Responsible Sourcing and Human Rights

 As a responsible retailer we are committed to:

·      The principles of responsible sourcing

·      Respecting human rights

·      Promoting the dignity and well-being of everyone contributing to our business.

 

We collaborate across industries and organisations around the world to help combat risks including, but not limited to:

·      Forced and child labour

·      Unsafe working conditions

·      Restricted freedom of association; and

·      Violence, harassment, and discrimination.

Our commitment extends to all individuals impacted by Asda and our subsidiaries’ business activities and relationships, including colleagues, customers, suppliers, workers within our supply chains, and the communities in which we operate. Asda's Human Rights Policy outlines the steps we take to respect internationally recognised human rights and formalises our expectations across our global supply chains.

Improving labour standards is a responsibility that should be shared with all our suppliers. We expect suppliers to operate responsibly, abiding to applicable local labour and employment laws and adhering to our Standards for Suppliers These standards are the cornerstone of our programme and lay out how we expect our suppliers to respect foundational worker rights across the globe. Our Standards for Suppliers are aligned to the ETI Base Code; an internationally recognised code of labour practice.

We monitor and investigate issues in the supply chain, enable colleagues within the business to understand their role in human rights and its impacts, and engage in initiatives to find root cause solutions that can transform entire supply chains. Partnering with our suppliers and their global facilities, we work to mitigate risks, drive remediation, and improve standards for workers via our risk-based approach.

Transparency of the supply chain is key to our approach. We map and collect data on our supply chains through SEDEX, a responsible sourcing management platform. This supply chain data helps us to identify our salient labour risks (further detail below).

Since 2023, Asda has partnered with Open Supply Hub to publicly share supply chain data, helping to drive greater transparency and accountability across our global operations. With over 2,500 accessible data points currently available, users have a comprehensive view of our in-scope supply chain network, including information on suppliers, manufacturing sites, site demographics, workers’ contracts, whether a trade union is present, alongside key compliance information such as when the site was last audited.

The map below shows Tier 1 supplier sites producing Asda own-brand and exclusive products across our Food, Produce, Non-Edible Grocery, General Merchandise and George ranges. We also disclose suppliers providing goods and/or services not for resale including labour providers servicing Asda operations and printing and packaging facilities.

We are committed to increasing visibility of our supply chain and strengthening stakeholder understanding of where our products are made. As our supply chain mapping progresses, we will continue to expand this data to include additional supplier categories and deeper tiers of the supply chain.

Our Transparency Supply Chain Monitoring Policy details how we monitor supply chain compliance with our standards and how we will support suppliers to demonstrate continuous improvement through the provision of guidance and resources.

We currently use third party social, safety, and environmental compliance audits to help us evaluate our suppliers’ compliance to our standards and to manage risk in the supply chain. These audits seek to monitor whether, among other things, workers are properly paid for the work they do, labour is voluntary, working hours are not excessive and are consistent with local laws, and facilities meet health and safety laws and regulations. Whilst social audits still have a place within our programme, we recognise their limitations and the need to move beyond audit to identify root cause. We will continue to work with suppliers to help upskill and improve standards within their facilities through the provision of guidance and access to tools and resources.

Where an issue is identified in the supply chain, we are committed to working with suppliers and third parties to understand the root cause and provide relevant guidance and resources to support thorough investigation and remediation for impacted workers. We ask suppliers to close any non-compliances raised in a social audit within the timelines recommended by the auditor. If this is not possible, we will discuss the circumstances on a case-by-case basis and where there is both commitment and a clear action plan to resolve the outstanding issues, we may agree an extension. We encourage our suppliers to apply the same principles when working with their supply chain. Further examples of our approach to incident management can be found in our annual Modern Slavery and Human Rights Impact Statements, available on the Asda Corporate website.

Transparency of the supply chain is key to our approach. We map and collect data on our supply chains through Sedex, an online responsible sourcing management platform which helps us to identify our salient labour risks. We monitor and investigate issues in the supply chain, we enable colleagues within the business to understand their role in human rights and its impacts, and engage in initiatives to find root cause solutions that can transform entire supply chains. Partnering with our suppliers and their global facilities, we work to mitigate risks, drive remediation, and improve standards for workers via our risk-based approach. We are active members of external collaborations such as the Ethical Trading Initiative (of which we are a founding member), Stronger Together, and the Food Network for Ethical Trade which continue to support their members to drive continuous improvement. Through these partnerships we engage with other retailers, NGOs, Trade Unions, and suppliers to address risks, share best practice, investigate issues where appropriate, and establish initiatives to achieve collective goals.

Transparency of the supply chain is essential to identify and manage our salient risks. Below we have published a list of our Tier 1 Food, Non-Edible Grocery, Produce and General Merchandise sites, supplying Asda branded or exclusive products.

In 2023 we partnered with Open Supply Hub to provide more datapoints publicly. With more interactive and user friendly information we hope to drive accountability and awareness of where Asda operates globally.

Collective action and collaboration are vital to driving improvement into global supply chains and at Asda we work extensively with suppliers through external partnerships to bring about positive change. We regularly perform stakeholder mapping exercises to identify external partners who can collaborate with us to deliver action plans for our salient risks, including NGOs and Trade Unions.

We are active members of external collaborations such as the Ethical Trading Initiative (of which we are a founding member), Stronger Together, and the Food Network for Ethical Trade which continue to support their members to drive continuous improvement. Through these partnerships we engage with other retailers, NGOs, Trade Unions, and suppliers to address risks, share best practice, investigate issues where appropriate, and establish initiatives to achieve collective goals.

For a full list of our active partnerships see our latest Modern Slavery Statement available on the Asda Corporate website.

Asda sources a diverse range of products to meet our customers’ everyday needs through extensive global supply chains. These supply chains include manufacturers, farms, fishing vessels, smallholder producers, and other operations, often spanning multiple countries and involving complex production processes. This complexity can create a range of labour and human rights risks, reinforcing the importance of robust due diligence and responsible sourcing practices throughout our supply chains.

To identify the salient labour and human rights risks in our goods-for-resale supply chains, we use a range of data sources including country-specific risk information from publicly available sources, supplier self-assessment data, social audit findings and reported incidents. Analysis of this data enables us to identify the risks most relevant to our business and where focused action is needed by Asda, our suppliers, and our colleagues to address root causes and drive meaningful improvement.

We prioritise our efforts based on factors such as commodity, geography, potential impact, and the complexity of the issues identified. We are committed to continually enhancing our understanding of these risk areas and working collaboratively to mitigate adverse impacts and help protect the rights and wellbeing of the people who make the products we sell.

**Priority product categories:** Bananas, Berries, Citrus, Stone and Top Fruit, Tomatoes, Plants & Flowers, Tea, Coffee, Fish & Seafood, Meat & Poultry, Textiles – apparel & general merchandise, Wine, Toys, Games, Plastics, Solar

**Priority sourcing regions:** Bangladesh, China, India, Kenya, Spain, Turkey, United Kingdom

Action plans have been developed for these priority categories and sourcing regions with early phases of risk mapping and stakeholder engagement being undertaken to better understand the role Asda can play in delivering change. To further strengthen our approach, we have:

• Introduced a compulsory Tier 1 facility disclosure and site-claiming requirement on the **[Open Supply Hub](https://opensupplyhub.org/)** platform, aimed at driving greater transparency, accountability and local ownership of issues and resolutions. By associating each facility with its site manager or owner, we enable clear visibility to our supply chain and where remediation has the best chance of being effective and representative of rights holder requirements. This new step has been fully integrated into our enhanced **[Transparency Requirements and Monitoring Policy](https://corporate.asda.com/asda-responsible-sourcing-standards)**, which not only rewards supplier best practice, but also identifies and addresses risk with greater precision and measurable/meaningful impact.

• Issued enhanced guidance and clear expectations for suppliers operating in high-risk categories, including the sourcing of tomatoes, paprika, solar, seafood, and cotton. It covers the development of commodity-specific guidance documents that set out due diligence requirements such as transparency of ownership structures, identification of sanctioned individuals, assessment of potential indirect links to State Imposed Labour (SIFL), and mapping the supply chain from cultivation through to processing. We also expect suppliers to implement robust compliance systems with effective monitoring and accountability mechanisms.

 

GNFR supply chains form a significant part of our overall business operations (9,000+ suppliers) and include a wide range of goods and services that support our stores, distribution centres and offices. Unlike traditional product supply chains, GNFR encompasses a diverse portfolio of sectors such as logistics, technology, facilities management, construction, professional services and concessions. As a result, the nature of human rights risks and the rights holders potentially impacted may vary considerably.

To better understand these risks, we undertook a saliency assessment using datapoints across supplier spend, identified sector and industry risks, internal business data, rights-holder proximity, existing mitigations, publicly documented labour rights concerns and rights holder impact. Specifically, we categorised suppliers based on strategic spend, business function and proximity to rights holders as well as customers. We then assessed each category against a range of factors including severity of impact, likelihood of occurrence, existing controls and our ability to influence outcomes. This process has enabled us to recommend areas where enhanced due diligence, further stakeholder engagement and investigation should be a priority.  

 

**Priority GNFR categories:**

·      Franchises, concessions and tenants

·      Parcel, courier and last mile

·      Logistics - freight forwarding, shipping, air freight, road haulage / distribution, warehousing and import / export

·      Facilities management / security

·      Trade, contractors and traders’ persons

·      Contact centres

 

As our understanding of GNFR supply chains evolves, we continue to strengthen our human rights due diligence through additional research, stakeholder engagement, industry collaboration and the development of category-specific risk mitigation plans. This includes exploring the experiences of workers employed directly and indirectly across GNFR operations, including those engaged through subcontracting arrangements, labour providers, franchise models and global service providers. These processes will commence with the areas listed above.

·      Decent Work

·      Forced Labour

·      Gender

·      Vulnerable Workers

·      Worker Representation

 

**Decent Work**

**Priority categories**: Textiles, Toys, Games, Plastics, all GNFR priority categories

**Priority sourcing regions:** China, India, Turkey, United Kingdom

 

Our saliency assessments identified risks associated with wages, benefits and excessive working hours across several sectors. These risks are often linked to labour shortages, subcontracting structures, workforce flexibility/ demand models, sub-contracting and cost pressures within service-based industries.

In logistics and delivery operations, workers may face excessive hours, insecure work arrangements and limited access to employment protections. Similar concerns exist in security, cleaning and franchise operations where workers can experience low pay, unpredictable schedules or limited benefits. Within maritime shipping, excessive overtime, living conditions and limited opportunities for rest have been identified as key risks impacting worker wellbeing and safety.

Workers may operate in hazardous environments involving heavy machinery, vehicle operations, construction activities, waste handling, cleaning chemicals or specialist maintenance activities. The assessment highlighted risks relating to workplace injuries, fatigue, hazardous materials, transportation safety and the physical and mental wellbeing of workers.

Just transitions remain a key focus for Asda as we look at how work, supply chains and our climate are evolving. This lens is vital to include as we assess risks and what constitutes decent work within our GNFR supply chains.

Focusing on our own business practices, we have been delivering training internally to existing buyers and new starters in our George business to improve awareness of the impact of our purchasing decisions.

To strengthen our understanding of these issues, we will continue developing category-specific risk assessments and engagement plans focused on root causes and worker outcomes to put in place steps and controls to limit rights holder impacts.

**Gender**

**Priority categories:** Textiles, Berries, Plants & Flowers, Tea, Stone fruit

**Priority sourcing regions:** Bangladesh, India, Kenya, Spain

Within global supply chains, women face additional barriers of accessing decent work and fair benefits. Owing to the nature of the work and contract terms in certain supply chains, women may often have limited options beyond precarious employment and are unable to access their rights, represent their views, and often go unnoticed when trying to address imbalances and issues. Our aim is to promote a supply chain where all workers are free from discrimination and share equal rights and opportunities.

­­To help obtain a detailed understanding of how gender responsive we are as a business, in 2022 we worked with Womenwin to undertake a gender assessment. The gender assessment provided a baseline understanding of where we are as a business regarding gender-responsive due diligence and gender-responsive policies and practices. We have received feedback which we have used to develop a road map to implement further due diligence within our supply chains. The first step in our roadmap was to create a specific Gender policy to clarify our position and communicate our expectations of suppliers on this topic. This policy is due to be published in 2024.

Transparency is an important step to understanding gender-related issues. This is an area that is traditionally underrepresented in terms of data. With the help of suppliers and partners we intend to improve how we gather relevant gender-disaggregated data with a strong emphasis on worker voice to support our assessments and subsequent prevention and remediation measures.

**Forced labour**

**Priority categories:** Berries, Meat & Poultry, Textiles, Franchises, all GNFR priority categories

**Priority sourcing regions:** China, United Kingdom

 

Our assessment identified risks of forced labour and labour exploitation as one of the most significant human rights risks within the GNFR supply chain. Risks are particularly prevalent in sectors characterised by subcontracting, temporary labour, labour intermediaries and recruitment of migrant workers.

Areas such as last-mile delivery, logistics, warehousing, facilities management and security can create heightened risks where workers may experience excessive recruitment fees, debt bondage, document retention, wage deductions, sub-contracting, or lack of oversight across complex labour supply chains. Similar concerns exist within franchise and concession models where responsibility for recruitment, which can include migrant workers, and labour management is often delegated to third-party operators.

Where risks are identified, we will work with suppliers and partners to build capacity, improve oversight, strengthen remediation processes and ensure workers have access to safe and effective channels to raise concerns.

Please see our latest Modern Slavery Statement for a detailed update.

**Worker Representation**

**Priority categories:** Berries, Stone fruit, Toys, Games, Plastics, Solar, Logistics, Facilities management/security, Concessions & Tenants

**Priority sourcing regions:** China, Spain, United Kingdom

 

We recognise the importance of workers being able to raise concerns, access remedies and participate in decisions that affect their working lives. This can include their right to join, form, or assist a trade union. Asda requires all suppliers to respect workers’ rights to freedom of association and collective bargaining in accordance with applicable laws and practice (as set out in our Standards for Suppliers). It is therefore important that we are aware of circumstances where workers in our supply chain face barriers to effective worker representation.

Through our responsible sourcing programme, we collect data to identify the availability of trade unions and worker committees in our supply chain. In 2023 we improved the transparency of this information through our partnership with the Open Supply Hub; we now include whether a trade union is present within our published sites.

There are areas within our supply chain where we have identified an absence of independent representation available to workers. These challenges can be particularly pronounced in fragmented workforces, remote working environments, and highly subcontracted sectors where workers may not have access to recognised worker representatives, trade unions or trusted grievance channels. Maritime shipping operations present additional challenges due to the remote nature of work and the complexities associated with international jurisdictions.   

We will continue to engage with suppliers to better understand how worker concerns are raised and resolved and encourage the implementation of effective worker representation structures. We will also explore opportunities to collaborate with industry initiatives and worker-focused organisations to improve our understanding of worker experience across our supply chains, including reporting on where worker representation may be functioning well, or relatively inconsistently.

For example, in partnership with ES3G, we are piloting a real time worker voice tool in our George and General Merchandise supply chain to obtain live, direct feedback from workers about their working conditions. Outputs of this project will be reviewed against the labour standards data we collect through our responsible sourcing programme to identify any gaps we need to explore. We will continue to use our programme data to focus our activity on geographies and commodities that present the biggest gap and map Trade Unions and other third parties who can support us to improve representation in these areas of the supply chain.

**Vulnerable Workers**

**Priority categories:** Textiles, Toys, Games, Plastics, Bananas, Berries, Plants & Flowers, Tea, Stone fruit, Meat & Poultry, Fish & Seafood, all GNFR priority categories

**Priority sourcing regions**: Bangladesh, China, India, Kenya, Spain, Turkey, United Kingdom

Many industry sectors rely on workers who may be more vulnerable to labour exploitation due to their employment status, migration status or working arrangements. These groups can include migrant workers, agency workers, temporary workers, low-paid workers and workers engaged through subcontracting models. We recognise that vulnerabilities can be compounded when workers have limited understanding of their rights or are dependent on labour providers for accommodation, transport or immigration sponsorship.

Through our ongoing work with our external partners, we are continuing to enhance our knowledge around the risks vulnerable workers face. For example, we have identified increasing instances of seasonal, migrant workers entering the UK who have been charged excessive recruitment fees by third parties who have infiltrated the labour supply chain, have limited understanding of their rights, and enter employment with unmatched expectations of their working hours, pay and working conditions. To address these issues, we are supporting Just Good Work, an initiative that provides migrant workers with critical information to migrate to the UK and find fair and safe work. We also continue to be active members of the Seasonal Worker Scheme (SWS) Taskforce, a collaboration of industry trade bodies, retailers, growers, recruiters and non-profits focused on implementing tangible actions to help safeguard and ensure access to workers’ rights in UK horticulture.

Our GNFR saliency assessment highlighted concerns within logistics and facilities management / security services where precarious work, temporary contracts and high labour turnover can increase worker vulnerability. Where workers are remote in location, or their ability to raise grievances may also be restricted the risk of rights holder impacts increases

Worker vulnerability can increase when working in a hazardous environment. We can use our risk assessment data to identify suppliers who demonstrate best practice, comprehensive management systems for health & safety including training, storage of hazardous materials and fire safety plans. We will then promote and share this best practice with other suppliers who we identify as needing additional support in this area. An example of further due diligence is illustrated through our engagement with Nirapon, a non-profit organisation focussing on improving and maintaining high safety standards and management systems in Bangladesh facilities and The International Accord in Pakistan. These initiatives ensure the health and safety of vulnerable workers improves in markets we know have heightened risks.

In 2023 we started working alongside 8 other UK retailers and IDH, with a collective goal to close the living wage gap within our banana supply chains by the end of 2027. We are working pre-competitively to reduce the supplier burden and aim to promote tools and mechanisms that will help to close the living wage gaps. Our first year was focused on gathering supply chain data to provide an understanding of our current living wage gap. The focus for 2024 has been on the validation audits and working through the data to help inform our strategy and approach to closing any gaps identified.