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MODERN
SLAVERY
STATEMENT
2022/23
CONTENTS
INTRODUCTION FROM OUR CEO

OUR BUSINESS AND SUPPLY CHAIN

POLICIES AND GOVERNANCE

IDENTIFYING RISK AND PRIORITISING ACTION

TRAINING AND AWARENESS RAISING

PARTNERSHIPS AND WIDER INDUSTRY ENGAGEMENT

OUR PRIORITIES FOR THE YEAR AHEAD

INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

INTRODUCTION FROM OUR CEO

This is M&S’s eighth Modern in the host country. The seasonal nature  arrying our targeted due diligence
• c
of agriculture work increases the risk into our UK and ROI Own Operations
Slavery Statement issued in of modern slavery as there is often covering; Cleaning and Waste
accordance with the Modern a need for temporary labour during Management, Facilities Management,
peak harvest periods. Workers may Security Guarding, Construction,
Slavery Act 2015. It sets out be subjected to excessive working Warehousing and Operations and
the steps we have taken hours, substandard living conditions Logistics.
and withheld wages perpetrating their
(and continue to take) as a vulnerability to exploitation. • t he continued roll out of worker voice
business during year ending technology across our Clothing & Home
Regions experiencing cross-border and Food supply chains; and
1 April 2023 to prevent economic migration face unique
• f urther strengthening our governance
slavery and human trafficking challenges as when large numbers of
with the introduction of the ESG
people migrate for work it can put a strain
in our own operations and on resources and support infrastructures, Business Forum.
supply chain. creating an environment where

“
As was the case last year, we have scored
vulnerable workers can be exploited.
ourselves against the IASC maturity
As we review risks across the Group, we
At Marks and Spencer, doing the framework, with its four clearly defined
are particularly alert to, and focused on,
right thing is a core behaviour in our stages. We believe we remain in the
initiatives to identify and prevent modern As I complete my first year as CEO,
business. This means treating everyone “Evolving Good Practice” category, with
slavery in seasonal workers and regions I am committed to leaning into these
fairly and with respect, taking a zero some activity in “Leading on Human
with cross-border migration. challenges and working collectively
tolerance approach to discrimination Rights Innovation”.
with the industry to tackle the issue of
and unacceptable behaviour and treating modern slavery. We are actively working Our commitment to our customers and
supplier partners fairly and as partners with the agricultural sector to convene stakeholders is very clear; we will always
in our success. We understand the the government and wider supply base, treat people in our business and supply
responsibility to prevent, mitigate and as well as our peers, to act together to chain fairly. Doing the right thing by the
remediate, as understood and carried out manage the risks arising from labour people who work with and for M&S is part
in accordance with the responsibility to shortages in the UK. For example, we have of our DNA, and at the core of the trusted
respect human rights under the United been instrumental in the development of value our customers expect from us –
Nations Guiding Principles on Business the Seasonal Workers module of the “Just now more than ever.
and Human Rights (UNGPs). Good Work” app which gives workers their
We recognise that modern slavery is rights in their own language once arriving
a growing issue, and that global crises in country and has been downloaded

Stuart Machin
increase the risks of human trafficking 19,000 times already.
and forced, bonded and child labour. This year we have also made progress in
Modern slavery can be more prevalent Chief Executive Officer
strengthening our own approach, including:
in situations where migrant workers Marks and Spencer Group plc
are employed. People leaving their • c
 ompleting a review of our salient
home countries for work can often human rights issues at a country and 23rd May 2023
find themselves lacking social support sector level, with input from internal This Statement has been approved by the
networks and knowledge of their rights and external stakeholders; Board of Directors

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 2
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

OUR BUSINESS
M&S operates as a family of businesses across Food, Clothing Ocado - M&S holds a 50% investment in Services - M&S Bank is operated by HSBC.
Ocado Retail, a joint venture relationship Due to the nature of their business, they
& Home and International, each led by its own integrated between M&S and Ocado Group. report separately through HSBC.
management team, with functional accountability for their Ocado Retail publishes a separate
Brands – In March 2021, we formally
Modern Slavery Statement.
divisions, including marketing, supply chain and finance. launched “Brands at M&S”. To date, we
International - We work with trusted have launched over 60 brands under
We do this through a network of 1,064 stores, and over 100 websites globally. Across our partners to extend the M&S brand to owned, wholesale, consignment or
stores, support centres, warehouses and supply chain, our 64,000 colleagues serve over markets around the world. This statement collaboration models.
30 million customers each year. covers activity within our owned and JV
Gist – M&S acquired Gist, our principal
International operations (Greece, Czech
Food logistics provider in July 2022. Gist
Republic – owned, and India - JV).
will continue to report through their own
Modern Slavery Statement.

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 3
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

OUR OWN LABEL SUPPLY CHAIN

We predominantly sell Reporting transparently on our own-label GNFR includes products and services
supply chain practices and operations we buy to run our business and covers
own-brand products, is core to our approach to sourcing. We Logistics, Operations, Marketing
manufactured and marketed publish data within the M&S Interactive Technology, HR, Property, Facilities
Supply Chain Map, disclosing our Tier 1 Management and Packaging. We have
exclusively under the M&S supply chain across Food and Clothing nearly 1800 GNFR suppliers, 80% of
brand. Our relationships with & Home. This scope also includes some the money we spend is with the top
raw materials, including wool, man-made 250 suppliers.
our supplier partners are built cellulosic fibres, beef, fish and seafood,
on trust with shared aims. dairy, tea and coffee, and is updated
We have three primary groups twice each year.

of suppliers: Food, Clothing

& Home and Goods not for
Resale (GNFR):

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 4
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

POLICIES AND GOVERNANCE

We have several Group-wide Global Sourcing Principles First introduced in 1998, and extended to all suppliers and partners as of May 2016, these
principles set out our minimum requirements and expectations of how we and our supplier
policies in place that are partners conduct business to uphold human rights, labour environmental, ethical and legal
relevant to modern slavery, requirements in their own operations and their supply chains. The Principles were updated in
all of which are signed off at April 2022.

director level. We continually Human Rights Policy States our commitment to respecting internationally recognised human rights in line with the
principles and guidance contained in the United Nations Guiding Principles (UNGPs) on Business
review and develop our and Human Rights.
policies with input from
Code of Conduct Sets a floor of minimum commitments for our business conduct. The commitments are focused
in-house experts, suppliers on key policy areas affecting M&S, to ensure we act in line with relevant laws and regulations,
and external stakeholders. industry standards and stakeholder expectations. The code applies to everyone at M&S, including
our Board, our management team and all our colleagues, as well as those working in any joint
ventures that we control and overseas sourcing offices.

Confidential Reporting Aimed principally at our colleagues, but also available to others working in our supply chain,
Procedures confidential reporting channels are managed by Safecall and concerns can be raised by phone
or online in multiple languages. We are also strengthening our approach with digital solutions
including worker voice feedback mechanisms.
Grievance Procedure for Grievance mechanism to remedy adverse human rights impacts within the Food and Clothing &
Clothing, Home and Food Home supply chains. The policy sets out how to raise a grievance and our recommended process
Supply Chains for investigating and understanding concerns.

Our grievance policy was last updated in July 2022 and it is regularly reviewed to ensure it remains compliant with the ACAS
Grievance Procedure and best practice. Whilst the review did not identify any immediate opportunities to improve the process, it did
identify potential opportunities to use the data we gather in a more effective way to help guide decision making across the business.

GOVERNANCE
Overall accountability for the Modern Slavery Statement and risk assessment process is held by the Executive Committee “ExCo”,
chaired by the CEO, Stuart Machin. The report is also reviewed by the ESG Committee for content, the Audit Committee for internal
controls, and ultimately approved by the Board.
To further enhance our alignment across our family of accountable businesses, our modern slavery working group includes
representatives from each of the accountable businesses and support functions. The working group reports quarterly on progress
to ensure business-wide alignment, monitor progress against our modern slavery commitments and identify any emerging risks.
You can read more about our governance structures in our Sustainability Report.

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 5
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

IDENTIFYING RISK AND PRIORITISING ACTION

Our annual modern slavery to high-risk areas with systemic risks in In 2022/23 the following countries were identified as highest risk:
the areas of governance, security, human
risk assessment is aligned rights or environmental challenges.
with the M&S Group risk To identify the countries with the highest
assessment process that risk, we have used the following: FOOD
considers external, internal • the SEDEX Radar portal to understand UK
country-level risks of forced labour;
and emerging risks and how
• information and intelligence from
these are mitigated. our projects on the ground, and local
ITALY

It covers the business functions knowledge from our Clothing & Home
of Food, Clothing & Home, Retail & Property, sourcing teams in our 10 sourcing offices; INDIA

International, and the support functions: • the Food Network for Ethical Trade
Finance and Procurement, Digital and (FNET) product-specific risk assessment THAILAND
Technology, and HR. The Director of each to drill down to the specific ingredients
business area and support function is and raw materials per country to identify
accountable for their risk assessment SPAIN
if material to M&S;
and due diligence approach.
• the information contained in a report
The manifestations of modern slavery titled “M&S Ethical Trade Risk Index
are complex and hidden, so our risk 2023” based on country-level risk
assessment includes the following indicators and product-specific risk
to enable us to prioritise activity: assessment, commissioned with an
• detailed mapping of supply chains expert ethical consultancy; and
and operations;
• information received through our
• desk-based research; memberships including Ethical Trading
CLOTHING & HOME
TURKEY
• data from our audit programmes; Initiative (ETI) and FNET.

• supplier surveys; This year we also carried out a review

PAKISTAN
of our salient human rights issues,
• supply chain due diligence;
including detail at a country and sector
• supplier engagement; level, with input from internal and CHINA
• discussions with expert stakeholders external stakeholders. We completed the
through multi-stakeholder initiatives. assessment in April 2023, and we have
updated our group salient rights issues, MYANMAR
As a majority own-label business, our you can read more in our Sustainability
primary focus is on our Food and Clothing Report. BANGLADESH
& Home supply chains, where, working
closely with our trusted supplier partners,
we are able to make the greatest impact. INDIA
As part of our risk assessment process for
these supply chains, we map our exposure

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 6
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

IDENTIFYING RISK AND PRIORITISING ACTION CONTINUED

Our programmes are built FOOD AUDIT PROGRAMME

on a robust foundation of During 2022/23, we had 38 issues raised in

relation to ‘employment is freely chosen’
compliance which allows (compared with 84 in 2021/22) 13 of these
us to monitor and track our are closed and verified, with the remaining
15 related to contract wording related
supplier partner performance to voluntary overtime and deductions.
against our minimum Audits identified two potential instances
requirements. You can read of recruitment fees this year, one in the
UK and one Thailand. We are working
more about our approach closely with our supplier in the UK on
on our corporate website. the investigation and with our supplier
in Thailand on a detailed action plan.
While we are confident that there
continues to be a role for compliance and CLOTHING & HOME
social audit programmes, we recognise AUDIT PROGRAMME
their limitations in identifying instances
of modern slavery. We will continue to During 2022/23, five non-compliances
explore modern slavery due diligence (compared with five in 2021/22), under
methodologies that complement our “employment is freely chosen” were
strong compliance foundation. Where identified in SMETA audits. The findings
possible, we are using technologies, such related to forced labour indicators, for
as worker voice apps, to allow us to reach example compulsory overtime. For all
further into our supply chains and hear audit non-compliances, we continue to
directly from the workers impacted. You work with the factory, and other brands
can read more about these programmes where shared sites, with a plan to resolve
in our Sustainability Report. the issue.

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 7
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

IDENTIFYING RISK AND PRIORITISING ACTION CONTINUED

REPORTING THROUGH slavery with 18 in the UK, 1 in Italy and 1 in

OTHER CHANNELS Thailand. We have taken action on each
case in conjunction with our suppliers
Any notifications of potential modern
and as a result 15 cases are now closed,
slavery issues and risks that are reported
with 5 pending further investigations
to us through other channels, grievance
and/or actions with the supplier. We also
mechanisms, whistle-blowers or any other
have seen increased awareness of the
parties are thoroughly investigated and
indicators of modern slavery amongst our
remediated where required.
suppliers, many of whom have referenced
In Foods, we have seen a growth in completing Stronger Together training.
allegations, particularly with a focus We continued to sponsor this training
on the seasonal workers scheme (see as this is key in spotting the signs and
page 9). In 2022/23 we received 20 pieces taking the appropriate steps to support
of intelligence related to potential modern potential victims.

RISK INDUSTRY OR SOURCE MIGRATION / REMEDIATION

FACTORY LEVEL ACTION

UK – Seasonal workers Industry Collaboration and Collaborative action with

scheme External stakeholders SWS Taskforce
This year, in Clothing & Home, due to • external stakeholders: notification from
UK – agency worker with Factory Direct supplier contact Support supplier to engage the majority of our supply chain workers other external parties.
indicators of modern slavery with GLAA and law enforcement
being permanent and not seasonal, whilst
We investigate all allegations and put
UK – potential Factory Modern Slavery Helpline Site visit to identify issue and we received some notifications regarding
community exploitation worked with site to resolve risk mitigation or remediation measures
conditions in our partner factories, those
in place. These measures can either be
Thailand – recruitment Factory Issara, direct supplier Working closely with supplier related to modern slavery risk were
at a factory level for local issues, or at
contact predominantly industry-based as detailed
a country or industry level for wider
Italy – migrant worker Grower Direct supplier contact Working closely with supplier below. The information was received from
issues, acting in collaboration with other
exploitation multiple channels, including:
stakeholders where appropriate.
• internal mechanisms: our on-boarding due
diligence and worker voice programme. Examples of risks identified and mitigation
actions this year (Clothing & Home) include:
• collaboration: our participation in
partnerships and shared projects.

RISK INDUSTRY OR SOURCE MIGRATION / REMEDIATION

FACTORY LEVEL ACTION

Myanmar – forced labour Industry Collaboration and Responsible exit from

risk External stakeholders Myanmar
India – labour rights risk Industry External stakeholders Worker voice and grievance
and internal mechanisms programme initiated
Dubai – forced labour Factory Internal mechanisms Factory not approved
issues

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 8
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

IDENTIFYING RISK AND PRIORITISING ACTION CONTINUED

FOOD SUPPLY CHAIN and their KPIs, including 19 of our key As part of our Human Rights Strategy, chain, through Issara’s independent
produce and horticulture suppliers, you can we have committed to undertake human worker voice channels. It also provides
UK AGRICULTURAL read more in our Sustainability Report. rights impact assessments (HRIA), us with information on the responses of
SEASONAL WORKERS which provide an in-depth analysis of recruiters and suppliers; these are verified
As of April 2023, while risks still remain,
the salient risks to people in our supply by Issara and offer assessments of the
In Summer 2022, we supported the we believe the actions taken by industry
chains. They include desk-based research quality and timeliness of responses to
creation of the Seasonal Workers Scheme in response to the Taskforce will support
and, most importantly, field research worker grievances.
(SWS) Taskforce, a collaboration of trade in preventing challenges of the scheme,
including interviews with stakeholders,
bodies, retailers, growers, recruiters, we remain actively engaged with
rightsholders (workers and smallholders),
and non-profit organisations. The government on shaping the future of the MODERN SLAVERY INTELLIGENCE
and our own business. This year we
group was formed in response to the scheme beyond 2023. NETWORK (MSIN)
worked on a salient risk assessment of
well-documented human rights issues human rights issues associated with M&S is a founding member of the Modern
associated with the SWS and aims to Spanish produce and will be publishing
SOUTHERN EUROPE Slavery Intelligence Network (MSIN), a
work with the UK government to improve an action plan in due course. pioneering non-profit collaboration in the
practices and safeguard workers. The In Southern Europe, much of our UK food and agriculture sector created
output of this group has been an action fresh produce supply base is reliant We are also active partners in the Spanish
in response to the findings of Operation
plan agreed in February 2023, focussed on migrant workers, particularly over Ethical Forums, a collaborative initiative
Fort, the UK’s largest ever modern slavery
on five priority issues: seasonal periods. In 2022, we continued delivering dialogue and engagement
investigation. Members are coming
our longstanding engagement in the between the fresh food industry supply
• Prevention through education and together to pool intelligence from
Ethical Trade Initiative (ETI) Working chain and its stakeholders, while
information for job seekers through the within our supply chains and to achieve
Group on Italian Produce, which aimed obtaining relevant impacts, raising
creation of the “Just Good Work” app, effective ways of working across the food
to use its collective leverage to improve awareness, developing solutions and
which gives workers their rights in their industry with the aim of ensuring, as far
the human rights impact specifically improving workers’ lives.
own language once arriving in country. as possible, that robust mechanisms are
It has already been downloaded by in the processed tomato sector. The in place to safeguard those who may
19,000 workers. group worked to support local growers be impacted by modern slavery and/or
THAILAND
to adopt more robust labour practices worker exploitation. In June 2022, the
• Collaborating to take a risk-based and engage local suppliers to strengthen In Thailand, we have been strategic MSIN held a conference with over 100
approach to source countries. due diligence. During 2022/23, 38 partners with The Issara Institute since attendees engage wider stakeholders on
supplier partners received due diligence 2014, a non profit organisation tackling issues of labour exploitation in the food
• Minimising scheme costs to recruiters.
training and two additional webinars on issues of human trafficking and forced and agriculture sector. In 2023, MSIN was
• Independently assessing scheme responsible recruitment were hosted in labour through worker voice, partnership, created as a registered business; M&S is
operations. February 2023. The progress and learning and innovation. In 2022 Issara handled represented on the Board.
from this working group will now feed 105,365 calls and messages from workers
• Working with the government on quick
into the new ETI “Grievance Mechanisms and job seekers across the industry,
wins and longer-term policy changes to
in Agriculture” programme, which M&S providing critical information and leading
improve the system.
will be supporting. In addition to the ETI to the successful remediation of 34,608
A core pillar of our Food Human Rights Working Group, we also carried out our worker-reported labour issues. This
Standard, is the requirement for our own due diligence visit during harvest year, we have continued to make use
supplier partners to embed a pro-active season 2022, to understand the leading of the updated Issara Partner Supplier
Human Rights Due Diligence (HRDD) work our key supplier partner has been Dashboard, which allows us visibility of
approach in their own operations and undertaking in collaboration with an NGO information on recruitment and working
supply chain. This year we reviewed 45 and to build capacity to engage with conditions reported on an ongoing
supplier partners’ approaches to HRDD migrant workers in the fields. basis directly by workers in our supply

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 9
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

IDENTIFYING RISK AND PRIORITISING ACTION CONTINUED

CLOTHING & HOME In October 2022, based on the findings production and excluded Dubai from to remind existing or new suppliers of
from the Myanmar Enhanced Due becoming an approved sourcing country this ban.
SUPPLY CHAIN Diligence Sectoral Assessment, we for Clothing & Home. Even without
Since September 2022, we have been
concluded that it was not possible for our becoming part of our supply chain, we
MYANMAR RESPONSIBLE EXIT testing samples of cotton on a monthly
Global Sourcing Principles to be upheld, advised the factory on remediation of the
basis through the OritainTM lab. OritainTM
Following the coup in Myanmar we worked and as we do not tolerate any human issues that they agreed to address. We
apply forensic and data science to detect
closely with our stakeholder groups such rights abuses within any part of our continue to review our sourcing approach naturally occurring elements in a product
as the Ethical Trade Initiative, the British supply chain, we began working towards in response to risks identified in our due or raw material. Soil composition, climate,
Retail Consortium and the Government a responsible exit from Myanmar. You diligence and from information from altitude, precipitation, and other
Department for International Trade, as can read our public statement here. We external partnerships and stakeholders. environmental factors all reveal details
well as our on-the-ground audit process worked closely with relevant stakeholders
of the products origin – allowing us to
to monitor the situation in Myanmar. including the Ethical Trading Initiative
COTTON TRANSPARENCY confirm the claim origin of the cotton
There is always a balance between trying throughout the consultation process, and verifying any consistency with the
to be a force for good by offering jobs to ensure that our suppliers adhered Our Responsible Cotton Sourcing Policy banned source of origins. Launching
in a safe, respectful environment, and to national laws and human rights were requires that no cotton should be sourced the testing programme has given us the
reflecting changing situations, hence upheld and to ensure the effects of the from Turkmenistan, Uzbekistan, and the opportunity to reinforce the dialogue with
we kept the situation under review for withdrawal decision on the individual Xinjiang region of China. All supplier our supplier partners on cotton sources
many months. workers in Myanmar was considered. partners must declare the cotton country and gives us added assurance our policy
Myanmar was a very small sourcing This process of withdrawal has taken of origin and we regularly share updates is being followed.
market for us and in 2022 we refrained several months to ensure minimal
from making any additional investments impact on workers and a continuation
in Myanmar while continuing to of their employment after our exit and
meaningfully engage with unions locally we also honoured our commitment
and internationally as well as other to suppliers, to pay for products that
international NGO’s on the ground, such were in production. We have no further
as the International Labour Organisation, production nor trading relationship
to ensure the welfare of the workers in with Myanmar.
the small number of factories we work
with. As the situation developed, we
commissioned and co-funded a research DUBAI FORCED LABOUR CASE
assessment “Myanmar Enhanced Due In January 2023, our regional compliance
Diligence Sectoral Assessment” into the team carried out an M&S social compliance
situation in Myanmar, investigating the assessment of a potential new factory in
human rights risks, the economic links
Dubai. During the visit, evidence was found
to the military and the socio-economic
that migrant workers had paid recruitment
impact on workers of a withdrawal of
fees in their home countries, there was
sourcing. The assessment concluded
restricted freedom of movement in worker
that forced labour indicators were
accommodation and compulsory overtime.
present, including excessive overtime and
restriction of movement. The full report Due to the findings of our site visit, and
can be found here: Myanmar Enhanced in particular the forced labour issues,
Due Diligence Sectoral Assessment. M&S did not approve the factory for

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 10
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

IDENTIFYING RISK AND PRIORITISING ACTION CONTINUED

GNFR AND SERVICES UK OWN OPERATIONS CLOTHING & HOME LOGISTICS THIRD PARTY BRANDS
To ensure compliance with our minimum Labour shortages across the UK and With the exception of China, this year The Brands at M&S programme launched
Europe are increasing the reliance on we have been able to recommence our in 2021, and in recognition of the
standards in our GNFR supply base, all
temporary and contracted labour for regular physical audit programme in
our supplier partners are invited to carry growing importance to our business of
supplier partners providing services to all offshore Container Freight Station
out a questionnaire and document-based the programme, this year we recruited
our own operations. In recognition of this locations (CFS). Audits are completed
management system assessment through a Brands ESG Manager to work in
heightened risk, this year we completed by our International Sourcing Offices
the EcoVadis platform. This assessment partnership with our own label Ethical
targeted modern slavery due diligence and UK Logistics Team and they include
covers the policies and processes supplier with suppliers in the UK and ROI covering: Trade and Sustainability teams. The initial
questions on health and safety, wages,
partners have in place, covering topics Cleaning and Waste Management, focus has been to embed our compliance
agency work and management systems.
including employee health and safety, Facilities Management, Security programme and carry out due diligence
As China has now lifted restrictions our
working conditions, social dialogue, Guarding, Construction, Warehousing to understand more about how our brand
audits have recommenced. Maintaining
diversity, child labour and human rights. and Operations and Logistics. As an partners source through a combination
an open dialogue on modern slavery
Once a scorecard has been generated initial step we have engaged all supplier of desk-based research and interviews.
is a priority and this year we engaged
for a supplier, any improvements required partners operating in these areas to Our minimum requirements prohibit
with our logistics partner in Bangladesh
are highlighted and issued to suppliers understand more about their processes in conversations on the use of agency our partners from sourcing cotton from
in the form of a corrective action plan, including their policies, due diligence, workers. As a significant sourcing Xinjiang, Turkmenistan and Uzbekistan,
which is then actively monitored on the training, and whistleblowing channels. region our priority will be to ensure the and Myanmar was added to our high-
EcoVadis system. We approached the due diligence with standards and conditions for all workers risk country list in September 2022.
a particular focus on how our partners across sites are equivalent to the highest However, we know our biggest risk is
manage relationships with agents and in the network. transparency as we have limited visibility
sub-contractors. We will use the findings into our brand partner’s supply chains.
of this work to shape conversations with The priority for the year ahead will be to
our supplier partners over the next INTERNATIONAL OPERATIONS continue building relationships with our
12 months, sharing any learnings and partners through regular interviews and
With the growth in sales in European
best practice where appropriate. engagement through webinars on key
markets, this year we have invested in
a new logistics hub in Croatia enabling topics centred around M&S policies.
FOOD LOGISTICS the direct import of stock destined for
EU markets. The facility is managed by a
M&S acquired Gist, our principal Food
third party and modern slavery controls
logistics provider, which operates via
a network of 16 redistribution centres were incorporated into contracts. Over
across the UK and ROI. The acquisition 80% of the workers at the facility are on
provides a platform to accelerate our permanent contracts with the remaining
plans to modernise our supply chain and agency workers from two pre-agreed
support growth and allows us to take partners. Our priority in the coming year
closer control of key decisions. Modern will be extending our own operations due
slavery and human rights formed part of diligence to supplier partners in Europe.
the due diligence during the acquisition,
and we met with Gist to understand more
about their approach during the year.
Gist will continue to report through their
own Modern Slavery Statement.

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 11
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

TRAINING AND AWARENESS RAISING

Our colleagues and supplier FOOD SUPPLIER PARTNER TRAINING CLOTHING & HOME SUPPLIER
PARTNER TRAINING
partners play a major role This year we delivered three Supplier
Exchanges with the objective of bringing This year we co-funded a UK supplier
in helping us to identify and our supplier partners together to engage training event with Slave-Free Alliance
prevent modern slavery in on key topics, collaborate, and share and UK Furniture Brands: Addressing
best practice. This year sessions covered Modern Slavery and Labour Exploitation,
our supply chain. modern slavery and embedding human Together. This was a training event for
rights due diligence into their businesses. all UK furniture suppliers and was
COLLEAGUE TRAINING a collaboration between Slave-Free
We recognise the role that excessive
Alliance (SFA) and seven UK furniture
In January 2022, we launched an recruitment fees can play in leaving
brands. The training aimed to provide
e-learning module for our support centre workers in situations of debt bondage,
a deeper understanding of the risks
colleagues that shines a light on the a form of forced labour. M&S is a sponsor
and indicators of modern slavery and
“People Behind the Product”. The module of the Responsible Recruitment Toolkit
labour exploitation and deliver practical
helps our colleagues to consider who the (RRT), which enables our suppliers to
advice and tools to address these.
people behind our products are and to access a variety of tools and resources
It included best practice sharing on
understand how the choices they make to manage responsible recruitment.
responsible recruitment, effective
on a daily basis can impact the people This year 146 of our supplier partners
due diligence, grievance mechanisms,
who work in our supply chains. It includes have accessed the programme and
and proportionate remediation.
fictional case studies from global supply 124 individuals have completed an RRT
chains. The module was completed by training course.
94.8% of colleagues across our Food, We continue to work with Stronger
C&H, International, Bank and support Together, a multi-stakeholder business-
centre functions, including Corporate led initiative aiming to reduce modern
Governance, Procurement, Digital and slavery by providing guidance, training
Data, HR and Property. The module is and resources in the UK, Since the
mandatory for new colleagues when beginning of our sponsorship we
they join M&S, and will be completed have reached 1,932 individuals with
by all colleagues on a bi-annual basis. 570 suppliers across the UK; 18 sites
All colleagues will be completing the continued to be Stronger Together
training module in 2023/24. Business Partners and 9 became
Advanced Business Partners.

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 12
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

PARTNERSHIPS AND WIDER INDUSTRY ENGAGEMENT

Partnerships are crucial in ORGANISATION HOW IT SUPPORTS OUR WORK CONFRONTING THE CHALLENGE OF MODERN SLAVERY

tackling modern slavery, International Accord M&S were a signatory of the original Accord on Fire and Building Safety in Bangladesh (2013), and have since also signed
the subsequent Transition Accord (2018), the Interim Agreement (2021), and the International Accord for Health and Safety
particularly when confronting in the Textile and Garment Industry (2021). In January 2023, M&S signed the Pakistan Accord on Health & Safety in the
some of the global challenges Textile & Garment Industry, as part of our ongoing commitment to working conditions in our supply base.
Clear Voice Interpreting service specialising in telephone, face-to-face and video interpreting. The social enterprise run by Migrant
we face within the industry. Help allows us to speak to workers through translation during interview.
Collaborations between The Coalition to End Forced Labour in A coalition of civil society organisations and trade unions united to end state-sponsored forced labour and other egregious
retailers, manufacturers, the Uyghur Region human rights abuses against people from the Uyghur Region in China, known to local people as East Turkistan. M&S was
one of the first companies to formally sign the Call to Action on human rights abuses to exit the Uyghur Region.
NGOs and government ETI Our membership enables us to work collaboratively with companies, trade unions and civil society on difficult human rights
bodies is a crucial way to issues, including modern slavery, that cannot be solved by individual companies working alone.

share information, develop Food Network for Ethical Trade (FNET) FNET is a key vehicle to drive ethical trading down the supply chain and work with industry partners and suppliers on
challenging ethical issues. It played a pivotal role over the last year during Covid-19 – M&S was a founding member.
guidance and shape our ILO Better Work Programme M&S is a partner of Better Work, which is a comprehensive programme bringing together all levels of the garment industry
approach moving forward. to improve working conditions and respect of labour rights for workers.
Reimagining Industry to Support Formerly known as Empower@Work, RISE brings together the women’s empowerment programs from CARE, Better Work,
Equality (RISE) BSR’s HERproject, and GAP Inc. P.A.C.E to deliver a unified approach to women’s empowerment and gender equality in
global supply chains. M&S has been a member since January 2023.
Institute for Human Rights and Launched in May 2016, the Leadership Group for Responsible Recruitment is a collaboration between leading companies
Business “Leadership Group for and expert organisations to drive positive change in the way that migrant workers are recruited. As part of this group we
Responsible Recruitment”, focussing are committed to the “Employer Pays Principle”.
on the Employer Pays Principle
Issara Institute M&S is a strategic partner in the Issara Institute in Thailand, which promotes a different model of issue detection based on
an “empowered worker voice”.
Modern Slavery Intelligence Network M&S is a founding member of the Modern Slavery Intelligence Network (MSIN), a pioneering non-profit collaboration in the
(MSIN) UK food and agriculture sector created in response to the findings of Operation Fort, the UK’s largest ever modern slavery
investigation.
Responsible Recruitment Toolkit The Responsible Recruitment Toolkit (RRT) is an unparalleled online capacity building tool to help business understand,
achieve and demonstrate responsible recruitment. RRT is an initiative of not-for profit Stronger Together.
Seafood Ethics Action (SEA) Alliance The Seafood Ethics Action (SEA) Alliance is a pre-competitive collaboration of retailers and seafood businesses aiming to
strengthen human rights due diligence carried out in the global seafood supply chain and ensure respect for human rights.
Members include many of the UK's major retailers and seafood businesses, alongside retail and industry trade bodies.
SEDEX Sharing data significantly increases efficiencies for M&S. The platform creates consistency across supply chains, making it
much easier for suppliers to take action.
Spanish Ethical Trade Forums Collaborative initiative delivering dialogue & engagement between the fresh food industry supply chain and its
stakeholders, while obtaining relevant impacts, raising awareness, developing solutions and improving workers’ lives.
Stronger Together Multi-stakeholder business-led initiative aiming to reduce modern slavery by providing guidance, training and resources
in the UK, Spain and South Africa.
Unseen Modern Slavery and Exploitation Sponsorship of the Modern Slavery and Exploitation helpline and intelligence from the portal helps us to investigate live
Helpline and Business Portal issues within our supply chains.

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 13
INTRODUCTION OUR BUSINESS AND POLICIES AND IDENTIFYING RISK AND TRAINING AND PARTNERSHIPS AND WIDER OUR PRIORITIES FOR
FROM OUR CEO SUPPLY CHAIN GOVERNANCE PRIORITISING ACTION AWARENESS RAISING INDUSTRY ENGAGEMENT THE YEAR AHEAD

OUR PRIORITIES FOR THE YEAR AHEAD

ONGOING COMMITMENT

Train our colleagues to  trengthen our network of

S Identify risks regarding I dentify and use
raise awareness of our supply chain intelligence recruitment practices opportunities for
corporate responsibility to build supplier partner of third-party labour collaboration to verify
and train suppliers and capacity, and work with providers in M&S and help resolve
assess their ability to leading forced labour operations and risk issues.
detect and mitigate experts on bespoke due supply chains.
modern slavery risks. diligence audits.

ACTIVITY PLANNED FOR 2023/2024

Complete the bi-annual refresher Continue to develop and scale worker Extend our GNFR modern slavery due Continue to collaborate and work with
training the People Behind the voice programmes across Food and diligence to supplier partners in our the partnerships listed on page 13
Products module for all colleagues Clothing & Home supply chains. European operations. with a particular focus on:
and new joiners to the business. • E
 ngaging with the UK government
Roll out the Everyone’s Business App on delivering the objectives of the
Continue to sponsor the Responsible in Clothing & Home, a human rights seasonal workers taskforce and
Recruitment Toolkit and Stronger toolkit to allow M&S colleagues to shaping the future of the scheme
Together programme with supplier raise any issues of concern internally beyond 2023.
partners. when visiting our supply chain.
• S
 upporting the delivery of the
ETI “Grievance Mechanisms in
Continue to engage with high-risk Agriculture” programme
suppliers on their approach to HRDD
as a commitment within the Food
Human Rights Standard.

Marks and Spencer Group plc M&S Modern Slavery Statement 2022-23 14