Modern Slavery

Our business purpose is to bring brighter living within everyone’s reach, and in order to achieve this, Asda is committed to address the complex issue of Modern Slavery within our businesses and supply chains.

Our statement details our approach in addressing Modern Slavery, covering all areas recommended by government guidance:

• Organisation structure, business and supply chains;

• Policies;

• Risk Assessment;

• Due Diligence (steps to address risk)

• Training about Modern Slavery

• Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation’s actions and progress over time.

In addition, since introduced in March 2021, Asda also publishes our Modern Slavery Statement via the UK Government Modern Slavery Registry.

Modern Slavery is an umbrella term which encompasses human trafficking, slavery, servitude, and forced or compulsory labour. There are many forms of Modern Slavery, and these can impact everyone.

It is always a result of an ACTION (Transfer, Transportation, Receipt, Harbouring, Recruitment) using MEANS (Threats, Coercion, Abduction, Force, Fraud or Deception, Abuse of power with a PURPOSE (Forced Labour, Organ Removal, Servitude, Sexual or Criminal Exploitation, Slavery). From a business perspective many, if not all, of the forms of Modern Slavery may present a challenge for us or impact our customers and colleagues and we are cognisant to that.

Our actions on Modern Slavery therefore, start with risk assessment and reviewing all our risks in relation to Modern Slavery across our businesses and our supply chains.

Human Trafficking 

Someone is moved by force, fraud, coercion or deception to be exploited. Exploitation can include; Forced labour, Being made to commit crimes, Being forced into marriage or prostitution, Any other form of modern slavery. Some people are trafficked so that their internal organs can be harvested and sold. 

Forced Labour 

The definition of forced labour is “all work or service which is exacted from any person under the threat of a penalty and for which the person has not offered themselves voluntarily.” 

Bonded Labour or Debt Bondage 

Debt bondage is a form of forced labour and happens when a person is forced to work to pay off a debt.  They are tricked into working for little or no pay, with no control over their debt. This is thought to be the most widespread form of slavery today. 

Domestic Servitude 

Someone is forced to work in someone else’s home, perhaps cooking, cleaning and looking after children, with little freedom or pay. 

Forced and early marriage 

Someone who is married against their will and can’t leave. Most child marriages can be considered slavery. 

Criminal Exploitation 

Someone is forced into crime such as carrying drugs, forced begging, theft or fraud. 

Sexual Exploitation 

Victims are forced to perform sexual acts. 

Descent-based slavery 

Someone is born into slavery; they inherit the status of “slave” from their mother. 

Child Exploitation 

A child is exploited for someone else’s gain, this can include being trafficked, being forced to become a soldier or marry, or being kept in domestic servitude. 

This can take 3 main forms: 

• Child Criminal Exploitation 
  Child Criminal Exploitation occurs where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child or young person under the age of 18. The victim may have been criminally exploited even if the activity appears consensual. 

• Child Sexual Exploitation 
  When a child or young person is exploited they're given things, like gifts, drugs, money, status and affection, in exchange for performing sexual activities. 

• Child Financial Exploitation 
  Child Financial Exploitation, sometimes referred to as 'money muling', is the term used to describe the action of using a young person's bank account to move money obtained from illegal sources. 

From a business perspective many, if not all, of the forms of Modern Slavery may present a challenge for us or impact our customers and colleagues and we are cognisant to that. 

Our actions on Modern Slavery therefore, start with risk assessment and at Asda we look to review all our risks in relation to Modern Slavery across both our businesses and our supply chains. 

The Exploitation Spectrum 

Forms of Modern Slavery exist on a spectrum and a typical view of modern slavery is that it happens to someone else. In reality, across the forms of Modern Slavey there are many issues and indictors and individuals experiencing them may experience a spectrum of exploitation. 

Risk Assessment is one of the five ‘building blocks’ of the Asda compliance programme. It is the foundation on which the programme is built, allowing resources to be utilised in a risk-aware way, facilitating continuous improvement and simplification, and demonstrating good governance and due diligence. In our risk assessment process, we look to consider the likelihood and impact of a specified risk in occurring.

As Modern Slavery risks can be significantly different, dependent on whether we are looking at our own businesses or our supply chains, each is treated separately given the complexity of the associated issues. All risks are scored and prioritised, and action plans put in place for any gaps which are identified.

We recognise how important training and awareness in relation to addressing Modern Slavery and this is equally important across our colleagues, suppliers and customers as anyone can be impacted by Modern Slavery. Asda continues to engage these audiences in different ways to train and raise awareness to all.

We train our colleagues through a specific Modern Slavery e-learning module, and raise awareness at key moments every year, such as the UK National Ant-Slavery Day on the 18th October.

We encourage our suppliers to undertake training and awareness through our partners, making this accessible and free where possible for all.

Our customers are becoming ever increasingly aware of modern slavery where the subject matter is increasingly in news headlines and on social media, and we look to explore opportunities to highlight modern slavery issues more widely.

We have a number of policies in place to help support our Modern Slavery approach and convey our expectations ,particularly in our supply chains.

• Supplier Modern Slavery Policy

• Colleague Modern Slavery Policy

• Human Rights Policy

• Standards for Suppliers

• Statement of Ethics

A significant factor in addressing Modern Slavery risk relates to recruitment, and Asda is committed to responsible recruitment and supports the Employer Pays Principle.

Our Modern Slavery programme is delivered via our Legal and Compliance team, and we have a dedicated Modern Slavery Subject Matter Expert (SME) in place to deliver our programme and commitments. This is underpinned by a thorough internal business governance process, with Modern Slavery being one of our ‘Business Fundamentals’ in our overall approach to ESG. Due Diligence is critical to addressing our Modern Slavery business and supply chain risks, and as such, Asda has key processes and controls in place to mitigate these risks. For example, Modern Slavery Monitoring, on a quarterly basis: checking our colleague data for potential indicators of Modern Slavery such as duplicative records across bank accounts, telephone numbers, emergency contacts and addresses. 

Within our supply chains, our standard terms and conditions require that our Suppliers comply with the UK Modern Slavery Act 2015 and our supplier onboarding processes include controls to check for compliance from the outset. 

Asda also takes the approach that any grievances or whistleblowing with allegations of Modern Slavery are fully investigated via our incident management process, and will look to work with our suppliers where issues may be identified, and we reserve the right if needed to terminate our contracts with suppliers if they are not prepared to take steps to remedy. Governance is recognised as equally important and our approach in this area has evolved to integrate the subject matter area of Modern Slavery into Asda’s overall ESG strategy which is overseen by our ESG Steering Committee, co-chaired by our Chief People Officer and our General Counsel and Company Secretary. In addition, Modern Slavery risks are reported into Asda’s Compliance, Ethics, Risk and Audit Committee (CERA).