had a number of employee forums which provided a platform for employees to raise any concerns on matters relating to pay and the working environment more generally. It did not appear to be a member of a relevant multi-stakeholder initiative. It did not provide any specific processes available for workers in its supply chain to access anonymous complaints systems, free of charge or in their own language, or include any policies related to systematic input from NGOs and/or labour and/or not for profit in the country of supply into the verification of labour standard audits.
In turn, due to the lack of evidence for policies relating to stakeholder engagement, the Guardian received a poor rating for this section.

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.

Ethical Consumer viewed the Guardian Sourcing Values document but nothing related to its auditing and reporting policies was found. The company’s Modern Slavery document was viewed and contained some policies around disclosure of audit findings. The company stated that “Through the BCorp assessment, we have to indicate how we assess the standards practised by suppliers and we have to declare that our significant suppliers do not have practises or outcomes that produced and/or produce substantial negative impacts regarding human rights, labour conditions or local communities.” However, there was no evidence of a quantitative analysis of audit findings at the supplier level.

Regarding an audit schedule, there was no reference to a frequent auditing work plan.
The Guardian did state that “In the case of high risk suppliers the contracts include audit and termination rights to enable more effective monitoring of those suppliers and to enable us to take the relevant action”, but this did not refer to the auditing of labour standards across the breadth of the supply chain with significant depth. Regarding its remediation policy, the company did not mention a staged policy. The company did not refer to the costs of audits.

Overall, as the company did not have any adequate policies, it received a poor rating for auditing and reporting.

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 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.

In terms of purchasing, The Guardian stated in its Modern Slavery Statement that its “procurement team has been trained to assess the risks of modern slavery throughout the tender processes, contract renewals and at the point of new supplier approvals.” However, this did not appear to extend to general workers rights.

Ethical Consumer could not find any further information regarding The Guardian’s policies relating to its approach to difficult issues. The company therefore received a worst rating for this section.

Overall the company received a worst Ethical Consumer rating for Supply Chain Management.

Reference:

Modern Slavery Statement 2020 (10 August 2021)

In September 2021 Ethical Consumer searched the internet for information about Monwell Ltd, including its supply chain management policies and practices. No information or policy was found.
SUPPLY CHAIN POLICY - POOR
Ethical Consumer deemed it necessary for all companies to have a supply chain policy. A strong policy would include the following commitments: no use of a child under 15 (or 14 if ILO exempt), no use of forced labour, no discrimination by race, sex or for any other reason, permit freedom of association, pay a living wage, restrict working hours to 48 hours plus 12 overtime (ideally specifying these hours and that this is without exception).
STAKEHOLDER ENGAGEMENT - POOR
Ethical Consumer also 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. It is also constructive for Trade Unions, NGOs and/or not-for-profit organisations to have systematic input to 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.
AUDITING AND REPORTING - POOR
Ethical Consumer also 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 its 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.
DIFFICULT ISSUES - POOR
Ethical Consumer also deemed it necessary for companies to address other difficult issues in their supply chain. 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 other measures taken to address the issue of living wages, particularly among outworkers, and illegal freedom of association.
The company did not have any publicly available information on any of the above, therefore it received Ethical Consumer's worst rating for Supply Chain Management and lost a whole mark in this category.

Reference:

Monwell website (6 September 2021)

In August 2021, Ethical Consumer viewed a ruling on the ASA website for The Guardian News and Media Ltd, which was dated to 09 August 2017. The ruling provided a description of the advertisement in question:

"A web page on the Guardian Recruiters website, aimed at recruiters, seen on www.theguardian.com in November 2016, described the charity professionals audience for the Guardian Jobs website. The web page stated “36% of Guardian Jobs users have not used charityjob.co.uk”. Smaller text beneath this stated “Source: Guardian Connecting Professionals 2015”. Further text stated “4x as many charity readers as charityjob.co.uk”. Smaller text below this stated “Source: Guardian Connecting Professionals 2015, GPN member data 2015, Comscore 2015”.

JobLadder Ltd, which owned charityjob.co.uk (CharityJob) made a claim to challenge whether:

1. the claim “36% of Guardian Jobs users have not used charityjob.co.uk” was misleading and could be substantiated; and
2. the comparison was verifiable."

Whilst the first part of the claim was not upheld, the second point was. The ASA stated:

"The CAP Code required comparisons with identifiable competitors to be verifiable. This meant that an ad which featured a comparison with an identifiable competitor or competitors needed to include, or direct a consumer to, sufficient information to allow them to understand the comparison, and be able to check the claims were accurate, or ask someone suitably qualified to do so. While the source from which the data was taken was listed below the claim, no further information on why it was relevant to supporting it had been provided. Furthermore, the source did not appear to be in the public domain. For those reasons, we did not consider that the ad allowed consumers or competitors to verify the comparison and therefore concluded that the claim breached the Code.
On that point, the ad breached CAP Code (Edition 12) rule 3.35 (Comparisons with identifiable competitors)."

In response, the ASA took the following action, "We told Guardian News and Media Ltd to ensure that claims with identifiable competitors made in their advertising were verifiable."

This case was not considered to present a significance ethical issue, and therefore this reference is for information only.

Reference:

ASA Ruling on Guardian News and Media Ltd (5 August 2021)