Modern Slavery Statement - Walmart

Modern Slavery Statement - Walmart
       Modern Slavery

       02 Introduction
       03 Our policies
       04 Risk assessment
       05 Due diligence in our supply chains
       07 Due diligence in our own operations
       09 Training and awareness
       11   Progress indicators for 2018/19

                                                © Asda Stores Ltd 2018
Introduction                             This statement has been published in accordance
                                         with the Modern Slavery Act 2015. It sets out the
                                         steps taken in relation to part 6, section 54, by
                                         Asda Stores Limited and where appropriate, other
                                         relevant group companies to prevent modern
                                         slavery and human trafficking in our business and
                                         supply chains. It relates to our financial year ended
                                         31st December 2017.
Roger Burnley
President and CEO
                                       Asda welcomes the transparency required under the Modern Slavery Act
                                       2015. Modern slavery is a social, economic and political challenge which
                                       requires collaboration from governments, society and both the public and
                                       private sectors to successfully address. We work closely with our suppliers
                                       and service providers from Europe, America, Africa and Asia and are part
                                       of the global Walmart group committed to tackling this issue.

                                       This statement covers the activities of Asda Stores Ltd, McLagan
                                       Investments Limited, The Burwood House Group Limited, Power4All
                                       Limited, International Procurement & Logistics Limited (IPL), Forza Foods
                                       Limited, Kober Limited, and Asda Home Shopping Cards Limited (“Asda”),
                                       all of which fall within the scope of section 54(2) of the Modern Slavery
                                       Act 2015.

         About the Asda Group

         Asda employs 150,000 colleagues across           Asda’s supply chain ranges from products
         its UK stores, distribution centres, home        sourced via its own integrated subsidiary
         shopping centres and home offices. We serve      businesses in George and IPL to working in
         over 18 million customers each week in stores    partnership with direct and indirect suppliers
         and online, with products ranging from fresh     producing goods and services in factories
         food to general merchandise and clothing.        and offices around the world.

Asda Modern Slavery Statement 2018                                                                               02
Our policies                             Asda has implemented corporate policies and
                                         procedures that are designed to support the
                                         highest standards in ethical and responsible
                                         business practices, as part of our mission to be
                                         the most trusted retailer.

All of Asda’s suppliers are required   Asda has distinct policies for           Asda has updated its own colleague
to meet the high Responsible           suppliers of Goods and Services          policies to specifically address
Sourcing Standards expected            Not for Resale (GNFR). In 2018,          questions regarding non-retention
across Walmart. These standards        we introduced a specific Modern          of identity documents, and so
cover our fundamental expectations     Slavery Policy for these suppliers, in   helping to ensure its practices
regarding—amongst other things—        order for them to be fully aware of      and operations support freedom
the treatment and safety of workers.   our expectations of their conduct.       of movement. We strictly prohibit
In June 2017, the Standards were       This policy was issued to all GNFR       the confiscation of identity
revised and reissued to strengthen     suppliers and published on our           documents and only allow
the language around forced labour,     externally facing supplier website.      managers to temporarily request
human trafficking and responsible                                               such documents to create and store
recruitment.                           Asda has policies on Recruitment         copies, ensuring their prompt return
                                       and Agency Workers. Recruitment          before candidates leave assessment
Asda has implemented policies          of agency workers is carried out         centres/interview or a colleague
and procedures that are designed       through one managed services             leaves their shift. The updated
to support the highest standards       provider - working with a panel of       policy was published in April 2018.
in ethical and responsible supply      agencies which has its own Modern
chain practices. All suppliers of      Slavery Policy and statement and         In early 2018 we published a
own label Goods for Resale (GFR),      with which we have worked closely        colleague facing Modern Slavery
upon starting work with Asda, are      over the past year. Asda also has        Policy for Asda, outlining our
required to ensure compliance with     a formal Right to Work Policy            commitment to implementing
Walmart’s Responsible Sourcing         that outlines our procedures to          systems and controls aimed at
Disclosure Policy. This means that     ensure all potential colleagues have     ensuring modern slavery is not
within the scope of the policy,        permission to work in the UK and         taking place anywhere in our
facilities should be made available    do the work we are offering.             operations.
for an audit.

Asda Modern Slavery Statement 2018                                                                                03
Risk assessment                          Asda works closely with Walmart and regularly
                                         assesses the risk of modern slavery in its business
                                         and operations. It has regard to the Worldwide
                                         Governance Indicators from the World Bank in
                                         order to rate our supplier locations on their level of
                                         risk and apply this to our risk based audit process.
                                         These indicators consider political stability and
                                         absence of violence, government effectiveness, the
                                         rule of law and control of corruption.

                                     As a UK business we actively engage and consult with internal and
                                     external stakeholders such as the British Retail Consortium, the Ethical
                                     Trading Initiative (ETI) and the Gangmasters and Labour Abuse Authority
                                     (GLAA) in order to continually review risks in this area. Areas of highest
                                     risk identified for Asda, our subsidiary companies and supply chain are in:

                                     •   Temporary and/or unskilled labour;
                                     •   Farming and food manufacturing labour, particularly seasonal;
                                     •    Clothing manufacture labour in the UK and overseas;
                                     •    Construction labour (third parties engaged by Asda);
                                     •    Catering sector – particularly temporary labour;
                                     •    Facilities management (third parties engaged by Asda) and;
                                     •    Car washes (tenants of Asda).

                                     As a result, our priority activity to prevent modern slavery focuses on
                                     these areas.

Asda Modern Slavery Statement 2018                                                                                 04
Due diligence                         Global collaboration

in our supply                         Many of the greatest risks to human rights are
                                      complex, systemic and industry-wide issues that
chains                                cannot be solely addressed through supply chain
                                      monitoring and remediation.

The risks of forced labour,          In 2017, Walmart became a            Asda and Walmart believe that
human trafficking and modern         Supporting Member of the             the men and women who work
slavery are beyond the ability       Responsible Business Alliance        in the global supply chain should
of a single organisation to          (RBA), an industry association       not pay for a job. In 2017, Walmart
solve, but by working with           comprising more than 110             joined the Leadership Group
industry stakeholders, non-profit    electronics, retail, auto and toy    for Responsible Recruitment
organisations, governments and       companies with combined annual       as a member of the Steering
others, we are striving to improve   revenue greater than $4.75           Committee. Over the next two
transparency, empower workers        trillion. RBA offers its members     years, Walmart will join fellow
and create positive change           an auditing programme,               Leadership Group members
throughout supply chains. Asda       resources, training, and several     to help create demand for and
works closely with Walmart           working groups focused on            availability of ethically-sourced
and supports the promotion of        priority areas in the electronics    workers in Thailand and Malaysia,
responsible recruitment, helping     industry, including responsible      as well as to advocate for better
form coalitions to confront these    recruitment, environmental           government regulation of
challenges in the global supply      sustainability, and forced and       recruitment agencies.
chain.                               trafficked labour.

Walmart and Asda are taking          Walmart is a member of and sits
steps around the world to address    on the Board of the Consumer
human trafficking and forced         Goods Forum (CGF), which
labour, particularly focusing        brings together more than 400
on seafood supply chains in          retailers, manufacturers and
Southeast Asia and especially        service providers in the consumer
Thailand. Walmart participates       goods industry to create positive
in the Seafood Task Force, an        change across the retail industry.
initiative established by a group    In 2016, CGF aligned around
of seafood processors, feed          three priority principles: Every
producers, buyers, retailers,        worker should have freedom of
government representatives           movement; no worker should pay
and NGOs to address issues           for a job, and no worker should
surrounding labour conditions        be indebted or coerced to work.
and illegal fishing in Thai
seafood supply chains. The
group’s board of directors
includes a representative from
Walmart’s Responsible Sourcing

Asda Modern Slavery Statement 2018                                                                              05
Due diligence                          To complement our robust supplier set up process
                                       we use detailed social, safety, technical and
in our supply                          environmental compliance audits to evaluate facility
chains                                 practices on an ongoing basis.

The audits are conducted under        Our clothing brand has a              Our integrated supply chain
the auspices of internationally-      supply chain of approximately         IPL has focused on end-to-end
recognised third-party social-        600 primary sites (where              transparency of suppliers beyond
compliance programmes and             full production takes place)          its first tier for some time, and
focus on a variety of areas,          and a further 238 second-tier         in fresh produce it has achieved
including worker compensation         sites where processes such as         transparency to farm level. In
for all hours worked; voluntary       washing, printing and embroidery      order to further enhance this,
labour practices; facility            take place. Like other Walmart        a new traceability system has
observance of working age laws        companies, disclosure of first tier   been introduced: a software and
and standards; non-excessive          sites is required, however, Asda      data platform that allows for
working hours consistent with         is working towards full second-       complete farm-to-fork supply
local laws and regulations,           tier supply chain mapping to help     chain transparency and will be
and facility health and safety        further strengthen responsible        incorporated as a risk assessment
standards.                            sourcing practices across our         tool.
                                      clothing and apparel supply
Asda is also a sponsor of             chain.                                In higher-risk fresh produce
Stronger Together - an alliance                                             sourcing regions, our team is
working to reduce modern              In addition to this, Asda’s leading   working in collaboration to
slavery and human trafficking         clothing business George has          mitigate the potential risk of
by developing and providing           taken steps to list all primary       modern slavery in the supply
guidance, tools and training          production facilities in its          chain. An example of this is in
for suppliers. Asda contributes       ‘sourced by George’ website           Morocco, where we are working
to a UK Stronger Together             providing further transparency.       with supplier farms to develop
working group of retailers that       The responsible sourcing team         toolkits to provide awareness
collaborates on initiatives to        actively engage in the Ethical        and education for workers, to
address forced labour in UK retail    Trade Initiative working groups       improve worker management
supply chains. Asda colleagues        for Leicester, India, Turkey and      communication systems and
also actively engage in the British   Bangladesh.                           provide training for managers to
Retail Consortium Ethical Trading                                           deal with any identified issues.
Working Group and contribute to
Retailer and industry forums.

Asda Modern Slavery Statement 2018                                                                             06
Due diligence                          Asda uses only specified reputable licensed
                                       employment agencies to source labour via
in our own                             a single managed services provider. This
operations                             organisation has its own statement and Modern
                                       Slavery Response Plan and verifies all agency
                                       practices before workers are accepted. They
                                       also conduct regular audits, including on right
                                       to work processes.

                                     2017 saw the introduction of          Checks on payroll and banking
                                     a Modern Slavery Awareness            systems are carried out across
                                     Programme, supported by Hope for      Asda on a regular basis looking for
                                     Justice, for all panel agencies and   modern slavery indicators.
                                     delivered by our managed services
                                     provider. Quarterly awareness         Part of our integrated supply
                                     sessions are provided to panel        chain works with labour agencies
                                     agencies, a 10% wage slip audit is    to provide temporary labour. This
                                     carried out on all panel agencies     temporary labour carries with it
                                     and an incident register for modern   certain risks and, as such, agency
                                     slavery indicators is now in place.   providers are regularly audited and
                                     Further work is planned in the        GLAA accreditation is checked by
                                     coming year to include an agency      the business.
                                     toolkit focused on preventing
                                     modern slavery; a Modern Slavery
                                     Checklist for all new agencies
                                     before starting work with Asda and
                                     ongoing panel agency reviews.

Asda Modern Slavery Statement 2018                                                                               07
Due diligence                          Service suppliers

in our own                             All suppliers brought into the business to provide
                                       goods and services not for resale (GNFR) sign up, as
operations                             part of our terms and conditions, to adhere to our
                                       policy on modern slavery.

                                     Over the past twelve months,             In order to minimise the inherent
                                     we have chosen to prioritise             risks of hand car washes we have
                                     our resource and concentrate             made the decision to streamline
                                     specifically on our largest suppliers,   and reduce the number of providers
                                     seeking to ensure that where             across our existing estate. This
                                     appropriate they have their own          will include the refurbishment of
                                     Modern Slavery Statements and            the existing estate with the aim
                                     are working in the bounds of our         to complete by the end of 2018.
                                     most up to date contractual terms.       The tenants will be required to
                                     A newly drafted Modern Slavery           have their own Modern Slavery
                                     Policy for these suppliers helps         Statement and provide clear
                                     to ensure that the specifics of our      evidence how their systems and
                                     requirements are clear.                  processes seek to prevent right to
                                                                              work and modern slavery breaches
                                                                              in their aims to be industry leading.
                                                                              Our contracts are intended to
                                                                              ensure these requirements are
                                                                              legally binding on the tenant and
                                                                              that they conduct their business in
                                                                              an appropriate manner.

Asda Modern Slavery Statement 2018                                                                               08
Training and                           Colleague training

awareness                              Over the past year we have concentrated our
                                       training programme on those colleagues who are
                                       most likely to encounter modern slavery indicators.

                                     Activity in this area has included       In the clothing supply chain, we’ve
                                     briefing Senior People Managers          given ‘Buying Ethically’ training, run
                                     (HR), People Business Partners           in conjunction with ETI, for relevant
                                     (HR), Store Managers and Colleague       buyers. New colleagues to the
                                     Representatives as part of raising       business have attended awareness
                                     modern slavery awareness. We have        sessions, run throughout the year.
                                     also delivered training to all ‘new to
                                     role’ Managers and Section Leaders       Within our wholly-owned supply
                                     in retail and this training will be      chain we’ve developed a poster
                                     delivered to all new managers in         campaign, a screen saver and media
                                     future.                                  screen campaign in eight languages,
                                                                              to raise awareness across all of the
                                     Through updating our induction           UK sites. Additionally, at the start of
                                     training across the business, we’ve      2018, key HR colleagues attended
                                     ensured new managers in logistics        Stronger Together workshops on
                                     and Home Offices are briefed on          modern slavery and colleague
                                     modern slavery. This training is         representatives completed Stronger
                                     also being rolled out to colleagues      Together e-learning.
                                     across our retail stores. To help spot
                                     any signs of slavery, we run a face
                                     to face awareness session for our
                                     Regional Compliance Managers.
                                     These managers are often the first
                                     point of contact for our sites for
                                     any Compliance related matters
                                     and pro-actively visit stores, depots
                                     and a number of third party run

Asda Modern Slavery Statement 2018                                                                                 09
Training and                             Supply chain training and awareness

awareness                                In 2017, Walmart launched the Responsible Sourcing
                                         Academy Training Portal, which is accessible
                                         through Walmart’s corporate website. The portal
                                         provides suppliers and their facilities with tools
                                         and training opportunities designed to influence
                                         continuous and sustainable improvement.

                                      Asda continues to sponsor the           All relevant colleagues will be
                                      Stronger Together initiative, an        required to undergo the training in
                                      alliance working to reduce the          the first half of 2018. Another role-
                                      risks of forced labour and human        specific training module is being
                                      trafficking by developing and           developed for any colleagues who
                                      providing guidance, tools and           are required to recruit as part of
                                      training for suppliers. In 2017         their role and will be rolled out from
                                      Walmart worked in collaboration         May 2018.
                                      with Stronger Together to create a
                                      new e-learning module, (“Tackling       At the start of 2018 we further
                                      Forced Labour in Global Supply          reinforced our expectations around
                                      Chains”) to help suppliers and          modern slavery to the top 25
                                      colleagues understand the nature        suppliers in our integrated supply
                                      of forced labour in supply chains       chain and will continue to engage
                                      and to identify possible indicators     with them on this topic. A supplier
                                      and risk factors. The online training   conference is held at the start of
                                      is available free of charge for all     every year for these suppliers and a
                                      suppliers via the Responsible           specific presentation was given on
                                      Sourcing Training Portal.               forced labour and modern slavery
                                                                              at the start of 2018.

        Monitoring and reporting

        Asda expects all of its colleagues, suppliers, contractors, consultants and other service providers
        to act in a manner consistent with Walmart’s Statement of Ethics. We expect that any suspicions
        or concerns related to modern slavery are reported immediately to our anonymous ethics helpline,
        24 hours a day, 365 days a year.

                      0800 318 405      

Asda Modern Slavery Statement 2018                                                                                 10
Progress                               Over the next twelve months, Asda and its
                                       subsidiary companies will continue to work with
indicators for                         suppliers and partners to embed programmes
2018/19                                designed to prevent and tackle modern slavery.
                                       Specifically, we will:

                                     •A   ssess sourcing risk down to primary production in key fresh produce
                                          supply chains
                                     •C   omplete 2nd tier supplier mapping in selected supply chains
                                     •  Introduce a toolkit for our recruitment agencies focused on tackling
                                          modern slavery
                                     •  Review the training provided to agency colleagues and all hiring managers
                                     •E   nsure all relevant colleagues complete the e-learning module ‘Tackling
                                          Forced Labour in a Global Supply Chain’
                                     • Continue to review all service suppliers in relation to modern slavery
                                          including specifically construction, facilities and catering suppliers

Asda Modern Slavery Statement 2018                                                                              11
ASDA House
Great Wilson Street
Leeds, LS11 5AD

VAT registration: GB 362 0127 92
Company Registration: 464777       © Asda Stores Ltd 2018
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