Modern slavery act transparency statement 2018/19 - Screwfix.com

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modern slavery act
transparency statement
2018/19
Kingfisher   Modern Slavery Act               2
             Transparency Statement 2018/19

                                                                                  our business                   company
                                                                                  structure                      overview

At Kingfisher we respect                          This statement has been
                                                  published in accordance with
                                                  the UK Modern Slavery Act,
                                                                                  Kingfisher plc is a home
                                                                                  improvement company
                                                                                  with over 1,300 stores in
                                                                                                                  77,300
                                                                                                                  Colleagues3, 4
human rights and do not                           which requires businesses       10 countries across Europe.

                                                                                                                  1,331
                                                  to disclose the steps they
                                                  are taking to tackle slavery,   We employ 77,300 people and
tolerate any form of modern                       servitude, forced labour and
                                                  human trafficking (together
                                                                                  nearly six million customers
                                                                                  shop in our stores and          Stores4
slavery. However, we                              known as modern slavery).       through our websites and

                                                                                                                  10
                                                  It sets out the steps taken     apps every week.
                                                  by Kingfisher plc and its UK

recognise that no supply                          operating companies1, to
                                                  prevent modern slavery in
                                                                                  Our customers are everyone
                                                                                  wanting to improve their        Countries
                                                  its own business and supply     home, as well as the experts
chain is without risk of                          chain for the financial year
                                                  ending 31 January 2019.
                                                                                  and trade professionals who
                                                                                  help them.                      6 million
modern slavery and it is our                      Our statement covers the
                                                  six areas outlined in the
                                                  legislation and takes into
                                                                                                                  Customers every
                                                                                                                  week
responsibility to ensure we                       account good practice,

                                                                                                                  £11.7 bn
                                                  including Home Office
                                                  guidance2.
understand these risks and                                                                                        Total sales

work in partnership with
our suppliers to identify and                                                                                    1 All references in this statement to
                                                                                                                   ‘Kingfisher’, ‘We’ and ‘Our’ cover the
                                                                                                                   Group including Kingfisher plc and

mitigate them.                                                                                                     its Operating Companies, including
                                                                                                                   those legally required to produce a
                                                                                                                   Transparency Statement under the
                                                                                                                   Modern Slavery Act. These are B&Q
                                                                                                                   plc, B&Q Properties Ltd, Kingfisher
                                                                                                                   International Products Limited,
                                                                                                                   Kingfisher Information Technology
                                                                                                                   Services (UK) Limited and Screwfix
                                                                                                                   Direct Limited.
                                                                                                                 2 Transparency in Supply Chains,
                                                                                                                   A Practical Guide. Published by the
                                                                                                                   Home Office, 2017.
                                                                                                                 3 Total headcount, not full time
                                                                                                                   equivalent.
                                                                                                                 4 Turkey joint venture not consolidated.
Kingfisher                                Modern Slavery Act                          3
                                          Transparency Statement 2018/19

our markets                                                                           our stores

At Kingfisher, we believe                 This brings opportunities to
everybody should be able to               develop closer and deeper
have a home they can feel                 relationships with a smaller
good about, so our purpose is             number of suppliers, giving
to make home improvement                  us more visibility over our
accessible for everyone. We               supply chain and ability to
want our customers to be                  work in closer partnership
confident that the products               with suppliers to implement
they buy from us are                      our ethical and sustainability
responsibly sourced.                      standards.                                                                                               Russia
                                                                                                                                                    20
The ONE Kingfisher five year
plan, which started in 2016/17,
is leveraging the scale of the
business by creating a unified
company, where customer
needs always come first. We
are unifying our ranges and                                                                          UK &
supply chains, making the                                                                          Ireland                      Poland
best products from around                                                                            923 1                        76
our business available in all                                                                                         Germany
our markets.                                                                                                             19

                                                                                                             France                      Romania
                                                                                                              224 2                        38 3

                                                                           Portugal
                                                                              3           Spain                                                             Turkey 4
                                                                                           28
1   B&Q UK & Ireland 296, Screwfix 627.
2   Castorama 101, Brico Dépôt 123.
3   Brico Dépôt 15, Praktiker 23.
4   Turkey joint venture not
    consolidated.
Kingfisher                                Modern Slavery Act                          4
                                          Transparency Statement 2018/19

goods for resale – supplier production                                                                       our supply chain
sites by continent (%)

                                                                                                             Our products are currently
                                                                                                             sourced globally from around
                                                                                                             2,800 suppliers and there
                                                                                                             are around 3,700 production
                                                                                                             sites1 that supply us with
                                                                                                             finished goods. The number
                                                                                                             of suppliers this year is
                                                                                                             around one-third lower than
                                                                                                             in 2017/18, reflecting progress
                                                                                                             on our ONE Kingfisher
                                                                                                             transformation strategy.
                                                                             Eastern Europe
                                                            Western Europe         6%                        The map shows the
                      North America                              15%                                         percentage of production
                           1%                                                                 Asia Pacific   sites by continent.
                                                                                                  77%
                                                                                                             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 and buy.
                                                                                                             Read more in Assessing risks
                                                                                                             among materials suppliers.

                                                                                              Other          We also source goods and
Kingfisher                    Modern Slavery Act                 5
                              Transparency Statement 2018/19

our targets and
commitments

Our commitment to human       We support a number of                 Targets                                 Progress in 2018/19             Progress against target
rights is integrated in our   external initiatives that aim to
sustainable growth plan –     protect and promote human
                                                                     Ensure all suppliers                    995 production sites have       On track to target
our sustainability roadmap    rights. We are committed to
                                                                     meet our ethical and                    had an ethical audit in the
up to 2025 – which sets out   playing our part in working
                                                                     environmental standards                 past two years. This is 47%
how we will make it easy      towards the United Nations
                                                                     by 20201.                               of high-risk production
for our customers to have     Sustainable Development
                                                                                                             sites on Sedex, the online
sustainable, good homes       Goals (SDGs) and are a
                                                                     To monitor progress, we                 supplier data exchange
(See www.kingfisher.com/      signatory to ‘Better Retail,
                                                                     require high-risk production            (www.sedexglobal.com).
sustainability).              Better World’, the British
                                                                     sites of finished goods for
                              Retail Consortium (BRC)
                                                                     resale to have an ethical               See Due diligence
This includes two targets     commitments on the goals.
                                                                     audit by 2020. We have                  processes section for
designed to promote human     We are also a member of
                                                                     also started assessing our              further details of our
rights and address modern     the UN Global Compact and
                                                                     suppliers of goods and                  supplier audit programme.
slavery risks (see table to   report progress against its
                                                                     services not for resale using
the right).                   10 principles annually in our
                                                                     the EcoVadis assessment.
                              Sustainability Report.
                                                                     We will report progress
                                                                     next year.
                              We believe it is important
                              to report openly on our
                              approach and progress.                 Establish strategic                     We have started engaging        On track to target
                              Our Modern Slavery Act                 community programmes                    with key suppliers and
                              Transparency Statement                 to achieve positive change              stakeholders in Turkey and
                              2017/18 was ranked 11th in             in key sourcing regions                 China to identify where we
                              the Business & Human Rights            by 2025.                                can make a difference for
                              Centre’s report – FTSE 100 &                                                   communities, workers and
                              the UK Modern Slavery Act:             Many of our community                   suppliers, including piloting
                              From Disclosure to Action.             programmes help to support              projects in our Turkish
                              It was ranked 12th in the              and promote human rights.               ceramics supply chain, see
                              Global Governance FTSE 100                                                     page 11.
                              League Table compiled by
                              the non-profit Development
                              International (DI).

                                                                     1 This target covers our goods for
                                                                       resale suppliers and our 300 key
                                                                       suppliers of goods and services not
                                                                       for resale.
Kingfisher                        Modern Slavery Act                                6
                                  Transparency Statement 2018/19

company policies

                                                                                                    Our policy framework,
Our policy framework              Universal Declaration of         4. Ethical Sourcing Policy
addresses human rights            Human Rights); the UN Global     Our Ethical Sourcing and
and modern slavery and is         Compact; the International       Supplier Workplace Ethical
supported by training. Our        Labour Organisation’s            and Environmental Assurance
key policies and standards
include:
                                  Declaration on Fundamental
                                  Principles and Rights at
                                  Work; the Children’s Rights
                                                                   (SWEEA) Policy sets out
                                                                   our approach to ethical
                                                                   audits. The policy requires
                                                                                                    supplier standards and
1. Code of Conduct
Our Code of Conduct helps
to promote a culture where
                                  and Business Principles
                                  and UN conventions on the
                                  elimination of discrimination.
                                                                   all high-risk production sites
                                                                   of finished goods to have an
                                                                   ethical audit by 2020.
                                                                                                    training programmes
                                                                                                    help us to address
transparency, honesty and         It sets out our commitment
fairness are the norm. It         to implement due diligence       Read our policies at
sets out our personal and         procedures to avoid infringing   www.kingfisher.com/
shared responsibilities           on the rights of others (see     sustainabilitypolicies
for meeting high ethical
standards. It states that all
employees have a duty to
                                  Due diligence processes).

                                  3. Supply Chain Workplace
                                                                                                    human rights and
report any potential breaches
of the Code. The Code was
fully updated in 2018 and
                                  Standards
                                  Our Supply Chain Workplace
                                  Standards explain the ethical
                                                                                                    modern slavery risks.
now includes a section on         standards we require from
modern slavery. It states our     suppliers. These are aligned
commitment to human rights        with the code used by Sedex
and ethical sourcing.             in the Sedex Members Ethical
                                  Trade Audit (SMETA). This
2. Human Rights Policy            includes the Ethical Trading
Sets out our commitment           Initiative (ETI) Base Code and
to respect human rights,          additional elements agreed
in line with international        by the Sedex Stakeholder
agreements and guidelines         Forum. They prohibit slavery
including: the United Nations     and child labour and set out
Guiding Principles on             our expectations in areas
Business and Human Rights;        such as health and safety,
the International Bill of Human   working hours and wages,
Rights (which includes the        and freedom of association.
Kingfisher                           Modern Slavery Act                                 7
                                     Transparency Statement 2018/19

company policies
continued

We communicate the Code              We review our policies           —— Supplier contracts include        Whistleblowing policy and         It can be used by any
of Conduct to all employees,         annually and update them            clauses on compliance             procedures                        Kingfisher employee and all
including through our training       where necessary. Our Code           with our Code of Conduct,         Our whistleblowing policy         reports are investigated by
and awareness programmes,            of Conduct was updated              policies and standards1 and       and procedures enable staff       our ethical sourcing team.
see Employee training and            and strengthened in 2018,           our buying offices review         and suppliers to report any       We have provided training to
awareness. The Code forms            including the addition of a         compliance with our ethical       concerns about modern             help our teams use the tool
part of the contractual              section on modern slavery.          audit requirements before         slavery and any other             and understand the types of
terms and conditions for all         Our Supply Chain Workplace          any vendor is offered a           human rights violations. Our      issues they might encounter.
new employees. We have a             Standards were also updated         contract to supply goods          independent and confidential
compliance network which             to align with the code used         for resale;                       whistleblowing service,           There were no reports
includes a compliance officer        by Sedex. This includes                                               In Touch, is available to all     relating to modern slavery
in each operating company            requirements on responsible      —— Our Vendor Manual for             employees (intouchfeedback.       made via our whistleblowing
to help us implement our             recruitment set by the              our goods for resale              co.uk/kingfisher) and             line or other reporting
Code of Conduct. Our                 Sedex Stakeholder Forum.            summarises the key                suppliers (intouchfeedback.       channels in the 2018/19
internal audit function              All policies are approved           requirements of our               co.uk/kfsupplier). All reports    financial year. We require
monitors compliance of all           by members of our Group             policies and ethical audit        to the helpline are fully         suppliers to maintain a
businesses within Kingfisher         Executive.                          requirements;                     investigated and followed up      means by which workers
to the requirements set by                                                                                 and the outcome reported to       can openly communicate
our Code of Conduct, using           We embed the requirements        —— We published a new                the Audit Committee of the        and share grievances with
a risk based approach to             of our policies, Code of            Factory Handbook in 2018          Board of Directors.               management, without fear
plan their work. The Audit           Conduct and Supply Chain            for suppliers in Asia. This                                         of reprisal, intimidation or
Committee of the Board of            Workplace Standards into our        provides details of our           Many employees, including         harassment. This requirement
Directors receives regular           procurement processes in a          Supply Chain Workplace            those in our quality, buying      is included in our Supply
updates on the outcomes              number of ways:                     Standards and shows how           and logistics teams, will visit   Chain Workplace Standards
from our internal audits.                                                these should be applied in        supplier factories in the         and our ethical audits check
More information on our              —— Potential new suppliers are      the factory. It is available in   course of their work. We want     that suppliers have grievance
governance and control                  informed during the tender       English and Chinese and on        them to support our efforts       mechanisms in place (see
framework is in our Annual              process of our Code of           our website. We plan to roll      to improve supply chain           Due diligence processes).
Report and Accounts.                    Conduct, policies and            this out to more countries        standards by reporting any
                                        ethical audit requirements,      in future.                        unsafe or unethical practices
Our ethical audits check                so they can take these                                             they encounter during these
supplier compliance with                into account when quoting     We train employees and               visits. We launched ‘CSR
our Supply Chain Workplace              to provide products or        suppliers on our policies            Watch’, an online reporting
Standards (see Due diligence            services;                     and standards through                tool for employees in China
processes).                                                           our modern slavery and               and the Far East to make it
                                                                      ethical sourcing training            easy to report such issues.
                                                                      programmes (see Due
                                                                      diligence processes and
1 This includes contracts with                                        Employee training and
  suppliers of group-sourced
                                                                      awareness).
  products and services, including
  unified ranges.
Kingfisher                                Modern Slavery Act                               8
                                          Transparency Statement 2018/19

risk assessment

We have an extensive global               —— Sedex: We also use Sedex      Goods and services not           We are also using supplier
supply chain so we need to                   to help us assess risks       for resale                       visits and audits to help us     In practice: assessing
take a risk based approach,                  in our goods for resale       We use the risk assessment       better understand risks in       standards among UK
focusing on the highest risk                 (GFR) supply chain. Sedex     carried out in 2017 by Stop      our GNFR supply chain,
                                                                                                                                             logistics suppliers
countries and sectors for                    provides two indications      the Traffik, an organisation     see case study, right for
modern slavery and human                     of risk for each production   dedicated to preventing          an example. Our findings
rights issues. We assess risk                site – an inherent risk       modern slavery and               show that the level of risk
on an ongoing basis using:                   (based on sector and          human trafficking, to help       can vary significantly from      Our logistics suppliers         We are now working with
                                             country) and a self           us prioritise the areas of       supplier to supplier and         run our distribution            UK logistics suppliers to
—— Ethical risk matrix: Our                  assessment risk (based        risk in our supply chain for     that not all suppliers in        centres and the transport       encourage labour providers
   ethical risk matrix uses                  on a site’s response to the   goods and services not for       high-risk categories will        operations for our store        used in our logistics network
   data from Maplecroft to                   Sedex risk assessment         resale (GNFR).                   present a high-risk. For         and home deliveries. We         to sign up to minimum
   help identify the high-                   questionnaire).                                                example, cleaning services       have identified the use         standards developed by
   risk product areas and                                                  We are now also using            have been identified as a        of temporary labour by          the Indirect Procurement
   countries in our goods for             We aim for all suppliers of      EcoVadis, a sustainability       potential high-risk area.        logistics suppliers as a        Human Rights Forum
   resale (GFR) supply chain.             goods for resale to be using     ratings platform, to help        However, we have audited         potential risk area for human   (see External initiatives/
   We are currently focused               the Sedex platform by the        us assess and manage risk        one of our contractors in        rights. During 2018/19, we      partnerships). 40 have done
   on risks in our direct supply          end of 2020. We made good        in our GNFR supply chain.        the UK and found it to meet      took steps to increase          so, over 90% of the total.
   chain, particularly labour             progress in 2018 and around      Our suppliers are required       high standards with a low        our understanding of this
   risks among suppliers of               1,900 suppliers, incorporating   to complete the EcoVadis         risk for human rights. During    risk including asking all
   finished goods for resale.             2,600 factory sites, have now    questionnaire covering four      2019, we plan to focus on        UK logistics suppliers to
   We are also developing                 joined the Sedex platform.       themes – labour and human        further audits in the areas of   complete a self-assessment
   approaches to reducing                 This equates to around           rights, environment, ethics      construction and logistics to    questionnaire.
   risks in the wider supply              66% of suppliers of goods        and sustainable procurement.     address risks associated with
   chain including among raw              for resale1.                     Their responses are              subcontracting and labour        We also conducted a Sedex
   materials suppliers, see                                                reviewed by EcoVadis and a       providers.                       ethical audit of one of
   Assessing risks among                                                   rating provided highlighting                                      our main UK distribution
   materials suppliers.                                                    strengths, weaknesses and        We have also started             centres, focussing on risks
                                                                           risk areas. We have added        to engage with uniform           associated with the labour
                                                                           the EcoVadis assessment as       suppliers to understand their    agencies providing drivers
                                                                           a requirement in our tender      current approach to ethical      and workers. As part of
                                                                           process and set a minimum        audits and any new suppliers     the audit, we used the
1 This is the percentage of
                                                                           score threshold which must       will need to meet the ethical    Sedex worker wellbeing
  suppliers that had joined the
  Sedex platform by the end of                                             be achieved within a year        audit requirements included      assessment tool to enable
  the Kingfisher financial year                                            of the assessment. We plan       in our tender process.           us to gain a better insight
  (31 January 2019). In order to                                           to contact 1,000 suppliers                                        into how the agency
  fully onboard suppliers onto
  Sedex, Kingfisher also requires                                          during 2019, including our top                                    workers at the site feel
  that suppliers disclose and link                                         400 suppliers that account                                        about their jobs.
  Kingfisher to all production sites of                                    for 75% of our spend, asking
  finished goods for resale (including
                                                                           them to complete the
  direct and indirect sites) and work
  is in progress to achieve this.                                          assessment.
Kingfisher                       Modern Slavery Act                              9
                                 Transparency Statement 2018/19

assessing risks
among materials
suppliers

                                                                                                 We are working on
We are working on a number       In 2018, we started a research    We are working with
of projects to identify and      project into the potential use    suppliers in the leather
address salient human rights     of conflict minerals in our       supply chain to protect
issues in our extended supply    products, such as natural         workers and the environment
chain including among raw
material suppliers.
                                 diamonds, cobalt and
                                 tungsten. We identified
                                 suppliers and sub-suppliers
                                                                   by improving standards for
                                                                   the use of chemicals in the
                                                                   tanning process.
                                                                                                 projects to identify
For example, we require the
wood and paper used in our
products to be responsibly
                                 using these minerals and
                                 have begun to engage with
                                 them to identify where these
                                                                                                 and address salient
                                                                                                 human rights issues in
sourced, meaning it is           materials are sourced from.
certified to schemes such        We found that the diamonds
as FSC and PEFC or is            used in the supply chain for
recycled. These certification    Kingfisher branded products,
schemes ensure wood is
from well-managed forests.
Both schemes are also in the
                                 for example for drill tips and
                                 saw blades, are synthetic
                                 diamonds manufactured in
                                                                                                 our extended supply
process of developing new
requirements to increase
protection for workers’ rights
                                 two factories in China. We
                                 do not yet have full visibility
                                 of the cobalt and tungsten
                                                                                                 chain including for
                                                                                                 raw materials such as
including strengthening their    supply chains and are
criteria relating to health,     continuing to engage with
safety and labour issues in      the relevant suppliers to
the supply chain.                address this.

We are working with the
TFT Responsible Stone
                                 We also commissioned a
                                 materiality assessment which
                                                                                                 wood and paper, stone,
Programme, to improve
ethical, safety and
environmental standards
                                 considered 25 raw materials
                                 present in our products.
                                 This assessed their level of
                                                                                                 leather and minerals.
in quarries and stone            risk for human rights and
processing factories and         environmental practices. The
working towards improving        work was completed in late
the traceability of stone        2018 and we are reviewing
products.                        the findings to identify
                                 next steps.
Kingfisher                            Modern Slavery Act                                10
                                      Transparency Statement 2018/19

due diligence
processes

Our Modern Slavery Working            Our most significant human        We require suppliers to act
Group oversees due                    rights and modern slavery         swiftly to address non-           In practice: supplier
diligence and disclosure on           risks are in our supply           conformances and to ensure        engagement
human rights and modern               chain. We are rolling out a       the welfare of workers. We
slavery. It meets three               programme of ethical audits       monitor the effectiveness
times a year and brings               for high-risk production sites    of our audit programme
together ethical sourcing             of finished goods for resale      by grading suppliers and          Supplier spot checks            Overtime project pilot
representatives from our              (see Risk assessment section      tracking the number and type
group functions including             for details of how we identify    of non-conformances that          Our ethical sourcing            Excessive overtime remains
procurement (GFR and                  risk). Each production site       are found and remedied (see       team make regular visits        a challenge in China, which
GNFR), logistics, property,           identified as high-risk is        Effectiveness of measures:        to supplier sites where         is bad for workers but can
human resources, legal and            required to have a Sedex          supplier audit results). 995      potential concerns or           also have a negative impact
compliance. The Working               Members Ethical Trade Audit       production sites have had an      issues have been raised, for    on supplier productivity
Group reports to our Group            (SMETA) or equivalent at          ethical audit in the past two     example by an ethical audit.    and staff turnover. We have
Sustainability Committee, a           least once every two years.       years. We aim for all high-risk   This can be particularly        launched a project to raise
sub-committee of our Group                                              production sites of finished      important for product           awareness among suppliers
Executive.                            The audit reviews suppliers’      goods for resale (as identified   lines where demand is           about the need to address
                                      performance and identifies        through Sedex) to be audited      seasonal, requiring peaks       excessive overtime and
We aim to identify and                any instances of non-             by 2020 and we are currently      of activity at certain times    the business benefits of
manage ‘salient’ human rights         conformance. These are            at 47%1.                          of the year. For example,       doing so. We are trialling this
issues, as defined by the UN          prioritised according to                                            several years ago we            approach with one of our
Guiding Principles Reporting          the Sedex classifications                                           identified cases of child       garden furniture suppliers.
Framework. These are the              of minor, major, critical                                           labour at factories supplying
human rights at risk of the           and business critical. Any                                          Christmas products and we
most severe negative impact           instances of modern slavery                                         worked with the factories
through our activities. Our           or child labour would be                                            to address this. Our team
Modern Slavery Working                classified as business critical                                     now conducts regular
Group has agreed an action            – the most serious breach of                                        unannounced spot checks,
plan for improving our due            our standards.                                                      in addition to our program
diligence on salient human                                                                                of ethical audits, to confirm
rights and modern slavery                                                                                 that the factories continue
issues, including training,                                                                               to meet our standards.
ethical risk assessment
and supplier engagement
and audit.

1 47% of those high-risk production
  sites using Sedex.
Kingfisher                       Modern Slavery Act               11
                                 Transparency Statement 2018/19

                                                                       Supplier training and            External initiatives/             —— In 2018/19, we were
Promoting rights and                                                   engagement                       partnerships                         members of UK
supporting communities                                                 We are collaborating with        We participate in several            Stakeholders for
                                                                       suppliers to help build          partnerships aimed at                Sustainable Development
                                                                       their knowledge and              improving standards across           (UKSSD), a cross-sector
                                                                       understanding of human           the retail sector. For example:      network of organisations
Through our community            workforce; and the future             rights issues and how to                                              who work together to
strategy, we aim to promote      impact of automation on               address them. Examples           —— We are a member of an             drive action on the UN
the rights of workers and to     workers and businesses.               are included in the section         EDRA (the European DIY            Sustainable Development
improve skills and livelihoods   We have piloted a worker              In practice: supplier               Retail Association) working       Goals in the UK;
among communities in our         training programme with               engagement.                         group, which aims to
supply chain.                    93 workers from one of our                                                develop a collaborative        —— We helped establish the
                                 ceramics suppliers in Turkey          We conducted two seminars           approach to responsible           Indirect Procurement
As a first step, we undertook    and begun a pilot high school         for suppliers in China              sourcing within the home          Human Rights Forum to
research and direct              student training programme            during 2018 at Shanghai and         improvement sector;               promote collaboration
stakeholder engagement           to support future generations         Guangzhou. These provided                                             with other businesses
in Turkey and China. This        to develop life and technical         a forum to discuss common        —— We are members of the             and Sedex on ways to
included meeting with            skills. In 2019 and 2020 we           challenges and to share             British Retail Consortium         understand and address
key suppliers, workers,          will focus on scaling-up these        best practice approaches            (BRC) Working Groups              risks associated with
community groups,                projects across our Turkish           on issues such as overtime,         on Ethical Labour and             goods and services not
education organisations          supply chain.                         health and safety, carbon and       Responsible Sourcing              for resale. For example,
and trade unions, to help us                                           environmental management.           and we are signatories to         it has developed a set
understand the issues they       We will also investigate              Attendees were provided             Better Retail, Better World,      of standards for labour
face and identify ways we        other supply chains and               with a hard copy of our             a collaboration led by the        providers, see In practice:
can support them.                geographies where these               factory handbook. In total 484      BRC aimed at supporting           assessing standards among
                                 projects can add value for            people attended from 316            the UN Sustainable                UK logistics suppliers.
In Turkey we identified          communities, workers and              supplier companies.                 Development Goals in              We are one of ten core
three key challenges in our      suppliers where Kingfisher                                                areas including modern            members who meet on a
ceramics supply chain: a         operates.                             We plan to hold regular             slavery and decent work;          quarterly basis.
skills gap, with not enough                                            webinars with EcoVadis for
workers having the technical                                           our GNFR suppliers during
skills the industry needs to                                           2019. Around 50 GNFR
meet future challenges; an                                             suppliers attended the first
ageing population with fewer                                           session.
young people joining the
Kingfisher                       Modern Slavery Act               12
                                 Transparency Statement 2018/19

effectiveness of                                                       Top five non-conformances
                                                                       by category (%)
measures: supplier
audit results

We aim to drive up ethical       Audit results                                                                  56%
standards in our supply          During 1st February 2017
chain through our supplier       – 31st January 2019, our
engagement and ethical           buying offices identified 54          Health, safety & hygiene
audits (see Due diligence        production sites that did not
processes). We monitor           comply with our minimum                                                        14%
the effectiveness of our         standards (i.e. they achieved
ethical audit programme for      a business critical grade).
production sites supplying       We were able to work with             Working hours
goods for resale using           52 of these sites to resolve
a number of indicators.          the non-conformances. One                                                      11%
These include:                   factory was discontinued
                                 for business reasons. The
—— Percentage of sites           remaining factory has                 Wages & benefits
   according to audit grades     submitted corrective actions
   (see pie chart)               which are pending auditor                                                      7%
                                 approval.
—— Number of sites that
   failed to comply with our     During 2018/19, ethical               Environment
   minimum standards and         audits identified 21 non-
   the number of these which     conformances under the                                                         6%
                                                                                                                7%
   have been remedied (see       heading ‘employment is freely
   Audit results)                chosen’. These included               Management systems
                                 three cases of employers
—— Top non-conformances          illegally withholding worker
                                                                                                                6%
                                                                                                                7%
   identified by category (see   passports, see In practice:
   bar chart)                    audit examples. There were
                                 two instances of employers            Other
As we roll out the EcoVadis      withholding wage payments
assessment to our GNFR           to workers which were                 The majority of non-conformances
suppliers, we will develop       resolved.                             relate to health and safety, which
                                                                       include fire safety issues such as
performance measures                                                   provision of fire extinguishers. Other
and will report our progress                                           common non-conformances include
next year.                                                             working hours, wages and benefits,
                                                                       and environmental management.

                                                                       The % of non-conformances in the
                                                                       chart are from ethical audits carried
                                                                       out in the past two years (2017/18 and
                                                                       2018/19). The data covers production
                                                                       sites registered so far on Sedex.
Kingfisher                  Modern Slavery Act                         13
                            Transparency Statement 2018/19

Supplier production sites
by grade (%)

  	Grade 1                                                                            Audit grades                    The chart shows the audit
   	Grade 2                                                                           We allocate grades based        grades for the production
  	Grade 3                                         6%       4%                        on the results of the most      sites that have had an audit
   	Grade 4                                                                           recent ethical audit that       in the past two years.1 It
  	Grade 5
                                                                  5%                   has been carried out in the     includes the results from the
   	Grade Business                                                                    past two years. The grades      latest full audit at each site.
     Critical                                                               4%         are based on the number of      It therefore does not reflect
                                                                                       non-conformances identified     any corrective actions taken
                                                                                       during the audit: grade 1       or results from follow up
                                                                                       (no non-conformances);          audits.2 We work with sites
                                                                                       grade 2 (some observations);    graded as business critical to
                                                                                       grade 3 (minor non-             resolve the issues (see Audit
                                                                                       conformances); grade 4 (1-3     results). During 2019, we plan
                                                                                       major non-conformances);        to review how we monitor
                                                                                       grade 5 (4 or more major        and work with suppliers to
                                                                                       non-conformances or 1-3         improve factory performance
                                                                                       critical non-conformances);     grades over time.
                                                                                 24%   and business critical grade
                                                                                       (business critical non-
                                                                                       conformances or 4 or more
                                                                                       critical non-conformances).

                                                                                       Over time, we aim for
                                                                                       our suppliers to improve
                                                                                       performance and require
                                                                                       suppliers with low grades
                                                                                       (grade 4, 5 and business
                            57%                                                        critical) to have an annual
                                                                                       re-audit. Other suppliers are   1 A total of 995 production sites had
                                                                                                                         an audit in the past two years. The
                                                                                       re-audited within two years.      chart shows audit grades for 978
                                                                                                                         of these production sites. We are
                                                                                       We follow up with suppliers       unable to report audit grades for 17
                                                                                                                         of the sites audited. This is because
                                                                                       to ensure the most serious
                                                                                                                         their Sedex membership has
                                                                                       issues are remediated. As         expired and therefore the grades
                                                                                       a last resort, we cease to        were not available to download
                                                                                       trade with factories if they      from Sedex when our end of year
                                                                                                                         reports were generated.
                                                                                       don’t work with us to address   2 The previous year, we reported
                                                                                       business critical issues.         grades for the latest audit, including
                                                                                                                         partial and follow up audits, and
                                                                                                                         therefore the figures for 2018/19
                                                                                                                         are not directly comparable with
                                                                                                                         those reported for 2017/18.
Kingfisher                          Modern Slavery Act                                14
                                    Transparency Statement 2018/19

                                                                                                       employee training
                                                                                                       and awareness

                                                                                                       We are working to build          We conducted refresher
In practice: audit examples                                                                            awareness of modern              training for our Group
                                                                                                       slavery and ethical sourcing     Purchasing Team during 2018
                                                                                                       issues among employees,          on modern slavery covering
                                                                                                       particularly those responsible   identifying risks and engaging
Withholding passports               In Taiwan and Malaysia            Inadequate fire exits            for overseeing our modern        suppliers. The team also
                                    we stopped orders to the                                           slavery due diligence as         attended a sustainability
During 2018, as part of             factories while we worked         Most non-compliances we          well as buyers of products       training session which
our ethical compliance              with them to resolve the          identify are due to factories    and services. We are             covered our approach to
programme, we identified            issue. In Malaysia, the factory   failing to implement adequate    incorporating awareness          ethical sourcing.
three cases of employers            contacted its workers, giving     health and safety measures.      of modern slavery into our
withholding the passports           them the option to leave          During 2018, for example,        Code of Conduct training.        Our buying offices carry
of migrant workers. The             their passports voluntarily in    an audit at a factory in         This includes an e-learning      out training for appropriate
production sites were               a designated secure facility,     China supplying wooden           module that all employees        employees on ethical
located in Malaysia, Taiwan         accessible at any time. It        flooring found that one of       will be required to complete     sourcing, which includes
and the United Arab                 obtained written consent          the warehouse buildings only     in 2019 and more detailed        modern slavery. In 2018,
Emirates. We worked with            for all the passports stored      had one exit and therefore       face to face training sessions   this included training 339
these suppliers to ensure           in the facility and returned      did not meet our standards       for colleagues in higher         employees in our offices in
that clear processes are in         passports to any workers          on provision of fire exits. We   risk roles.                      Shanghai, Hong Kong and
place to safeguard worker           who did not want to use           contacted the supplier and                                        Vietnam on topics including
rights and to ensure that           the service. The factory          following our request they       It’s particularly important      our sustainable growth plan,
documents are only held             in Taiwan returned all            installed a new fire exit and    that our procurement teams       our CSR Watch reporting
if the workers specifically         passports to its workers.         updated their evacuation         are able to spot warning         tool (see page 7) and
request and consent to this                                           plans. This was confirmed        signs of modern slavery          environmental challenges in
on a voluntary basis, for           We verified that the new          with a follow up visit.          and also understand the          the supply chain.
example for safekeeping.            procedures had been                                                potential impact of our
                                    implemented through follow                                         actions on workers in our
In the United Arab Emirates,        up audits.                                                         supply chain. For example,
we engaged with the factory                                                                            employees should avoid
management to implement a                                                                              unrealistic delivery schedules
new consent form procedure.                                                                            that could encourage
This gave workers the                                                                                  excessive overtime.
option to keep documents
themselves or to store their
passports with the factory
in a secure, fire proof facility,
which is accessible at
any time.
Kingfisher                          Modern Slavery Act                                15
                                    Transparency Statement 2018/19

future plans                        transparency                     entities covered
                                    statement                        by this statement
                                    approval

                                                                                                    We are committed
Through our Modern Slavery          This Transparency Statement      This statement covers
Working Group, we will              was approved in May 2019 by      Kingfisher plc and all its
continue to identify risks and      the Boards of Directors of       subsidiary undertakings.
implement due diligence to          Kingfisher plc, B&Q plc, B&Q     This includes the following
help tackle modern slavery.
Over the next two years, our
key priorities are to:
                                    Properties Ltd, Kingfisher
                                    Information Technology
                                    Services (UK) Limited,
                                                                     UK subsidiaries with a
                                                                     turnover of £36 million
                                                                     or above:
                                                                                                    to working with
—— Roll out ethical audits to all
   our high-risk production sites
                                    Kingfisher International
                                    Products Limited and
                                    Screwfix Direct Limited.
                                                                     —— B&Q plc                     our suppliers and
                                                                                                    partners to play our
   of finished goods;                                                —— B&Q Properties Ltd
                                    It is signed by the Kingfisher
—— Review how we monitor            Chief Executive Officer who      —— Kingfisher International
   and work with suppliers          is also a member of the Board       Products Limited
   to improve factory
   performance grades;
                                    of Directors.

                                    Véronique Laury
                                                                     —— Kingfisher Information
                                                                        Technology Services (UK)
                                                                                                    part in stamping out
—— Further develop and roll
   out our modern slavery and
   ethical sourcing training
                                    Chief Executive Officer
                                    10 June 2019
                                                                        Limited

                                                                     —— Screwfix Direct Limited
                                                                                                    modern slavery.
   programmes, including
   incorporating modern
   slavery into our Code of
   Conduct training;

—— Continue to develop
   our modern slavery due
   diligence programme for
   our goods and services
   not for resale (GNFR) –
   using the findings from our
   first audits;

—— Onboard our key GNFR                                              See our Sustainability
   suppliers onto the EcoVadis                                       Report (kingfisher.com/
   assessment platform.                                              SustainabilityReporting)
                                                                     for further details of our
                                                                     progress, including our
                                                                     report on progress against
                                                                     the principles of the United
                                                                     Nations Global Compact.
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