WO R K I N G I N PA RT N E R S H I P F O R A H A P P I E R WO R L D

Human Rights Report &Modern Slavery Statement
2021/22

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OUR BUSINESSPOLICY

5,979

workers from 55 sites across the
UK and China participated in our
Better Jobs programme in 2021.

172

Worker Livelihood Projects weredelivered by Waitrose & Partners
Foundation in ten countries,
benefitting more than 75,000
workers and their communities.

2

Partners upskilled to provide
expert, on-the-groundmonitoring for workers in our
artisan supply chains in India.

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1,396

37

workers at a
Waitrose Foodand Grocery
supplier insouthern
Italy are now
supported by theestablishment of agrievance process.

8,545

Partners trained inspotting the signsof modern slavery.

Our 2021/22
highlights£2.2m
generated in Fairtrade
Premium through the saleof Fairtrade products. Thiswas paid to farmers on topof the Minimum Price toinvest in their businesses andcommunities.

£2.4m
was generated for the
Waitrose & Partners
Foundation to invest in
improving livelihoods,
empowering workers
and building stronger
supply chains.

20,000workers benefitted from
representatives of 44 ownbrand supplier sites attending
Stronger Together’s ‘Tackling
Modern Slavery in UK
Businesses’ course.

2

1,461
livestock farmers

ETHICS &S U S TA I N A B I L I T Y
WO M E N I N A N D A RO U N D
J O H N L E W I S PA RT N E R S H I P
S U P P LY C H A I N S

2022

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The latest update wasreleased, further aligning therequirements for Goods For
Resale (GFR) suppliers acrossboth our brands.

734

completed ourlivestock selfassessment
questionnaire, giving
us visibility of working
conditions on thesefarms.

SDGS

ETHICAL
CO M P L I A N C E
POLICY

non-conformances closed,
each demonstrating an
improvement to working
conditions in factories that
supply our Partnership.

SMETA audits werecarried out at our sites,
supporting our ambition
to demonstrate thatbasic working conditions
are in line with the
Responsible Sourcing
Code of Practice(RSCOP).

S TAT E M E N T

Our second ‘Womenin Supply Chains’
report was published,detailing thechallenges of women
working in global
supply chains andwhat we are doing toaddress the issues.

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Reflections from
our Chairman
The John Lewis Partnership
was founded in 1929 byJohn Spedan Lewis as anexperiment to find a betterway of doing business – onewith social purpose and adesire to do good at its heart.
Nearly a century later our
new Purpose – Working inPartnership for a happier world– is the modern incarnationof this historic vision.

T

he increasingly complex andchallenging world in which we livemeans that not only do we have towork together to maintain a successful
and sustainable business, we mustalso strive to create a happier world –including for our Partners, customers,
suppliers and the communities in which
we operate.
This report highlights the steps
we’ve taken this year to help protect
the human rights of people in thePartnership’s own operations andsupply chains. It reflects not only our
successes but also the challenges wecontinue to face as we work to help
create a fairer, happier and moresustainable future for generations tocome. In many ways, this report isa reminder of the scale of that task.
Although we’ve achieved a lot, there is
still much work to do.

The impact of the pandemic continues
to be felt by many people – withthe poorest and most vulnerable
across the world being most affected.
Global supply chains continue tobe significantly disrupted, including
shortages in raw materials and rising
freight costs, a situation made worseby the tragic war in Ukraine. Thisdisruption has directly affected thenumber of employment opportunities
and types of work available. Elsewhere,
traditional international migrant worker
routes have been displaced, leading
to staff shortages. More than ever,the past year has reminded us how
improving conditions for workers andtackling exploitation requires a firm andlong-term commitment.
We have continued to develop our
Better Jobs programme that westarted with John Lewis suppliers in
the UK in 2019. Aimed at improving
working conditions and job satisfaction
for workers in our supply chains, theprogramme gathers direct feedback
from workers at our supplier’s sites

and supports our suppliers to act on
the feedback. This year, the programme
has expanded to include a number ofFood and Grocery and Goods Not
For Resale suppliers. Nearly 6,000
workers across 55 sites have completed
the survey. We’re working with our
suppliers to develop action plansthat address areas for improvement,
supporting them with tools and events
over the next 12 months.
We must always have in our minds theindividuals and communities – in the
UK and globally –- that are behind theamazing products and services we sellor use in the Partnership. People whowork directly or indirectly with us havea right to safe employment, free of fearand exploitation – and it is our duty tohelp make that happen.

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I would like to thank all our Partners,
customers, NGOs, businesses andworkers from across the globe whohave contributed to our efforts. I lookforward to seeing how our work
together improves the lives of those
who work directly or indirectly for thePartnership.

SHARON WHITE
Partner & Chairman

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Our business

Contents
			O U R P RO G R A M M E

Page

1 Our business4

2 Policy

6

3 Governance74	Our human rights
programme

85	Risk assessments anddue diligence9

6 Salient human rights risks

20

7 Addressing risk

21

8 Training

32

9 Effectiveness35

10 Looking forward

38

11 Modern Slavery Statement41

12	Sustainable Development
Goals (SDGs)

42

13 Collaboration

43

T

36

4

1

1

2

22

2

1

11

42

70

2,000

8

1

1

5

Waitrose shops in the UK andChannel Islands

Partnership Heritage Centre

customer delivery hubs2

distribution centres3

Over 2,000 Goods For Resale
Tier 14 own-brand supplierfactories

Waitrose farm, the Leckford
EstateJohn Lewis shops in the UK1

John Lewis shop-in-shop,
Gibraltar

countries and territories
stock Waitrose products

Waitrose cookery schools

content production hub

own-brand product sourced
from over 70 countries

customer contact centres

5

soft furnishings factory,
Herbert Parkinson

Partnership hotels forPartners to use

You can find out more about our business in our 2022 Annual Report and Accounts.

SDGS

CO L L A B O R AT I O N

I am proud of the achievements we have made over thelast year but recognise that the need to protect the rightsof those working within our own operations and the supply
chains providing goods and services to the Partnership has
never been greater. The past few years have seen criticalshocks to our global supply chains which have had huge
impacts on people. Covid-19 was a very direct humanitariancrisis. We are already seeing the impacts of climate change
being felt by workers within our supply chain and, looking
forward, we are aware that issues like water scarcity will
become increasingly prevalent in some of our key sourcing
regions. Rights to water and safe, healthy environments are
becoming increasingly complex to uphold.

head offices, one in London
and one in Bracknell

sourcing office locations inIndia and Hong Kong

S TAT E M E N T

Reflections from our Directorof Ethics & Sustainability

he John Lewis Partnership is the UK’s largest employee-owned businessand parent company of our two cherished retail brands, John Lewis andWaitrose, which are owned in trust for over 78,000 employees (who arePartners in our business). We have 361 John Lewis shops including one outlet
and 331 Waitrose shops across the UK, along with johnlewis.com and waitrose.
com. We also have two international sourcing offices, a soft furnishings factory,
various distribution centres, 4 Waitrose cookery schools, a content production
hub, a heritage centre and our own Waitrose farm.

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1. Figure includes John Lewis
Canary Wharf and John Lewis
Swindon Outlet.
2. Figure includes three customer
fulfilment centres, one of which
is run by a third party.
3. 6 of the 11 distribution centres
are run by a third party.
4. A tier is defined as a stage
in the supply chain carryingout a particular activity in the
production of a product. For
example, Tier 1 is defined
as sites manufacturing or
assembling a finished product.
5. Five of the contact centres arerun by a third party.

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We have committed to set science-based climate targets andare currently developing a decarbonisation pathway for ouroperations and supply chain. We remain committed to being
net zero in our operations by 2035. Whilst this is criticalto halt the impacts of climate change, we face some toughdecisions and recognise that there will likely be unintended
consequences for those we are also trying to protect. As
we make these decisions we are committed to ensuring that
we deliver a just transition and take a human rights-based
approach to our climate change mitigations. Enabling workers
in our supply chain to realise their fundamental human rights
remains a core ambition, and we look forward to continuing
our work to ensure this is a reality.

M A R I J A RO M PA N I
Partner & Director, Sustainability & Ethics

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Our Purpose
Working in Partnershipfor a happier world

Our Partnership is theUK’s largest employeeowned business withover 78,000 Partners
who are all employeeowners. Our Founder,
John Spedan Lewis,
established it as a betterway of doing businessand to drive positivechange in society.

O

ur Constitution protects the values
that underpin our business, enshrining
our governance into a single written
document that can only be changed with theconsent of both the Partnership Council andthe Chairman. While our Constitution has
evolved since it was first published almosta century ago, it continues to embody the
essence of the extraordinary vision and idealsof our Founder.
The Principles and Rules set out in our
Constitution define our Partnership’s role insociety and our responsibilities to Partners,
customers, suppliers and the communities inwhich we operate. It also states that we are
required to make ‘sufficient’ not ‘maximum’
profit, and that’s why we are focused onreinvesting our profits back into our Partners
and to pursue our Purpose.
In 2021, to ensure our Purpose is fit for
the future of our Partnership, we invited
discussion, input and feedback from Partners
across the business on what our refreshedPurpose should be. Our new Purpose –‘Working in Partnership for a happier world’– makes it clear why we exist, our ultimate
aim as a business, and gives us an exciting
opportunity to do things differently.

Happier people

Happier businessHappier world

Our happier business starts
with happier Partners, enjoying
worthwhile and satisfying workin a supportive environment weall help to create.

We build happier businesses
that are honest, fair andfree to think and act for thelong term. We aim to makesufficient profit to retain our
financial independence, invest
in our Partners and pursue our
Purpose.

We champion the role
our Partnership can play inadvancing the happiness ofthe communities we workwith and the wellbeing ofsociety.

We treat people with fairness,courtesy and respect, and wework with others who do thesame.
We create an inclusive
environment and celebrate
diversity with our Partners,
customers and the communities
we serve. We’re at our bestwhen we all feel welcomed andfree to be ourselves.
We take pride in making
our customers happy. We
put everything we have into
everything we do, earning theloyalty and trust that we need
to be successful.

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Our Partnership is built on
democratic principles. We
share the responsibilities
and rewards of ownership:knowledge, power and profit.
Partner opinion is crucial indriving the actions of ourgoverning authorities: thePartnership Council, thePartnership Board and the
Chairman.

We build trusted business
relationships, acting withintegrity and doing what’s
right.
We take responsibility forour impact on the planet.
We work tirelessly to protect
and restore nature, creating
a more sustainable future forgenerations to come.

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OUR BUSINESSPOLICYG OV E R N A N C EJohn Lewis PartnershipResponsible Sourcing
Code of Practice
Labour Standards

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Responsible Sourcing
Code of PracticeT

he RSCOP is approved and signedby the Chairman and is applicable toall suppliers of goods and services to ourPartnership, in all sourcing countries andat all tiers of our supply chain.

The John Lewis PartnershipResponsible Sourcing Codeof Practice (RSCOP) sets out
our commitment to workers’
rights and our expectations of
our suppliers regarding issues
such as pay, working hours andchild labour. It is based on the
Ethical Trading Initiative (ETI)
Base Code and the relevant
Conventions of the International
Labour Organization (ILO).

SALIENT RISKS

Suppliers trading with our Partnershipare expected to comply with the RSCOP
and, in so doing, must also comply withall other relevant national and applicablelaws. Where there is a difference
between the protection offered by thelaw and that offered by the RSCOP,
the higher standard should always beapplied. If suppliers are unable to comply
with a provision of our Code, they must
explain to us how their own policies,
processes and standards address thefundamental principles of that particularprovision. They must also show us how
their standards have been developed incollaboration with their workforce.

As outlined in this report, the RSCOP
is the first stage in a continuous
improvement journey. We consult
with internal and external stakeholders
including government bodies and NGOs
on strengthening our approach, including
policy development, to improving thehuman rights of workers in supply chainssupplying the Partnership.
To demonstrate compliance to the
RSCOP, risk assessments and due
diligence are undertaken in our supply
chains. The initial focus is on high risk
supply chains and those where we canhave a direct impact. These assessments
seek to make sure the required standards
within our supply chains are upheld andalso highlight where improvements can be
made. Recognising the limitations of risk
assessments and ethical audits, however,our Human Rights Team monitors theinternational economic, environmental
and political landscape to also ensure wecan anticipate any new risks that mightarise and develop action plans to addressthese in our own supply chains.

We recognise our direct impact on
the human rights of workers in ourown operations and supply chains;
however, we are also aware that wehave a broader impact through ourwider business activities. Whilst implicitly
required of our suppliers, we had notpreviously published a policy which clearlylaid out our expectations to upholdthe broader human rights of thosetouched by these activities, for example,
smallholder farmers and those living in thesurrounding communities. This includes
recognition of our indirect influence on
the right to free and informed consent
and access to water (as highlighted in our
2020/21 report).

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As a result, we consulted with relevant
stakeholders, including NGO partners, toformalise our requirements in a Human
Rights Policy. This policy has a reachand relevance that is broader than the
RSCOP and has been designed to set
out our commitment to respecting thehuman rights of those within our own
operations, the supply chains (Goods For
Resale and Goods Not For Resale) andthe charities we work with. It includes
requirements for maintaining safe
workplace conditions, offering secure andeffective grievance processes, treating
workers with equity and inclusivity,
protecting indigenous communities,
ensuring clean water and sanitation andmaintaining a healthy environment.

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GovernanceStrong governance over how we manage andmitigate the risk to human rights – including
modern slavery – in supply chains providing
goods and services to our Partnership is criticalto ensuring we are meeting and exceeding
our responsibilities as a business, and therequirements of the Modern Slavery Act 2015.

G

overnance of human rights in ourPartnership forms part of our wider
ethics and sustainability governance. In
recognition of the importance of our
responsibilities to Partners, to those withwhom we build strong relationships– including suppliers, customers andcommunities – and to the environment,
the Board agreed in July 2021 to the reestablishment of the Ethics & Sustainability
Committee (ESC) as a Board Committee.
Prior to this, the ESC was a subgroup of
our Executive Team.

The Committee currently comprises the
Chairman, one Non-Executive Director
and four Executive Directors who areresponsible for John Lewis, Waitrose,
Strategy & Commercial Development,
and Finance. The terms of reference forthis Committee state that its purpose
is to “assist the Board in fulfilling its
responsibilities for setting the Ethics &Sustainability (E&S) strategy in accordancewith our Partnership’s Purpose andValues and ensuring that this strategy isembedded into [our] operations”.
Nina Bhatia, Executive Director ofStrategy & Commercial Development,
has accountability for human rights andresponsible sourcing performance acrossour Partnership.

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Human Rights governance
2021/22
Our Ethics & Sustainability Committee

SHARON WHITE
Chairman of thePartnership Board

RITA CLIFTON
Deputy Chairman of thePartnership Board andNon-Executive Director

BÉRANGÈRE MICHEL
Partnership Board member
and Executive Director,
Finance

JAMES BAILEY
Executive Director,
Waitrose

NINA BHATIA
Executive Director, Strategy &Commercial Development

PIPPA WICKS
Executive Director, JohnLewis

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Following the re-establishment of
the ESC as a Board Committee,
we have put in place a programmeof regular reporting to the ESC
at its quarterly meetings, toensure there is greater oversightof progress to fulfil our E&S
strategy, including human rights.
An ethical compliance update
is provided each quarter, with
the Committee holding toaccount those responsible fordelivery in operational teams.
Ethical compliance performanceis also monitored via our risk
management framework (forfurther information on thisframework, please refer to pages
31-39 of our Annual Report andAccounts 2022).
Alongside existing business activity,
our Partnership’s Human Rights
team identifies, and requests
funding for, additional project work
to support progress against our
E&S targets. In 2021/22, humanrights-related projects that we
initiated included a human rights
impact assessment in our tea
supply chains, GNFR gap analysis,
and plans to extend our Better
Jobs scheme to South Africa andIndia in 2022.

We also invested in new systems
and processes. Through ourprogramme of factory audits of
our Tier 1 sites we know that
there is room for improvementin our management of factorycompliance. To address this wehave introduced new systems
and processes during the past
12 months, including enhanced
reporting and better capability for
escalation and order blocking. This
work is ongoing and in 2022 weare committed to implementing
and embedding further
improvements, including training,system-based controls and internalreporting.
We also continue to invest in
programmes that will increasetransparency and traceability
beyond Tier 1 and across our
extensive supply base, while
actively identifying the best
partners and initiatives to address
the salient risks we’ve identified.

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Our Human Rights Programme
Our Human Rights
Programme – made up
of a number of strandsof activity – forms partof the wider ‘People
in Supply Chains’ area
within our Ethics &Sustainability Strategy.

The ambition of the programme isto enable everyone in our supply
chain to realise their fundamental
human rights. We believe thatchampioning worker voice and building
supply chain relationships creates lastingvalue for both our Partnership andthose with whom we work.
Our risk assessment and due diligenceprogramme ensures that suppliers
adhere to the RSCOP, whilst ourcapacity building programmes aim
to improve the understanding andapplication of our policies.

Our leadership programmes, including
Better Jobs and the Waitrose & Partners
Foundation, alongside our capacity
building programmes, go further
than compliance. These programmes
require greater investment of time andresources at an individual site level andengage multiple stakeholders (suppliers,
managers and workers) with the aim ofaddressing systemic human rights issues
in a holistic manner. These stakeholders
have valuable insight into issues at a local
level within the context of the broader
economic and political landscape.

We are also increasing our levels of
engagement with trade unions andthis year we have been consulting with
the International Transport Workers
Federation (ITF) on specific issues
relating to transport and fisheries.

Ensuring basic working
conditions are being met inline with RSCOP

Addressing broader
human rights risks throughcollaboration

Ensure all workers have thevoice and capacity to drive
improvements to their livelihoods

Pages 9-19

Pages 21-27

Pages 28-31

Capacity and capability
building in key supply
chainsMonitoring and due
diligence of suppliers
against our standards

Partner training inbusiness practices
influencing human rights

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Industry initiatives
and collaborations

Transparency andreporting against targets

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Ensuring basic working
conditions are in line with
our Responsible Sourcing
Code of Practice (RSCOP)
At a minimum we require conditions for
those working within supply chains supplying
our Partnership to comply with the RSCOP.
We verify compliance through tailored risk
assessments based on several factors: thelevel of associated supply chain risk – including
country of origin, industry and product type
– and the level of influence and impact we areable to have on a particular supply chain.

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Self-assessment
questionnaires
At the most basic level, a self-assessment
allows us to gather some of the mostvital information and provides us with agood baseline for understanding working
conditions on a site. This information
includes worker numbers anddemographics, primary site activity anddetails on labour policies and processes
already in place. Collecting this data
enables us to make informed decisions
about the level of further due diligencerequired, such as an ethical audit, indepth assessment or a spot check audit
to verify that the information provided
in the self-assessment questionnaire iscorrect.

“A self-assessment allows
us to gather some of themost vital informationand provides us witha good baseline forunderstanding working
conditions on a site”

SDGS

CO L L A B O R AT I O N

In 2021, 1,461 farms completed theself-assessment and we identified 843
high risk areas. The areas identified did
not necessarily mean that there wasa non-compliance to the RSCOP, but
provided an indicator as to whether
further investigation was needed to
identify the root cause of the risk, or
if farmers required further support tomake improvements.

Fresh produce packhouses
We plan to broaden our EthicalCompliance Programme to include incountry fresh produce packhouses. Thisis an important step in our complianceprogramme as we recognise that the
fresh produce sector remains an area
where there is a higher risk of humanrights violations. To begin to understandthe challenges at a packhouse level,a number of our fresh produce sites
have completed a self-assessment
questionnaire over the last year. Throughthis self-assessment, we can identify
where positive actions are taking place,or where there are risk areas that weneed to look into in further detail. To
date, 130 sites across 30 countries havecompleted the questionnaire, and fromthat we have identified 96 risk areas toinvestigate further. These risk areas do
not necessarily reflect a failure to comply
with the RSCOP, but highlight where it isimportant for us to look at root causes.
The risk areas identified largely relate
to payment of fees by workers and useof agency labour. We will be working
with our suppliers to investigate andverify risk mitigations, and to ensure that
information and support is provided to
growers where this is needed.

S TAT E M E N T

C A SE STUDY

Self-assessments inlivestock supply chainsAs set out in our 2020/21 Human
Rights Report, in early 2021 weundertook our biennial worker welfare
self-assessment within our livestock
supply chains. Thanks to this selfassessment we can identify areas where
improvements have been made, support
continuous improvement and highlightrisk areas that may require further
investigation.

For the 2021 assessment we updated
the questionnaire to better align withthe leading worker welfare ambitions
under our Waitrose Agriculture
Plan, and to place more emphasis oncompliance with the RSCOP. It alsoenables us to use the same questions forour global supply chains, such as fresh
produce. The updated questionnaireraises the bar on worker welfare
standards for our livestock farmers.

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The findings and trends were
presented to our supplier-led
Waitrose Farming Partnership
Livestock Steering Group. Suppliermembers have since continued towork directly with their farmers toverify risk mitigations and to ensurethat further information and support
has been provided to farmers where
this was needed. We have closed 820
of the high risk areas identified and aredeveloping the working group’s action
plan, which focuses on the following
key areas:
1. Attracting workers/labour to ensuresustainability of the sector.
2. Retaining workers by being fair
employers.
3. Training farmers and workers on
issues such as health and safety,
discrimination and basic right-towork checks.
4. Farmer wellbeing and ongoingsupport.

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OUR BUSINESSPOLICYThe Partnership’s
Ethical Compliance
PolicyAll Tier 1 sites supplying finished ownbrand or branded exclusive Food andGrocery and General Merchandise
products to our Partnership fall within
the remit of our Ethical Compliance
Programme, along with high risk ownbrand Tier 2 food sites. Historically, we
had separate Ethical Compliance policies
for Food and Grocery and General
Merchandise.
In 2021, we published our Partnership’s
Ethical Compliance Policy that furtheraligned requirements across all Goods
For Resale (GFR) and introducedchanges to our GFR Ethical Compliance
Programme. Key changes to the policy
include:• Removal of audit exemption for General
Merchandise sites with a low turnover.
• Risk assessments for both brands todetermine the frequency of audits.
• Alignment across both brands on our
audit grading process.
• A robust derogation process for sites
exempt from the requirement toundergo a SMETA audit.
We retain specific requirements where
it is currently not feasible to fully alignrequirements across Food and Grocery
and General Merchandise.

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Risk assessment
Firstly, we undertake risk assessments
for each site. For Food and Grocery
sites, this includes completion of a selfassessment questionnaire (SAQ) on the
Sedex platform. For General Merchandisesites we use a risk calculator that wedeveloped with our factory compliancePartners. The calculator takes into accountsite location, industry and products being
manufactured, previous audit grading andability to close non-conformances, todetermine whether a site is low, medium
or high risk. For Food and Grocery sites,
only those classified as high or medium
risk require a SMETA audit, every two
years and every three years respectively.
For General Merchandise, high, medium
and low risk sites require an audit every
one, two and three years respectively.

Ethical audits
Ethical audits are undertaken using
an industry-wide and internationallyrecognised audit methodology, SMETA(Sedex Members Ethical Trade Audit).
At a minimum we require a two-pillar
SMETA audit that covers the nine key
requirements of our RSCOP. We require
all social compliance audits to be carriedout by an Association of Professional Social
Compliance Auditors (APSCA) certified
auditor. APSCA is the professional standards
body which certifies auditors’ competence
and oversees the ethics and integrity ofmembers, both audit firms and auditors.

A SMETA audit is designed to assessa site’s compliance with the ETI BaseCode, which the RSCOP mirrors.
The Base Code was founded on theConventions of the International Labour
Organization (ILO) and notes nineclauses that reflect the most relevantlabour practice conventions of the
ILO. It is viewed as a global reference
standard and is widely used as abenchmark for minimum standards.
During the audit the auditor will note
any good practice examples, plus
observations and any non-conformances
against the ETI Base Code/RSCOP. All
non-conformances are given a criticality
score of either minor, major, critical or
business critical. Once complete, theaudit is given a green, amber or red
rating that determines whether the site
is compliant with our Ethical Compliance
Policy. Sites with a red-rated audit
are non-compliant to our Policy andconsidered in breach of the RSCOP.
All sites, no matter the audit grading,must take corrective actions to resolve
non-conformances within the timeframe
specified on the audit. These actions areverified either online or in-person by
the auditor to formally ‘close’ the nonconformances identified in the initial audit.

“

Ethical audits are undertakenusing an industry wide andinternationally recognised audit
methodology, SMETA”

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Sites in scope of
the Partnership’s
Ethical Compliance
Programme
Below we have detailed the numberof sites that fell within the scope of
our Ethical Compliance Programmein 2021/22, the number of audits thatwere carried out, and the number of
non-conformances that were opened
and closed during the same period.
Sites supplying our Partnership are
categorised as food, grocery, fashion or
home.

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Number of audit non-conformances opened and closed*
in 2021/227
1,949

During 2021/22, a greater number of
non-conformances were opened versus
2020/21 due to the high number ofaudits that took place after a backlog
from pandemic restrictions. We areworking with sites and suppliers toensure non-conformances are resolved
effectively and are prevented in the
future.

Goods for Resale sites in scope6 of the Partnership’s
Ethical Compliance Policy
Number of sites

SALIENT RISKS

Number of audits undertaken
in 2021/22

738

649
351

162
Opened*Closed*85

OpenedFood

ClosedOpenedGrocery424

238
ClosedOpenedFashion

ClosedHome

Number of audit non-conformances opened and closed in 2021/22 by ETI Base
Code Clause
ETI Base Code clause

Food

Grocery

Fashion

Home

Opened*Closed*OpenedClosedOpenedClosedOpenedClosedEmployment is freely chosen

38

9

7

1

0

0

0

0

Food

942

375

13

6

1

2

1

3

1

80

35

Freedom of association andcollective bargaining

13

Grocery
Fashion344

97

Health, safety and hygiene

844

312

87

60

190

193

419

351

Home

804

227

Children and young workers

34

11

4

0

1

0

1

1

Wages

225

59

17

8

58

10

101

8

281

76

17

2

57

6

120

4

Regular employment

418

76

15

5

22

15

52

33

Discrimination

16

7

2

0

0

0

0

0

No harsh/ inhumane treatment– discipline/ grievance

51

12

4

1

0

0

8

5

Other9

29

74

3

7

21

13

34

21

Working hours
6. Number of sites in scope at 2021/22 financial year end dated
29 January 2022.
7. Only audits of sites in scope of our Ethical Compliance Policy– all Tier 1 sites assembling or supplying finished own-brandor branded exclusive Food and General Merchandise products
to the Partnership, and high risk own brand Tier 2 food sites –are included in these figures.
8. Includes all non-conformances categorised as regular
employment, management systems, entitlement to work,business ethics.
9. Includes all non-conformances categorised as environmental
or other.

8*Opened: This refers to the number of non-conformances opened on audits carried out in the financial year ended 29 January 2022.
Closed: This refers to the number of open non-conformances closed out during the financial year ended 29 January 2022.

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Exploration oftier 2 in generalmerchandise
supply chains
Having refreshed our EthicalCompliance Policy we identified theneed for due diligence to be carriedout below Tier 1 across General
Merchandise supply chains. In some
supply chains, Tier 1 sites assemble a
product before it is boxed and shipped
to a retailer, therefore providing
us with little or no visibility of thesite where the main component is
produced. We are developing our due
diligence programme for sites below
Tier 1 and this year have undertaken
a pilot. In collaboration with one ofour main lighting suppliers, we haveidentified the Tier 2 sites where key
components in John Lewis branded
lights provided by this supplier are
made. During 2022/23, Partners in ourHong Kong sourcing team will begin to
conduct on-site assessments at these
Tier 2 sites. We will directly address
any issues that are uncovered during
these site visits and the learnings fromundertaking these assessments will
be used to develop the due diligenceprogramme for sites below Tier 1.

S TAT E M E N T

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Gap analysis –GNFRSpot checks
To test the effectiveness of the due
diligence within our Ethical Compliance
Programme, we conduct spot checks
using audit (namely SMETA two-pillar
audits) or tailored methodologies atrelevant sites and farms in our global
supply chains.

We reserve the right (stipulated in ourPartnership policy) to commission andconduct an audit at sites and farms in
any tier as part of our spot checks.

Spot checks are commissioned andpaid for by our Partnership and may be
driven by specific concerns, or as partof a random selection process to ensure
the effectiveness of our due diligenceprogramme.

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In 2020, we reviewed our Partnership’s
use of agency labour and carried out a
gap analysis of our GNFR procurement
policies, processes and procedures,
including four ‘deep dive’ ethicalassessments, to understand whether
the requirements of the RSCOP werebeing upheld by our third-party labour
providers. A number of risk areas wereidentified and, as a result, in 2021,
we began working with Slave-Free
Alliance (SFA) to look in more detailat what could be done to support
improvements in our operations supply
chains. The first step was for SFA tocarry out a detailed assessment at
our largest distribution centre, Magna
Park, over the peak period at theend of 2021. The assessment review
identified positive steps being taken
by our Operations team to ensure
responsible recruitment of labour, but it
also identified some improvements to
be made in the relationships between
management and staff which would
create a more inclusive environment
rather than an ‘us and them’ mentality.
Recommendations for how to improve
communication about grievancemechanisms and key employment
conditions such as benefits and career
progression opportunities are currently
being worked through with the supportof SFA.

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SDGSCO L L A B O R AT I O NIndustry-led audit
programmes
Our Partnership actively
participates in a number ofinternational programmes thatcollectively seek to improve humanrights through industry-wide
action. These include:

International Labour
Organisation’s Better
Work ProgrammeInternational Accord
John Lewis has been a signatory of the
Bangladesh Accord since its inception in2013 to improve factory building safety
in Bangladesh. Following negotiationsof the renewed Accord agreement
last year, we continue to support
the programme, now known as theInternational Accord. At the end of
FY 2021/22 we had 18 active apparelfactories in Bangladesh, all of whichwere registered on the International
Accord programme and who actively
participated in their site audits andclosure of corrective action plans.
At these sites we strive to follow
the International Accord guidelines,
instigating escalation procedures if
remediation isn’t effective within thegiven timescale.

In 2021, we had one whistleblowing
incident brought to our attention,
via the Accord, from the Bangladesh
Independent Garment Workers Union
Federation (BIGUF). It was alleged 11
union workers were unfairly dismissed,
their pay withheld and that union
members were also being subjected toverbal abuse and physical violence. On
behalf of the Partnership, the BIGUF
and other brands sourcing from thesame factory, the Accord facilitatedconversations with the factory andunion to resolve the issue.

The Better Work programme is apartnership between the United
Nations’ International Labour
Organization (ILO) and the International
Finance Corporation (IFC), a memberof the World Bank Group, and it was
created to improve working conditions
and respect labour rights for workers
in garment and footwear supply chains.
Working with the ILO and the WorldBank Group, Better Work supports
garment-producing countries tostrengthen the policies and industry
practices needed to ensure decent workand flourishing businesses, and to drive
improvements on a much larger scale.
The Better Work programme approachcombines advisory services, assessments
and training. It’s aimed at delivering
clear and continuous improvements infactories by working with governments,
employers, trade unions, workers andinternational buyers to ensure betterworking conditions that can boost
ethical compliance and profitability. The
model empowers factory workers,
their representatives, supervisors andmanagers to improve the working
conditions in their facilities.

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At the end of FY 2021/22 we had eightapparel and footwear factories, acrossBangladesh (three factories), Cambodia(two factories), Indonesia (one factory)
and Vietnam (two factories) actively
participating in the Better Workprogramme. As part of our EthicalCompliance Policy, these factories,
with a total of over 15,000 workers,
are exempt from providing a SMETA
audit. However, Better Work conducts
unannounced site visits, provides sites
with a dedicated advisor, industry
seminars and training for workers andmanagement. The factory programmechanges attitudes as well as behaviours,
policies and practices.

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Certification andthird party sourcing
programmes
Beyond Tier 1 and Tier 2, supply
chains become increasingly
complex and as such it is often
challenging for our Partnership,
acting independently, toundertake robust due diligenceand to drive improvements.
Certification, although not thesolution to de-risking supply
chains, can be a useful toolin supporting industry wide
improvements and ultimately
improving opportunities forworkers globally.

Responsible Fishing Vessel
Standard (RFVS)

Fairtrade
Waitrose has supported the Fairtrade
Foundation since its launch in 1994 andin 2020 we achieved our ambition of
offering the widest range of certified
own-label Fairtrade products of any
UK supermarket. We’re committed
to sourcing 100% Fairtrade across
key own-brand categories including
coffee, black teas, bananas, sugar,
block chocolate and the cocoa used inour confectionery. We recognise therole that the Fairtrade system plays
in monitoring and helping to drive
improvements in workers’ rights in someof the most challenging supply chains.

Launched in 2020, the RFVS enables
fishing operations to ensure decent
working conditions and operational
best practices in line with internationallyagreed protocols and guidelines. The
standard includes requirements relating tocrew rights, wellbeing, training and safety.
Fishing vessel owners and operators areaudited by a third party to demonstrate
they comply with this industry bestpractice standard. Our ambition is toachieve adoption of the RFVS by all UK
vessels supplying Waitrose. In Scotland,
vessels supplying Waitrose have started
to adopt the RFVS; however, there areuptake challenges elsewhere, largely
due to already strong sales demandand stakeholders not wishing to incur
additional costs without a guaranteed
price premium in the sales market.
Working with the Global Seafood Alliance(GSA), which owns and operates thescheme, and Flatfish, our main supplierof UK wild-caught fish, we’ve heldroadshows at UK ports encouraging
more vessel operators to sign up to the
RFVS. As the challenge continues, wewill work collaboratively with the GSA,
fishers, suppliers and other relevantorganisations to overcome the hurdles toadoption.

Better Cotton
Our Partnership has committed that
100% of the cotton used in own-brandproducts will be from more sustainable
or recycled sources by 2025.
We’ve been a member of Better
Cotton since 2013 and continue toengage with the non-profit, multistakeholder group on its mission to
help cotton communities survive andthrive whilst protecting and restoring theenvironment. This includes supporting
Better Cotton to continue to build
robust requirements regarding decent
work into the principles and criteriaof its framework. In January 2022,
our Senior Manager, Human Rights
Programmes, joined the Better CottonStandards Committee that has been
established to provide technical andstrategic oversight of the revision of
the framework. The result of this will
provide the Better Cotton Council witha final recommendation of approval forthe revised framework before it can beformally approved.

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Better Cotton Farmers must work to
uphold, and continue to comply withthereafter, four decent work standards:• Freedom of association and the rightto collective bargaining.
• The elimination of forced labour.
• The abolition of child labour.
• The elimination of discrimination in
employment and occupation.
The Principles & Criteria framework
includes 22 criteria for upholding thesestandards. Better Cotton Farmers arealso required to follow national labourand occupational health and safety
laws, unless those laws fall below ILO
standards.

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Roundtable on Sustainable
Palm Oil (RSPO)Our Partnership has committed tosource 100% of the palm materials
in our products from Roundtable on
Sustainable Palm Oil (RSPO) Segregatedsourced by 2025. Already, 72% issourced this way, with a further 25%
sourced via the mass-balance supply
chain model.
Palm oil is a perennial tree crop thatis heavily reliant on migrant labour for
year-round harvesting of the palm fruitbunches. Conflict over the appropriationof land for palm oil plantations fromlocal and indigenous communities
without their free prior and informed
consent is also frequent.

Ensuring human rights are upheld is a
key concern in the sector, and forms amajor part of the RSPO’s Principle &Criteria for its certification standard,
and its wider programme of work on
human rights. The standard sets out the
key requirements for certified producers
to ensure human rights are protected,
respected and remedied.

The Sustainable Fibre
Alliance (SFA)
Our Partnership is committed tosourcing 100% of our pure cashmere
used in own-brand products from
more sustainable or recycled sourcesby 2025.

Respect community and human rights
and deliver benefits (Principle 4)• Protection of human rights
defenders• Grievance, complaints andremediation procedures• Upholding of the right to free priorinformed consent
Support smallholder inclusion(Principle 5)• Support for smallholder livelihood
improvements• Fair and transparent dealing withsmallholders
Respect workers’ rights and conditions(Principle 6)• No discrimination• Decent living wage requirement• Freedom to unionise and bargain
collectively• No child labour or exploitation• No forced or trafficked labour• No harassment and protection of
reproductive rights• Safe working environment

We’ve been working with the
Sustainable Fibre Alliance (SFA) since2020. The SFA is in the process ofreviewing their cashmere standard andwill be relaunching it as the world’s
first global standard in December
2022. It will focus on five sustainability
principles: goat welfare, biodiversity
and land use, fibre quality, decent
work, and effective management.

“

Certification can be a useful
tool in supporting industry wide
improvements and ultimately
improve opportunities forworkers globally”

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In-depth
supply chain
assessments

S TAT E M E N T

SDGSCO L L A B O R AT I O N“Our research
identified migrant
workers paying
recruitment fees,
excessive overtime,
non-payment ofovertime wages”

Where we have identified a specificconcern, or know that a supply
chain poses a particularly high riskfor human rights abuses, we carryout ‘deep dive’ assessments. Thesemay look at any tier in the supply
chain, focusing in more detail on
policies, processes and views ofworkers.
C A SE STUDY

Understanding working conditions for
migrant workers in the UK fishing sectorT

he fishing industry has been linked
to horrific human rights abuses
globally. The UK wild-caught sector ischaracterised by lack of visibility, andthere are inherent vulnerabilities forworkers, specifically migrant crews. In
order to develop an understanding of
key issues facing migrant crews, wecommissioned Impactt, the ethicaltrade consultancy, to analyse what
processes were in place for workers tovoice grievances by undertaking deskbased research, stakeholder interviews
and semi-structured interviews withrandomly selected non-European
Economic Area (EEA) fishers working
on transit visas.
In June 2021, two major Scottish ports
were chosen for the semi-structured
interviews based on the increased
likelihood of finding fishers who met

this criteria. Forty migrant fishers,
six skippers and two recruitment
agents were selected at random to
be interviewed. It was not identified
whether those interviewed had
any connection to our Partnership.
A workshop was then conductedwith key industry stakeholders tofeed back the initial findings and toestablish structured and impactfulrecommendations.

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The research identified some positive
findings but there were someconcerning discoveries, including thepayment of recruitment fees, which was
flagged by 13% of those interviewed. It
was also reported that key challenges
workers faced included not being
prepared for the psychological andphysical hardship of working on theharsh sea off the coast of the UK,
and 38% of those interviewed had
either personally sustained injuries or
witnessed others injured on UK vessels.
More than 75% had worked on average
up to 20 hours per day continually
across three to four weeks without
proper rest and none of the workers
received any payment for the overtime
hours worked.
We’re now working collaboratively
with the industry – including withbodies such as the Seafood Ethics
Action (SEA) Alliance – to develop
the recommendations from the study
into meaningful action and we hope toshare an update in future reports.

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Verisio ‘Deep
Dive’ audits
With a focus on conducting a greaternumber of impact assessments, we
trialled ‘Deep Dive’ audits, developed
by Verisio, with three UK mattress
suppliers. We chose to focus
the audits in the UK because it’scommonly misconceived as a low risk
country, but in fact carries high risk
due to it being a key destination forvictims of trafficking.
The Verisio ‘Deep Dive’ audit
methodology combines a desktop
assessment of company documents,
such as policies, and a two-stage,
on-site unannounced audit consistingof an initial audit and a follow up at
roughly six months at which all nonconformances will be reviewed. Bycompleting the desktop assessment
beforehand, auditors are able todedicate more time to the on-site
visits.
Key findings included gaps inpolicies and procedures suchas those involving child labour,grievances, disciplinary processes andwhistleblowing.

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Where additional team support wasneeded, Hypnos worked quickly torecruit and train staff, showing complete
commitment to ensuring its workforce
had the required help. Furthermore,team leaders on the production floor
received training to enhance their
management skills and strengthen
relationships with their colleagues andoverall the business is now feeling thebenefits.

C A SE STUDY‘Deep Dive’audit – Hypnos

H

ypnos, a key own-brand andbranded mattress supplier,volunteered two bed-making sites forthe ‘Deep Dive’ trial. Findings fromthe initial audit identified areas where
immediate improvements could be
made.
Following the challenges and pressuresof the recent pandemic, with staff
shortages in the office and on the
production floor, the audit revealed
that the management team at Hypnos
could strengthen its connection with
its workforce and create greater
engagement. The audit closing meetingwith the Hypnos leadership team led
to some honest conversations andimportant recommendations, all ofwhich were taken on board. Hypnos
was keen to improve and strengthen
the business by using the audit findings
to drive culture change and enhance
workforce wellbeing.

S TAT E M E N T

Over the next six months, theleadership team improved its processes
by updating existing policies to ensure
all necessary points were covered,and introduced new policies where
needed. The team also introduced
robust procedures to ensure all
workers, current and new, had thesame positive experience, which
improved employee relationships.

“We take all feedback
on board and use it to
implement any changes thatmight enable us to becomea stronger and more
employee-engaged business”
JAMES KEEN

James Keen, Chief Executive Officer ofHypnos, commented: “We volunteered
to undertake one of the very first ‘Deep
Dive’ audits with our collaborative
partner, John Lewis. As a transparent,
forward-thinking company, Hypnos
views audits such as these as hugely
valuable ways to enhance our working
practices. We take all feedback on board
and use it to implement any changes
that might enable us to become astronger and more employee-engaged
business. The difference this robust audit
and subsequent learnings have made to
our business has been extremely positive
and allowed our teams to work together
as a more bonded unit with evengreater motivation. The ‘Deep Dive’audit helped our business make strategic
adjustments which have been a great
success. Thank you to the John Lewis
team for allowing Hypnos to be one of
the first participants in this innovative
audit programme.”

Chief Executive Officer of Hypnos

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EFFECTIVENESS• Duty Bearers (e.g. those downstream
in the supply chain, such as ourPartnership, who have the mostleverage and impact)• Rights Holders (focusing on
workers and marginalised groups
in the communities who are mostvulnerable and have the least ability
to raise concerns and have theirconcerns adequately addressed)• Relevant parties (eg local NGOs,
trade unions and other industry
initiatives that support rights holders
in the supply chains being assessed)

S TAT E M E N T

SDGSCO L L A B O R AT I O N

Impact assessments
in our Waitrose &Partners Foundation
supply chains

Human
Rights Impact
Assessments(HRIAs)Our Customised Human Rights
Impact Assessments (HRIAs) consider
a broader spectrum of human rights
issues and rights holders. Undertaken
by experts, HRIAs start with desktop
research focusing on corporate
policies, industry and country risks to
identify the salient issues specific to thebusiness and the supply chain of focus.
This is followed by field research that
includes interviews with:LO O K I N G F O RWA R D

Kenya tea HRIA
As we publicly committed last year, ourPartnership has undertaken a HRIA
within our Kenyan tea supply chains,
working with our supplier and anotherretailer with whom we share the same
Fairtrade-certified supply chains. The
assessment, run by Partner Africa,
will look in particular at the challenges
faced by smallholder farmers in Kenya.
Field research took place at the endof 2021, with a validation workshop
held in early 2022. We plan to work
alongside key stakeholders in the Kenyan
tea sector to develop actions that willaddress the assessment’s forthcoming
recommendations.

Pork and lamb HRIA

Ghana is a significant source of preparedown-brand fruit for Waitrose, and is a
key country for the Waitrose & Partners
Foundation, which is in its 12th year ofoperation there. We are working with
the University of Northampton, oursupplier, and the Dutch retailer Albert
Heijn on a piece of research to look at
the impact of our activity, both positive
and negative, over this time. We hopeto understand how the Foundation’s
activities and interventions haveresulted in changes to local livelihoods
and to identify how we can make
improvements going forward.

In 2021, we commissioned Impactt
to run a HRIA in our pork and lamb
supply chains in collaboration with our
supplier and another retailer. Impactt’s
HRIA methodology is informed by
the Danish Institute for Human Rights’framework and is designed to identify
negative human rights impacts ofpurchasing practices and business
relationships. Research was conducted
between October 2021 and early 2022
across the supply chains, from farms
to abattoirs and processing sites. We
will be reviewing the findings with our
supplier to identify areas where we canhelp to drive improvements.

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UnitedKingdom
Global
1
3

3

5

6

1

1

2

4

Italy

6

China
1

1

1
1

1

1

2

Bangladesh
India
5

In 2021/22 our Partnership updated theissues identified as the most salient humanrights risks within supply chains, using datato assess the severity and likelihood of themoccurring. These risks have taken priority for
programme development and selection for
the reporting year.

VietnamGhana
Coted’Ivoire

5

1

4

T

1

4
Peru

2

South Africa

2

Salient human rights riskso ensure we’re constantly
improving our ability toidentify salient human rights risks, in
September 2022, our Human Rights
team participated in training with the
Ethical Trading Initiative (ETI). This
training focused on how to identify
actual and potential human rights
risks and covered topics including
recognising labour rights as humanrights, understanding human rights
due diligence frameworks andimplementing mitigation and remedy.

1

Risk

Supply chain

1. Employment is freely chosen
SDG 8.7

Fresh produce and fish
Fashion and home
Warehousing

2. Freedom of association and supporting
effective worker voice mechanisms
SDG 8.8

Fresh produce

3. Health, safety and wellbeing
SDG 3 and 8.8

All

4. Child labour
SSDG 1.1, 1.5 and 8

Fresh produce andcocoa

5. Low wages and sustainable incomesSDG 1.1, 1.5 and 8

Fresh produce
Fashion and home

6. Gender and discrimination
SDG 5, 8.5, 8.8

All

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General Merchandise
Food and Grocery
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Addressing broader
human rights
risks throughcollaboration
We focus our capacity building, leadershipprogrammes and activities on theidentified salient human rights risks, asthese are the areas where we believe we
can have the most impact and influence.

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Employment isfreely chosen
When conducting ethical audits andself-assessment questionnaires in supply
chains supplying our Partnership, theInternational Labour Organization’s(ILO) indicators of forced labour –including withholding wages, debt
bondage, abusive living and poor
working conditions – are used tohighlight risk areas in our supply chains.
Forced labour and human trafficking
are both forms of modern slavery, aparticularly complex crime. Migrant
workers are often especially vulnerable
to these forms of exploitation and withan increasingly challenging labour market
and refugee crisis in Europe, the risk offorced labour is high.
In the UK, a combination of factors
including leaving the EU, and the
pandemic has meant that many migrant
workers have returned to their homecountries. Recruitment in the fresh foodlabour market is at a major disadvantage
due to physically demanding work,seasonal demand and fluctuation
in work available. Our Partnership
continues to engage with the UK
Government to share insights into
these challenges, and to identify ways
to support the food and farming sector.
We’re also working in collaboration withothers in the industry to tackle theseissues.

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EFFECTIVENESSLO O K I N G F O RWA R DModern Slavery Intelligence
Network (MSIN)ETI Italy agriculture
working group

In 2020/21, we reported that Waitrose
had joined a pilot scheme for a newModern Slavery Intelligence Network.
Created in response to Operation
Fort, the UK’s largest-ever modern
slavery investigation, MSIN’s mission is
to disrupt and prevent modern slavery
and labour exploitation. In 2022, the UKsees the launch of this network, which
is a non-profit collaboration of retailers
and suppliers from the UK food andagriculture sectors.

Waitrose is a member of a tripartite
working group helping to address salient
human rights issues affecting the Italian
agriculture sector. Key issues identifiedin studies10 over the last ten years relate
to the use of illegal contracts (black andgrey work), the use of illegal recruitment
practices, poor working conditions andcases of forced labour11.

“

Forced labour andhuman trafficking areboth forms of modern
slavery, a particularlycomplex crime”

Release on Temporary
Licence (ROTL)
Given the challenges regarding
recruitment of labour, a number ofsuppliers have been considering options
to diversify the workforce. Recruiting
offenders has been explored as a way
in which to provide opportunities of
employment and work experience forthose nearing the end of their prison
sentence. To better understand theopportunity and associated risks, since
September 2021 we have been working
with one of our suppliers, Huntapac,
along with the consultancy NGaje
and other retailers, to understand
Huntapac’s experiences of recruiting
offenders through the ROTL scheme.
Working collaboratively, we havedeveloped a guidance document forother suppliers considering using thislabour pool. The case study has beenshared at the Food Network for Ethical
Trade (FNET) and ETI webinars and has
been made available to our suppliers.

The ETI-led group, involving local
stakeholders, suppliers and retailers,
aims to address these issues by using
the collective leverage of members
to support farms and cooperatives tostrengthen due diligence processes,
better worker engagement and advocate
for improvements in wider labour
practices. In 2021, the group focusedon developing resources for capacity
building. This included designing farmrisk assessment criteria and an ethicaldue diligence checklist for suppliers, aswell as running a presentation for local
cooperatives to help raise awarenessof the role they can take in promoting
legal practices amongst their member
growers.

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In January 2022, the working group alsobegan collaborating with local NGOs topromote their existing local multilingual
help desk that provides workers withinformation on local support services.
Between June and December 2021, thehelp desk received 993 enquiries and as
a result 437 listening and information
advice services were provided toworkers to help resolve their question
or concern. 40% of the users wereagricultural workers; however, we cannot
verify whether these workers were
working in Food and Grocery supply
chains supplying our Partnership.

10. Oxfam, 2021, The Workers Behind Sweden’s Italian
Wine: An illustrative Human Rights Impact Assessment of
Systembolaget’s Italian wine supply chains, 01.06.22, https://policy-practice.oxfam.org/resources/the-workers-behindswedens-italian-wine-an-illustrative-human-rights-impactass-621266/
11. Oxfam, 2018, Human Suffering in Italy’s Agricultural Value
Chain, 01.06.22, https://policy-practice.oxfam.org/resources/
human-suffering-in-italys-agricultural-value-chain-620479/

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Uyghur autonomous region
and cotton sourcing

S TAT E M E N T

SDGSCO L L A B O R AT I O N‘Three-on-the-spot’ Vietnam

For many years pressure has
been increasing from a variety of
stakeholders, including NGOs,
governments, consumers and the
media, for businesses to have greater
oversight of raw materials supply chains.
More recently, this pressure has focused
predominantly on reports of Uyghur
Muslims being detained in ‘re-education’camps in Xinjiang and forced to work ina number of industries, including cotton
supply chains.
Our Partnership recognises that thetraceability of cotton is an industrywide challenge due to its long andcomplex global supply chains. We arecommitted to addressing this challenge,
both through our own actions and byworking collaboratively with others,
which is crucial to implementing theimprovements needed.
During December 2020, ourPartnership was invited to contribute to
the Foreign Affairs and Business, Energy
and Industrial Strategy Committees’
inquiries into the Xinjiang region. Our
response to the inquiry was publishedin January 2021 on the Parliament
website. Following this response, we
met with the Department for Business,
Energy & Industrial Strategy (BEIS) in
May 2021 to discuss the topic, including
how we map our supply chains andhow we conduct our due diligence.

LO O K I N G F O RWA R D

We remain vigilant to the high riskof modern slavery within the region.
However, our policy remains unchanged:
our Partnership does not source goods
or services that have been made (orprovided) using forced labour. We havenot introduced a country- or regionspecific policy and we continue tomonitor the situation.

“

We remain vigilant to the high riskof modern slavery from the Xinjiangregion. Our policy remains unchanged:
our Partnership does not source
goods or services that have been made(or provided) using forced labour”

H U M A N R I G H T S R E P O RT & M O D E R N S L AV E RY S TAT E M E N T 2 0 2 1 / 2 2During 2021, the pandemic continued
to heavily impact many of our
supply chains. In June 2021, Vietnam
experienced its fourth wave of thevirus, which severely affected the livesof its population and the capabilityof factories to maintain productionlevels. The Vietnamese authorities
introduced a very strict policy, known
locally as a ‘three-on-the-spot’, in an
attempt to curb the spread of thevirus among workers whilst allowing
factories to continue operating undersafe conditions. The policy meant thatin order for factories to remain open,
workers had to live, rest and work on
the premises and whilst there they andmanagers had to follow strict Covid-19
prevention measures including social
distancing and regular testing. This was
entirely optional for both factories
and workers, but the risk of managers
exploiting vulnerabilities was heightened.
During this period we kept in contact
with our key suppliers in the regionand offered support to those living at
the factories away from their families.
For more information, please see our
2021/22 Ethics & Sustainability Report(page 13).

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Health, safety and wellbeing
Health and safety remains a salient
human rights risk in our global supply
chains. During 2021/22, 1,540 healthand safety-related non-conformances(NCs) were reported at sites supplying
own-brand Food and Grocery andGeneral Merchandise to our Partnership.
Key health and safety risks include, but
are not limited to, fire safety, hazardous
working conditions, first aid facility andworkers’ training.

Over 40% of the 3,200 NCs openedin 2021/2022 are categorised as healthand safety. This is largely the same whenlooking at non-conformances acrossboth brands, as health and safety nonconformances can be seen to make up
44% and 56% of Food and Grocery andGeneral Merchandise non-conformances
respectively. This demonstrates thesalience of health and safety risks for
those working in factories from which
we source.

TR AINING

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C A SE STUDY

To help support our sites, our UKbased Human Rights team and sourcing
offices in Hong Kong (HKSO) and India(ISO) are able to offer guidance inunderstanding ethical compliance andclosing non-conformances. Our Partners
directly support factories offering onsite instructions for improvement and
we also offer broader training on key
safety topics. For example, in December
2021, the HKSO held a virtual supplierconference which included improving
suppliers’ understanding and awarenessof health and safety non-conformances.

Improper emergency
evacuation structure –changing the mindset

A

soft furnishings manufacturer inIndia, employing over 50 workers,
had rolling shutters installed on three
emergency exits on the production
floors, additionally these exits did notopen outwards in the direction ofevacuation. The intention was to provide
added security at the premises but
in fact the fire safety standards werecompromised. The Factory Complianceteam from our India Sourcing Office(ISO) worked with the management
in resolving the issue, demonstrating
why the rolling shutters needed to be
replaced as they were too slow andinefficient to open in an emergency. Our
team also explained how emergency
exit doors should always open outwards
to provide egress without contravening
the fire safety standards, especiallywhen a factory houses flammable raw
materials. The management understoodthe importance of fire safety standards
in adherence to the local law andremoved all of the rolling shutters andensured the exits opened outwards inthe direction of evacuation.

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A spokesperson for the factorycommented: “Working with yourPartnership compliance team has reallyhelped us to understand the reasons
as to why they asked us to remove therolling shutters and also to keep the
emergency exit doors open outwards.
These changes were needed to ensure
the safety and wellbeing of our own staff
and we are pleased that the result is asafer workplace for workers and for thesmooth working of our factory.’’24

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EFFECTIVENESSChild labour

Low wages and sustainable incomes

The impact of the pandemic is likely to befelt by children for some time. Lockdowns
and school closures during 2020-2021 limited
children’s access to education, and reports
by UNICEF and the International Labour
Organization (ILO) have suggested that childlabour has increased in recent years12.

Low wages in handwovenrugs supply chains

Whilst we were not aware of and were notalerted to cases of child labour being found in
our supply chains during the year, we know
there are areas where the risk of it occuring ishigh; for example, in agriculture, where children
often support their parents in the familybusiness. Our expectations regarding childlabour are outlined in the RSCOP.

Since 2019, we’ve been developing ourapproach to improving traceability anddue diligence in our artisan hand wovenrugs supply chain, with a particularemphasis on the lower tiers. Workers inthe subcontracted parts of this supply
chain usually work on an informal basis,
without written employment contracts
in place.

We are working on a project thatwill improve the transparency of theworkers’ conditions of employment,
which should be at least in line with legal
minimum wages. We will begin working
to implement this monitoring process in
2022.

Child labour is a particularly high risk in thecocoa sector. In 2020, Waitrose moved all
cocoa in its own-brand confectionery to
Fairtrade. To achieve Fairtrade certification,
no child labour (as defined by the ILO
minimum age and the most serious formsof child labour conventions) should be
employed. Paying a Premium for Fairtrade
products enables families to earn a sustainableliving and in doing so, it is hoped that they
become less reliant on their children for
additional income. More broadly, we support
the commitment the Fairtrade Foundation ismaking to fight the root causes of child labour
and to prevent exploitation and child abuse.
Waitrose is also a founding member of the
Retailer Cocoa Collaboration (RCC).
12. UNICEF/ILO, 2021, Child Labour: Global estimates 2020, trends
and the road forward, 01.06.2022, https://data.unicef.org/resources/
child-labour-2020-global-estimates-trends-and-the-road-forward/

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Living wages in banana
supply chains
Low wages are a systemic challenge
for workers in the banana industry.
Our commitment to purchasing only
Fairtrade-certified bananas means thatboth smallholder farmers and workers
on plantations receive the Fairtrade
Minimum Price, which ensures they canmeet the cost of production, as well as
receiving Fairtrade Premiums to invest
in improvements to their environmentand community. In July 2021, the new
Fairtrade Base Wage in bananas wasintroduced for hired labour, which is
helping to improve wages for workers
in the sector and move towards a living
wage. However, we recognise that
this will take time and over the lastyear we’ve started to work with IDH
Sustainable Trade Initiative, making useof IDH’s Salary Matrix, to understandthe gap between current wages anda living wage in our supply chain. Our
shared ambition is to bring together UK
retailers to collaboratively drive sector
improvements to wages.
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C A SE STUDYWorking hours and wages

W
Fairtrade Premium
Waitrose sources 100% of its ownbrand tea, coffee, bananas, sugar andcocoa in confectionery on Fairtradeterms. Through our Fairtrade sourcing
we generated more than £2.2m in
Fairtrade Premium in 2021 – theadditional sum of money paid on
top of the purchase price. The
Fairtrade Premium provides a valuable
opportunity for our producer groups toinvest in their business and community
and improve their economic livelihood.
Across our Fairtrade supply chains,some Premium spend includes investingin fertilisers which support farm
productivity, pest-resilient seedlings,
financial services, housing improvements
and education services including school
resources and scholarships. Our
coffee supply chain alone generated
approximately £530,000 in Fairtrade
Premium, of which around 31% wasinvested in productivity projects, and
13% in living income projects.

hen audited, a factory in China
supplying our Partnership had anumber of visible non-conformances in
Health and Safety, but there were also
more hidden issues such as the auditor
being unable to verify the working
hours between production records
and time records. This could have been
an indicator that working hours were
excessive and it also meant that it was
not possible to verify that the correct
wages were being paid. Subsequently
the factory was transparent in letting us
know that there were overtime issues.
Our team at the Hong Kong Sourcing
Office (HKSO) suggested the factory
engage with a consultancy service tounderstand the root causes of theovertime hours, and to develop a plan
to address all of the issues systematically.
This independent advisor visited thefactory approximately once a month(six visits in total) between April andNovember 2021 to give advice andcheck the progress on the open issues.
After this intervention, the factory has
started to implement new ways ofworking to resolve the critical issues assoon as possible.

“

Thank you for your support. The consultant has been very
helpful regarding the production situation of our company tomake a reasonable plan and rectification plan. The consultant
gave us a reasonable deadline to make improvements andanswer our questions based on the problems on site anddocuments. Let us no longer be confused”
FACTORY MANAGER

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SDGSCO L L A B O R AT I O NGender anddiscrimination
We have continued to develop
our focus on gender and women’s
empowerment over the last year,
recognising that there is still much to
be done. In 2022, our Partnershipformally endorsed the UN Women’s
Empowerment Principles (WEPs). The
Principles form a holistic framework
for businesses to demonstrate theiraction in empowering women in theworkplace, marketplace and community.
We are proud to have become
signatories and are committed tocreating gender-inclusive supply chains inpartnership with our suppliers.

“We are proud to havebecome signitoriesof the UN Women’s
Empowerment Principles
and are committed
to creating genderinclusive supply chainsin partnership with our
suppliers”

In our Fairtrade supply chains, we
continue to support programmes that go
beyond certification in helping to address
gender issues. For example, in Colombia
we are working on a cross-supply chain
programme which includes 36 women,
supporting them to improve the qualityof the coffee crop and enable greater
market access. These women have also
been trained in preventing contaminationof organic products, traceability andquality control.
In Malawi, following reports in March
2021 of gender-based abuse on the
Lujeri Tea Estate, we stood by our direct
supplier to ensure that improvements at
the estate were made. This has included
establishing clear grievance processes anda training programme for workers, whichis underway, on recognising and tackling
discrimination.
For more detail on the work we aredoing to address the most significant
challenges for women within supply
chains supplying our Partnership, we
published our ‘Women in and aroundJohn Lewis Partnership Supply Chains2022’ report for International Women’sDay 2022. This report provides an updatefrom the previous report; it details what
we are currently doing to help support
improvement in opportunities and setsout where we have plans to do more.
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Ensuring all workers
have the voice andcapacity to drive
improvements totheir livelihoods
Freedom of association andsupporting effective worker
voice mechanisms
The freedom to join a trade union ofyour choice is one of the basic humanrights as defined by the Universal
Declaration of Human Rights. Tradeunions play an important role indemocracy and support their members
to negotiate with their employers. We
recognise that not every worker insupply chains supplying products andservices to our Partnership wants tojoin a trade union, and in some cases
union representation is not in place. Our
Partnership encourages and supports
effective processes to give workers avoice and worker committees.
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Grievance mechanism to improve
worker voice – southern ItalyIn 2021, our Partnership worked with
Oxfam Business Advisory Service todevelop a pilot to address the lack ofeffective grievance mechanisms for supply
chain workers in the Italian tomato
industry. We worked with a site in theregion to analyse its existing grievancepolicies, design improved procedures andpolicies alongside workers, and create anexit strategy to ensure new processes
were sustainable without external
support.

The project closely aligns with the ETI
working group’s objective of establishinggrievance mechanisms (page 22);
therefore, in order to boost mutual
learning we have shared our findings
with ETI members. Design of a second
phase is currently underway and is due
to take place in 2022.

“

As a result of this project, the site
has implemented new grievance andresolution policies, and improved thequality and quantity of grievance-raising
methods for workers. They have also
introduced a grievance committee tosupport implementing new processes,
and created a grievance support role
into which workers can be elected. The
worker in this role can be contacted byother workers to provide support whenraising a grievance or navigating theprocess.

We’re seeing a morecollaborative dialogue…
We already can see during
the trial period the amazing
wish of the workers inparticipating in the projectand in the updating of thepolicy, and the incredible
number of ideas andinformation rising fromthem”
ANGELA(Account Executive)

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Engaging with unions
In the run-up to Christmas, themedia widely reported the challenges
regarding sea freight and the build-up
of cargo at ports, in part as a resultof changing border requirements
following Brexit and ongoing global
supply chain challenges. To ensure thatthese challenges did not impact on ourability to meet Christmas demand, we
chartered additional space on cargoships. We recognised the risk thisincrease may bring for workers (forexample, increased working hours)
and as such began discussions with
the International Transport Workers’
Federation (ITF) on how best to ensure
the wellbeing of workers on vessels
used by our Partnership. This resulted
in the inclusion of worker welfare
requirements as part of our tendering
process for our sea-freight services.

S TAT E M E N T

SDGSCO L L A B O R AT I O NIssara Institute(Project Assara)

Peru social dialogue
programme
As reported in our 2020/21 Human
Rights Report, the ETI initiated a social
dialogue programme in Peru. The
programme was due to launch at an
event in 2020; however, this was paused
following political unrest in the country.
Instead, the ‘Fruits of Peruvian Dialogue’
programme was inaugurated in 2021
through a virtual webinar.
The purpose of the programmeis to develop dialogue among thebuyers, growers, exporters andother stakeholders in the Peruvian
agriculture industry to improve
working conditions, raise awarenessof health and safety issues, modeland test the implementation of living
wages for workers and promotesustainable business growth. Since its
launch, the programme has delivered
two multi-stakeholder webinars andsupported dialogue and an agreement
between agribusiness workers union(FENTAGRO) and the Associationof Agricultural Producers Guild of
Peru (AGAP). It has also supported
successful dialogue and intervention on
industrial disputes. In 2022, the ambition
is to further define the programme’s
thematic focus areas, and establish key
performance indicators.

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Issara Institute is an independent nonprofit organisation, based in South East
Asia, focused on tackling modern slavery,
human trafficking and forced labour
through data collection, technology,
partnership and innovation. At present,
our work with Issara is focused at foodfactories in Thailand that supply ownbrand products to Waitrose, monitoring
and adjusting labour conditions bypartnering with businesses to empower
workers to make themselves heard.
In August 2021, Issara released thesecond stage of its ‘Golden Dreams’smartphone application. The app
supports workers from Cambodia and
Myanmar to access safe and reliable workin Thailand by offering job seekers andworkers a way to review employers,
recruiters and service providers andshare their feedback with others. The
update provides key information andpeer-to-peer sharing on employment
and recruitment conditions, as well as
policy and news updates, at both sourceand destination – critical information forboth job seekers and workers. Workers
are also able to give their perspective
on labour conditions, and accessinformation to help them adapt and to
avoid exploitation. This aims to reduce
exploitative recruitment, forced labourand human trafficking by empowering job
seekers and workers with informationand support, and by increasing thetransparency of recruiters and employers.
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Worker voice-led
leadership programmes

In 2021, we introduced a further theme
to the framework, Business Relationships,
enabling suppliers to consider how theirbusiness relationship with us supports
their commercial success and impacts
worker happiness. We’re proactively
looking to understand better how our
ways of working with suppliers can be
improved and we’ve welcomed thisfeedback to inform how we can act going
forward.
This year, the programme expanded toinclude Food and Grocery and GNFR
suppliers. In total, 50 suppliers completed
the programme: 29 in the UK covering
31 sites and 2,399 worker responses, and21 in China covering 24 sites and 3,580

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Better Jobs workshops to promote worker
and management dialogue in China

Better Jobs programme
Our Better Jobs programme aims to
improve worker conditions and job
satisfaction for the people who make our
products and provide our services. In
light of global challenges, it’s never been
more important to give workers in our
supply chains an opportunity to share
their views and experiences of being atwork, so that we can work collaboratively
on improvements that will have a positive
impact. The Better Jobs programme
launched in 2019, starting with UK
factories supplying own-brand General
Merchandise to our Partnership.

SALIENT RISKS

worker responses. We’re working withall suppliers to develop action plans that
address areas of improvement identified
through their participation this year, andwill be supporting them with tools andevents over the next 12 months.
Having run the Better Jobs programme
for three years, we are beginning tobetter understand where opportunities
exist for us to collaborate more closelywith our suppliers to improve aspects ofworkers’ experience of their jobs. We will
be focusing more on this collaborationin future, giving more time to address
the underlying issues that are identified.
We’re therefore making a change tothe programme and from 2022 will besurveying workers every two years, with
the intervening year focusing on building
capacity and making improvements inthe areas that each site has identified.
This will also give factories more time to
implement changes and embed initiatives
fully before workers are surveyed again,
giving us a more accurate picture ofworkers’ views on the improvements
made. We will be publishing countryspecific action plans later in 2022, which
will outline the areas of focus for the UK
and China programmes.

I

n 2021, two workshops were held in
Shanghai and Guangzhou in China across 13
factories participating in the Better Jobs China
programme. Using fun activities, the purposeof the workshops was to promote open andeffective communication between workers andfactory management.
In total, the workshops were attended by 17
managers and 23 workers. Scenarios wereused to educate both parties in how to feel
confident in establishing mutual and effective
communications, through theatrical exercises
and role plays.
Workshop participants commented:“The team game was the most impressive
session because it was quite fun and taught me
about the goal of communication. No matter
what kind of way we use to communicate, theultimate destination is to achieve our goal.”“The training was very interesting. I’ve
learnt how to improve my language when I
communicate with my manager.”
It was clear both management and workers
learnt from and enjoyed the day’s activities,
highlighting that when given the opportunity
to participate in off-site activities, it actuallyencouraged them to learn from eachother and foster a stronger relationship, an
important lesson in particular for management.

H U M A N R I G H T S R E P O RT & M O D E R N S L AV E RY S TAT E M E N T 2 0 2 1 / 2 2“The theatrical exercise was verypractical. It helped me learn about abetter way of communication with
employees. It is difficult now to recruit
workers. Better communication could
build a better worker relationship, whichis good for the growth of the company”

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Better Jobs programme
expansion
After the UK and China, India represents
our third largest sourcing country
for General Merchandise own-brandproducts. We have a sourcing office inIndia with a team of experts that works
closely with our suppliers. In 2022 wehave therefore chosen to expand our
Better Jobs programme there.
The Waitrose & Partners Foundation
is well established in South Africa, acountry where effective worker voicemechanisms are often lacking. As noted
in previous reports, we had intended tocarry out collaborative industry activity
on this issue in 2020, but this wasdelayed due to the pandemic. Instead,
we now plan to pilot the Better Jobs
initiative in South Africa in 2022, enabling
us to take some practical action toaddress these challenges. This will be thefirst time Better Jobs has been trialledin our Partnership food supply chainsthere.
We have appointed advisory grouprepresentatives in both India and South
Africa as we prepare to launch theprogramme in both locations. We lookforward to sharing the results of theworker insight gathered in the first year.

Waitrose & Partners
Foundation
Since the programme’s inception in
2005, it has generated more than
£17 million to support our workers
in Waitrose own-brand supply chainssupplying our Partnership and theircommunities. In 2021, we raised £2.4m
for the Foundation through the sale ofmore than 200 product lines, including
flowers, green beans, grapes, mango andberries, to deliver 172 projects which
supported 75,000 individuals across 424
farm partners in ten countries.
Over the past year, as part of theFoundation’s Global Strategic Fund,
we continued to deliver our Covid

Relief Programme. Since 2020 wehave invested more than £530,000,
with £200,000 invested in 2021. This
investment was used to provide PPE
to workers and local schools, hardshipfunds and yield improvement projects,
supporting more than 45,000 workers
and their communities.
We have also completed 157 Worker
Voice projects, suggested and developed
by workers to meet their local needs.
These have been across our fivecategories: Water and Sanitation, Healthand Wellbeing, Environment and Green
Energy, Access to Finance and Education.

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Projects included the provision of
microloans, construction of schoolclassrooms, gender empowerment
programmes and the refurbishment ofvocational training centres.
For more information on Waitrose& Partners Foundation activity, see
our 2021/22 Waitrose & Partners
Foundation Annual Report.

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Training
Ensuring our Partners andsuppliers have up-to-dateknowledge and awareness ofhuman rights risks is essential
in enabling us to prevent andtackle modern slavery andhuman rights abuses within
supply chains. Training playsa critical role in upskillingindividuals and teams to ensurethat our policies are upheld
and that we are vigilant in
identifying where breaches may
have occurred.

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SDGSCO L L A B O R AT I O NPartner training
Our Human Rights Specialist delivered
a two-hour training session forPartners in our General Merchandise
Quality & Technical team. The training
covered topics including our EthicalCompliance Policy, the RSCOP, detailon the SMETA audit process, including
non-conformance grading and closureand escalation of non-compliant
suppliers. Eight Partners whose roles are
directly responsible for ensuring ethicalcompliance attended. The session was
positive and supported those Partners
to improve their understanding of ethicalcompliance.

85%of our Supply Chainteam completed training
on spotting the signs ofmodern slavery

Rugs programme – capacity
building of the ISO

During 2021, the Ethical Complianceteam conducted a virtual roadshow
for the John Lewis Trade Board andsubsequently all Heads of Category,
serving as a reminder of the importanceof human rights due diligence and tohighlight our ambitions for humanrights programmes within our supply
chains. The roadshow included data
insight and introduced teams to a new
ethical compliance business intelligence
dashboard to monitor up-to-date
information on the ethical audit status
of factory sites within their categorymix. Trading teams were also given an
overview of the wider market context,
outlining why upholding human rights in
own-brand producing factories is such apriority for the industry. This roadshow
led to a strengthening of relationships
between our Human Rights teamand Trading Partners, setting our new
teams and structures up for positive
collaboration going forward.

In 2021, two Indian Sourcing Office(ISO) Partners participated in aworkshop with expert local consultancy,
ASK India, covering a review of known
risks in artisan handwoven rugs supply
chains and the process of carrying out
risk assessments and identifying noncompliances in supply chains of this type.
An additional workshop was heldin January 2022 looking at the legal
requirements for producers operating in
the rug making area around Varanasi in
India, with framework tools provided foruse on site visits.
This training is invaluable as we now
have in-house expertise to support
factories in our handwoven rugs supply
chains. This will be supplemented withvisits from ASK India consultants toprovide independent third party reviews
and additional expertise where needed.

Spotting the signs ofmodern slavery
During the peak trading period of2021, we set ourselves the target
to train 100% of our Supply Chain13
Partners to spot the signs of modern
slavery. Training was delivered througha bespoke online module with the aimof reaching Partners who would beworking alongside agency workers. In

total, more than 6,000 Supply Chain
Partners completed the training (which
represents 84% of that team) and morethan 8,500 Partners took part in total.
Our Partnership’s Human Rights teamalso distributed the helpline posters invarious languages at our warehouses anddistribution sites.

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13. Our Partnership Supply Chain team works in service ofboth Waitrose and John Lewis to ensure our customers
can access the products and services they want and need
wherever, whenever and however they choose.

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Supplier training

Stronger
TogetherModern slavery is one of themost salient risks affecting
workers around the world.
Stronger Together is a multistakeholder initiative that aims to
reduce modern slavery throughproviding guidance, training
and resources, and building
a network for stakeholders
to work together to reduce
exploitation.
During 2021, 44 UK-basedsites supplying own-brandproducts to our Partnership,
employing over 20,000 workers,
attended Stronger Together’s‘Tackling Modern Slavery in UK
Businesses’ course. Delegateswere provided with a range ofmeasures they can put in place
to prevent modern slavery fromoccuring in their own operations
and were advised on how tospot signs that workers might bevictims of exploitation or slavery.

Responsible Recruitment
Toolkit (RRT)
Stronger Together UK also
provides a Progress Reporting
Tool (PRT), a free online selfassessment tool that enables
suppliers to measure theprogress they have made in
addressing modern slavery risks
within their own operations
and supply chains. Developed inalignment with the UN Guiding
Principles on Business andHuman Rights, the frameworkprovides data analytics whichallows suppliers to track theirprogress over time, benchmark
their performance against peers
and identify improvement
opportunities. Since launch,
18 of our UK suppliers havebegun completing the progressreporting tool with an average
progress percentage of over44%.

We recognise that one of thebiggest risks to workers becoming
trapped in slavery is the requirement
to pay back recruitment fees.
The Responsible Recruitment Toolkit(RRT) is an industry leading online
tool designed to support businesses
to develop robust, ethical andprofessional recruitment practices.
In addition to online training
courses, RRT offers a full toolkit
online providing sites with step-bystep guidance on adhering to anddemonstrating compliance withinternational ethical standards.
Since February 2019, 46 of ourfood manufacturing suppliers,
representing over 16,000 workers,
have signed up to use the RRT. Using
the tool allows them to progress
through a series of modules focusedon international ethical standards
and record actions they’ve taken.

Of those 46 suppliers, 14 ofthem – employing over 6,000
workers combined – completedthe ‘Introduction to Responsible
Recruitment’ training course
in 2020 and 2021, and threecompleted the ‘Eliminating WorkerPaid Recruitment Fees’ course.
Each course teaches a fundamental
area of responsible recruitment.
For example, ‘Introduction to
Responsible Recruitment’ provides
a gateway into the topic andexplains the business case for it,
whereas ‘Eliminating Worker-Paid
Recruitment Fees’ teaches delegates
how to eliminate recruitment fees
and what they should do if theyfind out workers have paid themduring the process of securing
employment with them.
In 2021, we worked with RRT
to further promote its training
programmes to our suppliers anddevelop a strategy to increase
supplier uptake.

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Waitrose & Partners
Foundation
In 2021, the Foundationdelivered training for ten worker
committees at Foundation farms
across South Africa, East Africa
and Ghana. In South Africa,
the training covered how todevelop a successful project plan,
as well as teaching soft skills toworkers to help them develop
confidence and feel empowered
when participating on their farm.
In Kenya, the training provided
an overview of ethical tradeprinciples, as well as leadershipskills and expectations ofFoundation committees.

The Foundation also delivered
additional capacity building
training courses. In South
Africa, 25 participants
took part in Project
Coordinator training and
22 participants took partin People Management forSupervisors training. These
courses improve skills andaim to support a wide groupof workers into managerial
positions on Foundation
farms.

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Effectiveness
Effectiveness ofour due diligenceprogrammes
In the second half of 2021, we focusedon the effectiveness of our due diligenceprogrammes, in particular for own-brand
General Merchandise sites. Previously weplaced orders at supplier level rather thanat site level, meaning we were unable tolink an individual own-brand product withits manufacturing site on our orderingsystems. Purchasing at supplier level alsomeant we were unable to enforce asanction on an individual non-compliantsite without impacting on all of the
supplier’s sites. Working with John Lewis
Trading teams, we implemented a systemsolution to directly link product codes
to the site of manufacture. Suppliers
are now responsible for ensuring they
provide the site details for each orderand are reminded to declare if any data isincorrect. Furthermore, after developing
this capability, we’re able to block orders
from sites that, after ample opportunity
to comply, remain non-compliant. Buildingon these improvements, work on gaining
greater visibility and improved ethicalcompliance remains ongoing (see page 11).
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Spot checks

Whistleblowing

Spot checks are designed to support ourdue diligence programme at sites. This
year we undertook a spot check in one of
our Kenyan fresh vegetable supply chainsto understand whether a farm’s labour
practices met the requirements of regular
employment ETI base code clause. In
addition to findings regarding fixed-term
contract renewal, the spot check uncovered
differences between the benefits afforded
to temporary and permanent workers, suchas access to savings and loans programmes.
As a result, we widened the criteria of our
Waitrose & Partners Foundation ‘Access toFinance’ programme to temporary workers
at the farm to ensure that, together withthe farm, we were meeting the needs of ahigher proportion of workers.

We have a number of channels
and contact points that enable
individuals working in supply chainssupplying our Partnership to contact
us. All correspondence is handledin accordance with our internal
whistleblowing guidelines. We aredeveloping our existing Partnershippolicy to ensure these channels are
effective and consistently managed.

However, as a result of prioritising
improvements to supply chain transparency
over the past 12 months, we were unable
to carry out our planned number of spot
checks in 2021/2022. Going forward,
we’ve committed to utilising the spot checkprogramme more effectively by increasing
the number of checks carried out andcontinuing to use the programme to carryout independent investigations when weare alerted to issues of possible breach to
our RSCOP. Our target is to carry out 16
spot checks over the course of the 2022/23
financial year.

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In 2021/22, we had 29 reports from
whistleblowers, mostly alerted to us
via The Issara Institute, compared to
21 in the previous year. To continue
harnessing an environment where
workers can report grievances to us, wewill keep utilising a range of sector andlocation-specific whistleblowing channels,
including those listed in the table below.
We also work collaboratively with otherbrands and key stakeholders to share
information, resolve issues and provide
solutions where appropriate.

Whistleblowing cases
2021/22

Fairtrade tea
producers – AssamOver the last year the number ofFairtrade-certified producers of Assamtea has reduced14. The Assam region isa particularly challenging setting, withpoor living and working conditions, low
wages and increasing costs of production.
Fairtrade requires a high set of standards
to be met and systemic challenges in
the region have meant a number of
producers have been unable to maintaincompliance with these standards. As aresult, Fairtrade is working to develop a
new approach to Assam tea certification.
Waitrose is involved in the consultation

Contact method

process for this, alongside local producers
and other retailers. Whilst this is being
developed we have continued to pay a
Fairtrade-equivalent price and Premium,an additional sum of money to enable
investment in the community. This is being
monitored by a third party, Impactt, toensure funds are used to benefit workers
and their communities.

14. Fairtrade Foundation, 2021, Fairtrade Sourcing In Assam,
01.06.2022, https://www.fairtrade.org.uk/tea/

2020/21

Cases

Countries

Cases

Countries

UNSEEN business portal

2

UK

4

UK

Local MP

1

UK

1

UK

Media

7

UK, Spain,
Portugal,
Malawi2UK

Trade unions/Industry bodies

1

Bangladesh

2

UK

Issara15

Thailand1

Thailand

Sedex/Audit company

1

UK

1

China

Direct letter from a whistleblower

1

UK

5

UK

ETI

1

UK

1

Zimbabwe

Direct from tier 1 supplier

0

N/A

3

UK

Direct from authorities

0

N/A

1

UK

Total

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Advocacy work
During 2021, our Partnership, alongside
35 other businesses and investors,
called on the UK Government to bringforward important legislation that would
mandate companies to carry out humanrights and environmental due diligence.
As we move into 2022, we will continue
to monitor and support the progressof this legislation, which will help drive
higher standards of human rights andenvironmental due diligence across more
supply chains and, most importantly,
ensure justice for those who have been
victims of poor practices.

Driving change
throughcollaboration
Our Partnership participates in a
number of industry initiatives, forums
and membership communities thatengage on global human rights issues.
These collaborations enable all
involved to bring about change in an
effective way utilising our combined
resources, experience and leverage. Key
partnerships include:

Ethical Trading Initiative (ETI)
We actively participate in a number of the
ETI’s initiatives across the Food and Farmingand Apparel sectors. These include the Italy
Working Group and the newly established‘Transitions’ workstreams. We’re able towork with other retailers and key industry
stakeholders to share findings from ourprogrammes, learn from the work of otherprojects and collaborate on ensuring thatindustry best practices are well known andaccessible to all. One example is the work
we’ve done with the Italy Working Groupin sharing our learnings from a grievancemechanism project that we initiated insouthern Italy (page 29).
We also participated in the FCDOfunded project ‘Securing Workers’ Rights
in a Covid-19 Context in East African
Agriculture Supply Chains’, alongside several
other retailers and suppliers, coordinated by
the ETI. See page 12 of our 2021/22 Ethics& Sustainability Report for more detail.
The ETI also gives us an effective
mechanism to engage with othercompanies, NGOs and trade unions tofind resolutions to whistleblower cases
or grievances which impact on the wider
industry. Working through the ETI helps
us to ensure that all efforts to obtain
resolution are coordinated, prompt andeffective.

Ethical Trade Forums in Spain

Food Network for
Ethical Trade (FNET)
Waitrose, alongside a number of otherUK retailers and suppliers, is a memberof the Food Network for Ethical Trade.
The FNET aims to improve working
conditions in global food, beverageand horticulture supply chains byproviding guidance, resources, training
and opportunities for collaboration.
Our Senior Manager - Human Rights
Programmes, is an FNET Board member
and we actively participate in a numberof the FNET working groups, including
those focused on improving worker
representation and tackling issues aroundrecruitment fees. FNET provides us
with a space in which to share learnings
and, over the last year, regular updates
on regulations and risks in relation to
Covid-19 have been invaluable to enable
us to understand challenges within our
supply chain.

Waitrose has actively supported the
Ethical Trade Forums (ETF) since its
formal inception in 2015. The groupaims to improve working conditions in
the Spanish horticulture sector throughpromoting good practice, facilitating
collaborative working and building
capacity through training. In addition tovolunteering to represent UK retailers
in the ETF’s governance sub-group, weare part of two of the working groups:
event support and increasing active
engagement. Our involvement in thesegroups helps to ensure the EFT achieves
its vision in a sustainable way, as we areable to share our expertise and use ourleverage to refine and shape its work.
The programme operates by issuing asurvey to growers in the three main
regions they operate in, Murica, Huelva
and Almeria, to ensure focal areas
for region-specific work are relevant.
The 2021 Sector Survey revealed themost common challenges currently
facing growers are labour challenges,
including a lack of workers, managing
working hours, understanding customer
requirements, and environmental
challenges including water management,
waste and the impacts of climatechange.

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To address these concerns, the ETF
hosted ten online seminars and three
one-day events online in 2021. Topics
ranged from discussing how to apply
technology to managing people andworkplaces, to providing training on theimportance of due diligence in social
auditing and labour migration, andresponsible use of water. Introductory
guides were also developed, focusing on
areas such as implementing an emissionreducing climate strategy, developing
grievance procedures, improving
dialogue with worker representatives
and preventing workplace harassment.
These were shared with relevant
growers and uploaded to the ETF
website for public use. As of February2022, the guide for improving dialogue
with worker representatives15 has been
downloaded 38 times.

15. Conexión Social, 2022, Ethical Trade Forums Newsletter,
01.06.22, https://foroscomercioetico.com/wp-content/
uploads/2022/03/boletin_febrero_22_ENG.pdf

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Looking
forward
We are proud of our work andachievements over the past
year to protect the humanrights of every person in
our own operations and the
supply chains supplying ourPartnership, yet we recognise
there is more to do.

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Ensuring basic working conditions
are being met in line with RSCOP

Addressing broader human rights
risks through collaboration

Ethical compliance

Human Rights Impact
Assessments (HIRAS)

Addressing human rights
in the UK fishing sector

Our new Partnership Human Rights
Policy (as referenced on page 6)
formalises our requirements relating
to the respect for human rights within
our direct supply chains and thecommunities from which we source.
We have started two HRIAs to lookat these broader requirements and will
be putting in place plans to address therecommendations from these during2022/23. We are also planning tocommission two new HRIAs in 2022/23
with a focus on cotton and farmed fish
supply chains.

Our research into the experiences of
migrant fishers in the UK wild-caught
fishing sector highlighted some areas
where our influence could help todrive improvements, particularly in
relation to supporting migrant workers
in better understanding their rights in
the UK. We’re currently working withstakeholders in the fishing sector to put
in place a plan of activities, which will
combine both practical tools to support
migrant fishers, but also the developmentof an industry roundtable to advocate
for improvements in the sector.

As noted in the Effectiveness section,
our work towards greater visibility andimproved ethical compliance is ongoingand in 2022 we are committed to
implementing and embedding further
improvements, including training,system-based controls and internalreporting. We continue to invest in
programmes that provide increasedtransparency and traceability beyond
Tier 1 across our extensive supply baseand are actively identifying the best
partners and initiatives to address thesalient risks identified. Identifying risks tohuman rights in these tiers continues tobe a challenge due to the complexity of
global supply chains. At present, we takea risk-based approach beyond Tier 1 but
recognise we need to do more.

“

As part of our commitment to ensuring
our ethical compliance programme isdelivering effective due diligence, wehave a target to undertake at least 16
spot check audits in 2022/23.
This year we were able to close 65%
more non-conformances identified
during SMETA audits at sites supplying
our Partnership, an increase from 846
in 2020/2021 to 1,396 in 2021/2022. To
ensure sites are continuously improving,
we have set ourselves a target of closing
20% more non-conformances in the
coming year. Although this is a smaller
increase than last year, we believe this isachievable given the competing priorities
of sites whilst dealing with ongoingchallenges in supply chains.

We’re working with stakeholders
in the fishing sector to support
improvements to working
conditions in the industry”

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Expanding our work with
the ETI Italy agriculture
working group
In 2022, our work will expand to include
establishing grievance mechanisms,
promoting good purchasing practices
and advocating for change, working withlocal NGOs and engaging additional
retailers with our work so we canensure broader collaboration across theEU.

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Addressing pressures in UK
manufacturing
As manufacturers continue to feelthe pressures of the pandemic andstruggle with labour shortages, wehave identified a need for providing
support at our General Merchandisesites in the UK. In 2022, we will besupporting management teams andproduction workers by conducting
webinars, site visits and training for
suppliers.

Promoting living wage
payments
Recognising the importance of theliving wage, during 2022/23 we willcontinue to work collaboratively with
the IDH and the UK retail sector
on identifying the gap between
current and living wages in banana
supply chains, with a view to working
towards a sector commitment
regarding wage improvements. We
are due to complete our assessmentof wages in banana supply chainssupplying Waitrose in late spring andwill look at using these findings todrive positive action over the nextyear.

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Ensuring all workers have the voice and capacity
to drive improvements to their livelihoods
Understanding worker
satisfaction

Strengthening worker
representation on farms

This year we will carry out worker
satisfaction and responsible recruitment
surveys at the most high risk sites
supplying our Partnership that areregistered with Issara. This will enable
us to identify shortfalls in worker
welfare that we can support each site
to address, and which will provide us
with better data on the recruitment
fees that migrant workers in Thailand
are being subjected to. This will help to
inform our country-specific programmes
and provide a baseline for measuring
improvements as a result of responsible
recruitment work.

As labour shortages in the UK continue
to impact, in particular, food supply
chains, we will support a programmeof work with the FNET to improve theeffectiveness of worker representation
within UK and global food supply chainssupplying our Partnership. The pilot
will include ten suppliers, six of whom
supply fresh produce to Waitrose, andwe will report on the results in our next
Human Rights Report.

Promoting worker-voicemechanisms through our
Better Jobs programme inIndia and South Africa
We have set a target to expand theBetter Jobs programme to include atleast 20 sites across India and South
Africa in 2022. In order to complete
the programme, sites will now need todemonstrate that their management
questionnaire has been fully completed,and that at least 20% of employees
have completed the worker survey. This
ensures robustness of the data and also
demonstrates a commitment to theprocess of continuous improvement
required by the programme.

Promoting a ‘Just Transition’We’re in the process of establishingscience-based targets in line with limiting
global temperature rise to 1.5°C for
operations and supply chain (scope
1, 2 and 3). Building on our existingcommitments, these will ensure thatour business follows a credible andscientifically verified carbon reduction
pathway, but will likely impact on the
livelihoods of workers within some ofour global supply chains.

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We have partnered with the Foreign,
Commonwealth & Development
Office (FCDO) on its ‘Work andOpportunities for Women’ programme,
managed by PwC, to undertake
research into the current impacts ofclimate change on women workers,
focusing particularly on the Kenyan
horticulture and fresh produce sectors.
More broadly, the research will also
make recommendations for ensuringthat our policies lead to a just transition,
demonstrating how potential net zerostrategies would have positive andnegative impacts upon these workers.
In 2022/23, we will use this research to
inform our own policy and share withthe wider sector.
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S TAT E M E N T

SDGSCO L L A B O R AT I O NModern Slavery StatementModern slavery is one of the most severe
breaches of human rights imaginable –as outlined throughout this report, we are
steadfastly determined to make a difference
in rooting it out and preventing human
exploitation. We cannot tackle this alone
and are committed to continuously sharing
our insights and collaborating with external
stakeholders to do so.

In its totality, this report outlines the steps taken
during the year to 29 January 2022 (the financial
year-end of these entities) to protect the humanrights of workers in our Partnership’s operations
and the supply chains of the goods and services
provided to our Partnership. This includes theprevention of modern slavery (including forced orcompulsory labour) and human trafficking. The tablebelow outlines where, in this report, the six areas
recommended for disclosure in a Modern Slavery
Statement by the Home Office can be found.

Disclosure

Page number/sOrganisation structure and supply chains
Policies in relation to slavery and human trafficking
Due diligence processes
Risk assessment and management
Key performance indicators to measure effectiveness of steps being taken
Training on modern slavery and trafficking

Page 4
Page 6
Pages 11-19
Pages 9-11, 20-31
Pages 33, 35-36
Pages 33-35

This group statement of John Lewis Partnership plc (the parent company) has been published in accordance with the Modern Slavery Act 2015
(the Act), and also covers its subsidiaries John Lewis plc and Waitrose Limited.
The report and statement has been approved by the Board of John Lewis Partnership plc on 13 July 2022 and signed on its behalf by:

SHARON WHITE
Partner & Chairman

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SDGSCO L L A B O R AT I O N

Sustainable
Development
Goals
T

he United Nations Sustainable
Development Goals (SDGs)
were created in 2015 to establish
a path towards a more sustainable
and better future for all. The
17 goals are an interconnectedcall to action, recognising that
activity against one target affects
the outcomes of others and that
progress must be made across
many areas to achieve real change.
In recognition of the role ourPartnership plays in meetingthese goals, we align our strategy,
including our human rights activity,
to them. Below is a list of theactivities discussed throughout
this report aligned to the SDG
upon which they have the greatest
impact.

SDG 1
No Poverty
Low wages and sustainable incomes Page 25

SDG 5
Gender Equality
Human Rights Programme

Page 8Endorsing the UN Women’s
empowerment principles

Page 27

Supporting women in the coffeeindustry in Colombia

Page 27

Supporting the Lujeri Tea Estate

Page 27

SDG 10
Reduced Inequalities

SDG 8
Decent Work andEconomic Growth

Human Rights Programme

SDG 17
Partnership for the Goals
Page 8Industry-led initiatives

Page 14

Responsible Sourcing Code ofPractice (RSCOP)

Page 6

Certification and third-party
sourcing programmes

Page 15

Worker welfare self-assessment,
livestock supply chains

Page 10

Page 17

Ethical Compliance Policy andprogrammes

Page 11

Understanding working conditions
for migrant workers in the UKfishing sector

Page 22

Ethical audits

Page 11Addressing broader human rights
through collaboration

In-depth supply chain assessments

Page17

Page 22

Understanding working conditions
for migrant workers in the UKfishing sector

Page 17

Modern Slavery Intelligence
Network (MSIN)
Stronger Together Training

Page 34

Ethical Trading Initiative

Page 37

Food Network for Ethical Trade(FNET)

Page 37

Ethical Trade Forums (ETF)

Page 37

Human Rights Impact Assessments Page 19
Grievance mechanism to improve
worker voice – south Italy

Page 29

Better Jobs Programme

Page 30

Stronger Together Training

Page 34

Whistleblowing

Page 36

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Who we work with
International Accord
A legally binding agreement between brands andtrade unions to enable a safe working environment
in the Bangladeshi garment industry.

Ethical Trade Initiative
An alliance of companies, trade unions and NGOs
advocating respect for workers’ rights around theglobe. Our Partnership is a corporate member.

Slave-Free Alliance
A membership initiative launched by anti-slavery
charity Hope for Justice, which partnered with us on‘spot the signs’ training for Partners.

Institute of Employment Studies
A British human resources employment research
centre and consultancy which acted in an advisory
capacity on the development of the Better Jobs
programme.

UnseenA registered charity working towards a world
without slavery, Unseen runs the Modern Slavery
Helpline, which JLP supports through our ‘Unseen
Business’ membership.

Food Network for Ethical Trade FNET
Established in 2016, the FNET uses the collective
leverage of suppliers and retailers to bring about
positive change in working conditions in global food,beverage and horticulture supply chains by providing
guidance, resources, training and opportunities forcollaboration.

ASK India (Association for Stimulating Know-how)
ASK India is a non-profit organisation that has
been working on empowering workers within thesustainable development field since 1993. Based infour states – Bihar, Uttar Pradesh, Rajasthan and
Tamil Nadu – its work focuses on child labour,
sustainable agriculture and safe migration.

United Purpose
In 2019, we began working with United Purpose
as a delivery partner for the Waitrose & Partners
Foundation in Senegal and The Gambia. United
Purpose is working closely with our farms todevelop plans for how Foundation funding can bebest spent in local communities.

Verisio
We work closely with Verisio to manage and deliver
our ethical audit due diligence programme. Using
its Optimus software, we are able to ensure Tier 1
suppliers and factories are compliant in supplying
valid audits and remediate non-conformances.

Centre for Child Rights
In 2021, we worked closely with the Centre forChild Rights to address the issues faced by parents
working in factories and their children during the
pandemic. This included workshops for parents andwe hope to continue working with the Centre on
future projects related to child rights.

CIPD
The CIPD is the professional body for HR andpeople development. It acted in an advisory capacity
on the development of the Better Jobs programme.
We drew on the CIPD’s Good Work Index when
designing the Better Jobs employee survey.

Responsible Recruitment Toolkit (RRT)
We sponsor the RRT, which provides our supplierswith free access to training and an online selfassessment and learning tool to help embed
responsible recruitment practices.

Stronger Together
We sponsor collaborative initiative Stronger Together
and roll out its training and guidance on detecting,deterring and dealing with modern slavery to our
supply base in the UK, South Africa and Spain.

Sedex
We are a member of Sedex (Supplier Ethical Data
Exchange) and use the Sedex platform to store
supply chain assessment data, such as SAQ and audit
information, for Food and Grocery sites.

The Joseph Rowntree Foundation
An independent UK organisation focused on socialchange research, policy and collaborations that solve
poverty. The JRF has acted in an advisory capacity inthe development of our Better Jobs programme.

The Fairtrade Foundation
We work closely with the Fairtrade Foundation toensure that key commodities including tea, coffee,cocoa, sugar and bananas meet their certification
requirements. We collaborate to raise awarenessof the difference that Fairtrade makes for farmers
in our supply chain and are working with them on
additional programmes to drive change.

Impactt
A worker-focused human rights and business
management consultancy with whom we partnered
to conduct modern slavery risk investigations andtelephone surveys for smaller suppliers.

Farm Africa
In Kenya we are working with Farm Africa todeliver activity as part of the Waitrose & Partners
Foundation. Farm Africa strives to strengthen
farm worker committees and support them todevelop programmes that meet the needs of theircommunities.

International Labour Organization Better Work
Programme
A partnership between the UN, the ILO and the
IFC, aimed at improving labour standards andcompetitiveness in global supply chains. We are abrand partner member.

Issara Institute (Project Issara)
Issara Institute is an independent non-profit
organisation, based in SE Asia, focused on tacklingmodern slavery, human trafficking and forced labour
through data collection, technology, partnership andinnovation. At present, it mainly works with our foodfactories in Thailand, monitoring and adjusting labour
conditions through partnering with businesses toempower worker voice.

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TBCJohn Lewis Partnership PLC
171 Victoria Street, London SW1E 5NN
Incorporated and registered in England and Wales
under Company No. 233462