Kingfisher Modern Slavery Act (MSA) Transparancy Statement 2020/21

2020·3.7 MB·English

by  Kingfisher Group

Modern
Slavery Act
Transparency Statement
2020/21
2 Kingfisher Modern Slavery Act Transparency Statement 2020/21
At Kingfisher, we respect human Contents
3 Introduction
rights and do not tolerate any form
4 Company overview
of modern slavery in our business or 5 Our supply chain
6 Company policies
supply chains. 8 Risk assessment
10 Due diligence processes for
modern slavery
14 Effectiveness of measures
However, we recognise that no
16 Future plans
17 Transparency Statement approval
business or supply chain is without
17 Entities covered by this statement
risk of modern slavery and it is our
responsibility to ensure we understand
these risks and work in partnership
with others, especially our suppliers,
to identify and mitigate them.
3 Kingfisher Modern Slavery Act Transparency Statement 2020/21
Introduction
About this statement Our approach focuses on: Responding to the pandemic
— Robust policies and governance procedures. Actions and performance in
This statement has been published — Risk assessment. 2020/21 The Covid-19 pandemic has impacted our
in accordance with the UK Modern — Due diligence including supplier engagement, business, supply chain, colleagues, customers
training and a programme of ethical audits. — Worked with a consulting partner and communities during the period covered
Slavery Act, which requires
— Setting and monitoring key performance to identify our salient human rights by this statement. Throughout, we have been
businesses to disclose the steps
indicators. issues, across our business and focused on ensuring the ongoing health and
they are taking to tackle slavery, supply chains, as defined by the safety of all our colleagues, customers and
servitude, forced labour and human We work within our business, with our suppliers UN Guiding Principles Reporting suppliers, and remained fully committed to our
trafficking (together known as and with external partners such as Slave Framework. Responsible Business priorities.
Free Alliance to address modern slavery
modern slavery). It covers the six — Partnered with Slave Free Alliance,
risks. We also support a number of external During the initial phases of the coronavirus
areas outlined in the legislation and a social enterprise developed
initiatives that aim to protect and promote outbreak in China, and subsequently in Europe,
by anti-slavery charity Hope
takes into account good practice,
human rights. We are committed to playing we experienced some modest disruption to
for Justice, who undertook a
including Home Office guidance. our part in working towards the United Nations our supply chain. Overall, there was a relatively
gap analysis of our approach to
Sustainable Development Goals (SDGs) and are limited impact on the supply of goods to our
modern slavery.
a signatory to ‘Better Retail, Better World’, the retail banners from any temporary closures of
Our statement sets out the steps taken by
British Retail Consortium (BRC) commitments — Engaged with suppliers to vendor factories.
Kingfisher plc, its UK operating companies and
on the goals. We are also a member of the UN encourage Covid-secure working
its UK retail banners, to prevent modern slavery
Global Compact and report progress against practices, including carrying out However, periods of national lockdown in our
in its own business and supply chain for the
its 10 principles annually in our Responsible online checks where a physical markets and sourcing regions and the need to
financial year ending 31 January 2021.
Business Report. audit was not possible due to change some working practices to ensure the
the pandemic. continued safety of colleagues, customers and
suppliers in all our markets, have meant that
— 73% of our high-risk production
progress on responsible sourcing has been
sites of finished goods for resale
slower than expected in some areas.
(GFR) have had an ethical audit in
the past two years (see page 10).
We engaged with the Sedex Working Group to
— 60% of goods not for resale support the use of Sedex Virtual Assessments
(GNFR) suppliers (with whom we (SVAs) for factories which could not be visited
spend over £75,000) completed an due to Covid-related restrictions or safe
EcoVadis assessment. working procedures. We accepted SVAs as
an alternative to an ethical audit for existing
vendors, with the audit result valid for one year,
rather than the usual two years (see page 11).
4 Kingfisher Modern Slavery Act Transparency Statement 2020/21
Company overview
Kingfisher plc is an international Our business structure and strategy Our markets and our stores
home improvement company
At Kingfisher, our purpose is to make better
with approximately 1,386 stores
homes accessible for everyone.
in eight countries across Europe.
We operate under retail banners Under our strategic plan, ‘Powered by Kingfisher’,
including B&Q, Castorama, Brico we utilise our core strengths and commercial
Dépôt, Screwfix, TradePoint and assets, and ‘power’ our distinct retail banners
in order to address the significant growth
Koçtaş, supported by a team of
opportunities that exist within the home
80,000 colleagues.
improvement market, returning the business to
growth. To serve customers effectively today,
We offer home improvement products we also need to be digital and service orientated,
and services to consumers and trade while leveraging our strong store assets.
professionals who shop in our stores and via
our e-commerce channels. Our strong and distinct retail banners address
diverse customer needs, operate different
80,000†* models and have a clear positioning and plan to
connect with customers and drive loyalty. These UK &
differentiated brands are aimed at specific Ireland1 Poland
colleagues 1,023 83
customer segments within their markets. They
1,386‡ are powered by Kingfisher, which provides key
benefits, such as Group sourcing and buying,
differentiated own exclusive brands, technology
stores
and partnerships (including joint venture
8 partners, franchisees and marketplaces) and
our values and Responsible Business practices. France2 Romania
214 35
These strengths are underpinned by our
countries
experienced, skilled and committed colleagues
£12.3 billion* and the financial scale of the combined
Kingfisher Group.
total sales
By delivering our strategy and operating as a
Portugal Spain Turkey
Responsible Business, we create sustainable
3 28 140
1. B&Q UK & Ireland 301, Screwfix UK & Ireland 722. value for our customers, our colleagues, our
2. Castorama 93, Brico Dépôt 121. shareholders, our suppliers and broader society.
* Turkey joint venture not included.
† Total, not full-time equivalent.
‡ The sale of our business in Russia was completed
on 30 September 2020.
5 Kingfisher Modern Slavery Act Transparency Statement 2020/21
Our supply chain
We work closely with our With our ‘Powered by Kingfisher’ strategy, Goods for resale – supplier
suppliers to bring the best home we are changing how we source some of production sites by continent (%)
our product ranges. Our Group Offer &
improvement products to our
Sourcing (O&S) team will continue to drive
customers at great prices while
the development and sourcing of our market-
ensuring they meet our ethical leading own and exclusive brand products
standards. We have global sourcing (OEBs) and manage global relationships with
offices in China, other Asian our top international brand suppliers. We will
continue to increase our OEB ranges.
countries and Europe.
Our retail banners will develop the category
The products we sell are currently sourced strategies and product range for their market
from around 2,991 suppliers that are listed on to reflect local tastes and preferences, and be
our systems in over 80 countries and there are responsible for buying non-OEB products.
around 2,824 known production sites that supply
us with finished goods.
Eastern
Europe region Asia Pacific
The map shows the percentage of production region
sites for finished GFR by continent based on Americas region WEuersotpeern r e gion 13.60% 43.70%
1.45%
data disclosed to us by suppliers via Sedex (the 38.77% Middle East region
online supplier data exchange). This covers 2.27%
around 62% of GFR suppliers. There are many
more indirect suppliers in our extended supply
chain, including suppliers of raw materials and
component parts used in the products we sell Africa region
0.18%
and buy. We do not have visibility of all these
suppliers, but have conducted work in higher-
risk areas to identify priority indirect suppliers.
This includes our supply chains for wood and
paper, leather and electroplating. Read more in
‘Assessing risks among materials suppliers’.
Other regions
0.04%
We also source GNFR which support our
business, such as IT equipment for our
colleagues and offices, cleaning services and
logistics.
6 Kingfisher Modern Slavery Act Transparency Statement 2020/21
Company policies
We updated our policy in 2020/21 to require all
Our policy framework addresses Our Group compliance function monitors 3. Supply Chain Workplace Standards audits to be carried out by social compliance
human rights and modern slavery compliance to the Code requirements. auditors certified by APSCA (Association of
Our internal audit function provides Our Supply Chain Workplace Standards Professional Social Compliance Auditors).
and is supported by training.
additional assurance on compliance to key explain the ethical standards we require This will strengthen our audit programme
Our key policies and standards
aspects of the Code, using a risk-based from suppliers. These are aligned with and improve consistency between locations.
include: approach to plan their work. The Audit the Code used by Sedex in the Sedex To become APSCA certified, auditors must
Committee of the Board of Directors Members Ethical Trade Audit (SMETA). complete training, sign a professional Code of
receives regular updates on the outcomes This includes the Ethical Trading Initiative Conduct and have gained a sufficient amount
1. Code of Conduct from our internal audits. (ETI) Base Code and additional elements of professional auditing experience.
agreed by the Sedex Stakeholder Forum.
Our Code of Conduct helps to promote They prohibit slavery and child labour and Our policies have been approved by members
a culture where transparency, honesty 2. Human Rights Policy set out our expectations in areas such of our Group Executive. We aim to review our
and fairness are the norm. It sets out our as health and safety, working hours and policies each year and update them where
personal and shared responsibilities for Our Human Rights Policy sets out our wages, and freedom of association. necessary. Our annual review did not take
meeting high ethical standards. It states commitment to respect human rights, place during 2020 due to the pandemic but will
that all employees have a duty to report in line with international agreements Our ethical audits check supplier take place during 2021. However, Slave Free
any potential breaches of the Code. and guidelines including: the United compliance with our Supply Chain Alliance, a social enterprise and membership
The Code includes a section on modern Nations Guiding Principles on Business Workplace Standards (see ‘Due diligence initiative launched by anti-slavery charity Hope
slavery and states our commitment to and Human Rights; the International Bill processes’). for Justice, undertook a policy gap analysis for
human rights and ethical sourcing. of Human Rights (which includes the policies relating to human rights and modern
Universal Declaration of Human Rights); slavery (see page 12). We will be incorporating
Our Code forms part of the contractual the UN Global Compact; the International 4. Ethical Sourcing Policy their feedback as part of our policy review
terms and conditions for all employees Labour Organisation’s Declaration on in 2021/22.
and is integrated into training (see page 7). Fundamental Principles and Rights at Our Ethical Sourcing and Supplier
All colleagues are now required to Work; the Children’s Rights and Business Workplace Ethical and Environmental You can read our policies at www.kingfisher.com/
complete annual training on our Code of Principles; and UN conventions on the Assurance (SWEEA) Policy sets out our sustainabilitypolicies
Conduct. This covers modern slavery risks elimination of discrimination. approach to ethical audits.
and includes information on how to report More information on our governance and
a concern or escalate issues in relation to It states our commitment to implement The policy requires all high-risk production control framework is in our Annual Report and
modern slavery via our internal reporting due diligence procedures to avoid sites of finished GFR to have a valid Accounts, available at www.kingfisher.com/
mechanisms, whistleblowing hotline or infringing on the rights of others (see ethical audit annually, or every two years investors/company-reports
Slave Free Alliance. Our compliance ‘Due diligence processes’). dependant on the grade received at
the initial audit. The lower the grade, the
network, including a compliance officer
sooner we re-audit.
in each retail banner, helps us implement
our Code.
7 Kingfisher Modern Slavery Act Transparency Statement 2020/21
Embedding our policies into Employee training and awareness We have held training sessions for our We raise awareness of the hotline via our annual
procurement GNFR buyers to introduce them to the compliance training. During 2021/22, we will also
We run regular training sessions to build EcoVadis platform so they can encourage be running an awareness campaign to ensure
We embed the requirements of our policies, awareness of modern slavery and ethical their suppliers to participate. In 2020, we ran employees know about our whistleblowing
Code of Conduct and Supply Chain Workplace sourcing risks among key employees, including training sessions for new starters to our Group hotline and are encouraged to use it to report
Standards into our procurement processes in a those responsible for overseeing our modern Procurement team. any concerns.
number of ways: slavery due diligence and buyers of products
— Potential new suppliers are informed during and services. All new joiners were required to We require suppliers to maintain a means by
the tender process of our Code of Conduct, complete our Code of Conduct training which Whistleblowing which workers can openly communicate and
policies and ethical audit requirements, covers modern slavery risks. On top of that, share grievances with management, without
so they can take these into account when over 35,000 colleagues also completed a Code Our Whistleblowing Policy and procedures fear of reprisal, intimidation or harassment.
quoting to provide products or services. of Conduct refresher module, launched during enable staff and suppliers to report any This requirement is included in our Supply
— Supplier contracts include clauses on the year. Our buying offices carry out training concerns, including about modern slavery Chain Workplace Standards and our ethical
compliance with our Code of Conduct, for appropriate employees on ethical sourcing, and any other human rights violations. Our audits check that suppliers have grievance
policies and standards. Our buying offices which includes modern slavery. independent and confidential whistleblowing mechanisms in place (see ‘Due diligence
are required to review compliance with our hotline is available to all employees and processes’).
ethical audit requirements before any vendor In 2020, we conducted training on modern suppliers. Employees learn about our hotline
is offered a contract to supply GFR. slavery risks in connection with the recruitment through our annual compliance training.
— Our Vendor Manual for our GFR summarises of migrant workers. Thirty colleagues in our
the key requirements of our policies and Vietnam buying office and Sustainability All reports to the hotline are reviewed and,
ethical audit requirements. It is usually shared team attended the training, which was run in where necessary, investigated. The outcome is
with vendors when we request a quotation. conjunction with consultancy Elevate and the reported to the Group Ethics and Compliance
— Our Factory Handbook for China provides UN International Office for Migration. Committee or, from 2021/22, the relevant local
details and guidance around our Supply Chain Ethics and Compliance Committee. Twice a
Workplace Standards. It shows how these Slave Free Alliance also carried out a pilot year, a summary of outcomes is reported to the
should be applied in the factory reflecting local training session with seven buyers in the Audit Committee of the Board of Directors.
circumstances and regulatory requirements, Kingfisher O&S function. A key component of
and is available in English and Chinese. Over the pilot was aimed at helping the commercial Many employees, including those in our Quality,
300 printed copies of the Handbook have colleagues identify the potential for exploitation Buying and Logistics teams, will visit supplier
been distributed to suppliers in the Far in a commercial context. Further training will factories in the course of their work. We want
East. We will publish Factory Handbooks for take place during 2021. them to support our efforts to improve supply
suppliers in India, Malaysia, Taiwan and Vietnam chain standards by reporting any unsafe or
in 2021 which also summarise key aspects From 2021/22, our banners will take on more unethical practices they encounter during
of local labour law. The Handbooks can be responsibility for sourcing products. We these visits.
downloaded from our website. have begun training sessions for buyers in
— Training for our colleagues (see below) and our banners to enable them to implement There were no reports relating to modern
suppliers (see page 11). our responsible sourcing standards. This will slavery made via our whistleblowing line in the
continue during 2021/22. 2020/21 financial year.
8 Kingfisher Modern Slavery Act Transparency Statement 2020/21
Risk assessment
We have a large business and an We also carried out a detailed risk and gap including modern slavery, across our business joined the Sedex platform. This equates to
extensive global supply chain, so we assessment to ensure we understand where and business relationships. around 62% of suppliers of GFR1.
salient risks are most likely to appear in
need to take a risk-based approach
our supply chain and business, and we are We recognise that managing and mitigating Sedex updated and strengthened its self-
to managing human rights and
addressing and prioritising these. This included human rights risks, and upholding human rights, assessment questionnaire during 2020.
modern slavery risks. consideration of emerging risks such as those is a shared responsibility and we will continue We are asking all suppliers to update to
related to the Covid-19 pandemic. to work closely with others, including suppliers, the new questionnaire, which is now more
peers, industry bodies, NGOs and governments, comprehensive with a greater number of
Our salient human rights issues This work has confirmed that the most to address salient issues and raise standards. sector-specific criteria. Around 76% of our
significant human rights risks for our business high-risk production sites have updated to date.
We respect human rights and take steps to are found in our GFR supply chain including
protect the rights of our employees, workers at the raw material extraction and product Risk-based ethical audit programme We use the results of our risk assessment with
in our supply chain and others affected by manufacturing stages. Stop the Traffik, an organisation dedicated
our business activities. As part of this we must We use a number of risk assessment tools to to preventing modern slavery and human
ensure that we identify and manage our salient To inform the saliency assessment and risk help us ensure we target our supplier ethical trafficking, to help us prioritise risk areas in
human rights issues. These are the human rights and gap assessment, we engaged with almost audits on the highest-risk countries, sectors our GNFR supply chain, as well as our recent
at risk of the most severe negative impact 100 colleagues around the business including and locations. This includes: saliency assessment and the review by Slave
through our activities. from our Sourcing, Commercial and Group — Ethical risk matrix: Our ethical risk matrix Free Alliance (see page 12).
functions through interviews and structured uses data from Verisk Maplecroft to help
During 2020, we worked with a consulting questionnaires. We also drew on the findings identify the high-risk product areas and We are also developing approaches to reducing
partner to identify our salient human rights of our previous materiality assessment that countries in our GFR supply chain. We are risks in the wider supply chain including among
issues, across our business and supply chains, considered 25 raw materials present in our currently focused on risks in our direct raw materials suppliers (see ‘Assessing risks
as defined by the UN Guiding Principles products, external human rights frameworks supply chain, particularly labour risks among among materials suppliers’).
Reporting Framework. We identified 10 salient such as the United Nations Guiding Principles suppliers of finished GFR.
issues. These are: on Business and Human Rights, external risk — Sedex: We also use Sedex to help us assess
— Modern slavery. assessment tools, and the findings from our risks in our GFR supply chain. Sedex provides
— Child/underage labour. ongoing engagement with civil society and two indications of risk for each production
— Freedom of association/collective bargaining. industry organisations including Slave Free site – an inherent risk (based on sector and
— Health and safety. Alliance, Elevate and allianceHR. country) and a self-assessment risk (based on
— Wages/working hours. a site’s response to the Sedex risk assessment
— Land rights. The results of these assessments have informed questionnaire).
— Depletion of natural resources. our plans for 2021 and beyond. We are also
— Air, water and land pollution. using the findings of this exercise and our work We aim for all suppliers of GFR to be using
— Impacts of climate change. with Slave Free Alliance (page 12) to further the Sedex platform. In total 1,846 suppliers,
— Discrimination. develop our management of human rights risks, incorporating 2,824 factory sites, have now
1. This is the percentage of suppliers that had joined the Sedex platform by the end of the Kingfisher financial year (31 January 2021). In order
to fully onboard suppliers onto Sedex, Kingfisher also requires that suppliers disclose and link Kingfisher to all production sites of finished
goods for resale (including direct and indirect sites) and work is in progress to achieve this.
9 Kingfisher Modern Slavery Act Transparency Statement 2020/21
We work with Goods and services not for resale Assessing risks among materials Modern slavery risks in our operations
suppliers
EcoVadis, a We work with EcoVadis, a sustainability ratings From the analysis we have done through
platform, to help us assess and manage risk In some cases, we can help to influence our human rights saliency assessment and
sustainability in our GNFR supply chain. Any new suppliers standards in our extended supply chain, with Slave Free Alliance, we believe there is
are required to complete the EcoVadis including among raw material suppliers. a low risk of modern slavery occurring in our
ratings platform, questionnaire covering four themes – labour business operations and among our direct
and human rights, environment, ethics and For example, we require the wood and paper employees.
sustainable procurement. Their responses are used in our products to be responsibly sourced,
to help us assess
reviewed by EcoVadis and a rating provided meaning it is certified to schemes such as Risks are higher for workers providing
highlighting strengths, weaknesses and risk FSC and PEFC or is certified/verified recycled. contracted services such as construction,
and manage risk
areas. We have added the EcoVadis assessment These certification schemes ensure wood is cleaning, security and logistics, particularly
as a requirement in our tender process for new from well-managed forests. FSC and PEFC where labour providers are used. These risks are
in our GNFR
suppliers and set a minimum score threshold have also developed clearer requirements to managed through our GNFR programme (see
which must be achieved within a year of the increase protection for workers’ rights including page 12).
supply chain.
assessment. strengthening their criteria relating to health,
safety and labour issues in the supply chain.
We aim to assess 85% of our GNFR spend (with These will come into force over the next
suppliers with whom we spend over £75,000) by 18 months.
the end of 2021. To date, 60% of our spend has
been assessed by EcoVadis. All suppliers who We have also joined the Leather Working Group
do not meet the EcoVadis Bronze level must to help improve standards and traceability in
put an action plan in place to improve. They our leather supply chain. More information on
are required to redo the assessment within 12 wood and paper and leather is included in our
months to demonstrate that they now meet at reporting (see our website).
least Bronze level. We will be supporting low-
scoring suppliers to make improvements. We previously conducted a materiality
assessment that considered 25 raw materials
Our contracts with new GNFR suppliers in present in our products, to help focus our work
high-risk categories include a ‘right to audit’ on raw materials. This assessed their level of risk
clause. We have asked some of our suppliers for human rights and environmental practices.
to undergo a third-party ethical audit to help Our review of salient human rights issues has
us better understand risks in our GNFR supply provided an updated assessment of human
chain. We expect to complete several supplier rights risks in our materials supply chain.
audits during 2021/22. These will focus on
suppliers in potentially higher-risk categories
such as cleaning services, logistics, uniforms,
construction and facilities.
10 Kingfisher Modern Slavery Act Transparency Statement 2020/21
Due diligence processes
for modern slavery
Our due diligence on modern Our Responsible Business Committee
slavery issues includes ethical (RBC) leads and oversees delivery of our Progress against our policy
Responsible Business strategy and has
risk assessment, ethical audits,
overall oversight of modern slavery risks. Ensure all suppliers meet our ethical and environmental standards.
supplier engagement, training and
The Committee’s role is integral to setting
broader collaboration, including the ambition, facilitating and monitoring To monitor progress against our policy, we require high-risk production sites of finished
with others in our sector and Kingfisher’s Responsible Business strategy. GFR to have an ethical audit. In 2020/21, there were 1,318 high-risk GFR production sites
expert partners. The RBC is a committee of the Board and listed on Sedex. Of these, 960 production sites have had an ethical audit in the past two
is chaired by Non-Executive Director (NED) years, which equates to 73%.
Sophie Gasperment. Its members are our
Governance of modern slavery risks CEO, a second NED, our Chief Offer & Under our new strategy we aim to maximise the benefits of our distinct retail banners,
Sourcing Officer, our Chief People Officer which will continue to have their own product ranges and commercial approaches in
Our Modern Slavery Working Group brings and the CEO of Screwfix. order to service our customer base effectively. The pandemic has also had an impact
as it has made it harder to visit factories and reduced the number of auditors available.
together operational managers and ethical
sourcing representatives from across our
Group functions including procurement Escalation procedure Going forward, we will continue to work with suppliers to achieve compliance with
our ethical policies and standards. This will include our O&S function working with our
(GFR and GNFR), logistics, property, human
resources, community, sustainability We have established a protocol for handling banners to help them prioritise suppliers for engagement and auditing.
and legal and compliance. It coordinates any incidents of modern slavery, to ensure we
implementation of our business-wide respond quickly, effectively and consistently. We assess our suppliers of GNFR using the EcoVadis assessment. To date, 60% of our
modern slavery action plan covering due This involves escalating issues to senior priority spend has been assessed by EcoVadis (see page 15).
diligence, ethical audit, supplier and colleague director level, gathering information and
engagement, and training, policy and investigating non-compliances, as well
reporting. The Working Group usually meets as a process for deciding further action
three times a year but met twice in 2020/21 or escalation. The protocol means we
due to the pandemic. can co-ordinate a quick response to any
concerns raised. It has been communicated
In 2019, we established a Modern Slavery to the relevant people in our Risk, Legal and
Steering Committee made up of senior Sourcing teams.
directors from risk, corporate affairs and
procurement of GFR, to respond to the
Operation Fort case in the UK (see our
‘Modern Slavery Act Transparency Statement
2019/20’). In 2020/21, the Group met twice to
review the results of our human rights saliency
assessment. We will be reviewing and updating
the governance procedures for human rights
in 2021/22.