S Y S T E M S F O R

S U C C E S SA SUSTAINABILITY REFERENCE GUIDE

FOR M&S FOODS SUPPLIERS

E T H I C A L

H O W T O U S E T H I S T O O L K I T ??

This toolkit is developed from all the best practise that has been captured from the M&S supply base and clearly shows the journey from starting out developing a strategy through to a comprehensive integrated approach. We know that when it comes to developing a sustainability and human rights strategy there is no simple one size fits all so this toolkit is not designed to be a prescriptive guide; but instead a reference guide for your business to learn from others, and help develop your own strategy that works for your business.

This toolkit:

• Is not designed to replace M&S policies

• Contains helpful links to find out more

• Is not a prescriptive list, use it as a guide to develop your own strategy

• Can be used to benchmark your current processes and approach

M&S has been working proactively with suppliers on issues of ethical trade, environmental sustainability and lean manufacturing since the launch of Plan A in 2007. Over the years, through our Supplier Exchange programme, we have been lucky to capture best practise from experts and M&S suppliers which has helped M&S food suppliers drive forward positive change in these areas within their businesses.

We have witnessed great successes from significant waste reduction programmes, through to fantastic employee engagement and significant cost savings due to lean efficiencies. This toolkit contains case studies from a variety of organisations of different scales, all facing different challenges and coming up with different approaches to overcome them. We hope that this toolkit will inspire you to look again within your own organisation and think – what can you do to continue to push this agenda on and ensure your business is fit for the future?

I N T R O D U C T I O N

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There is no doubt that people are a business’ biggest asset and often are the reason why a company will fly or fail. Marks and Spencer has had a strong focus on people, human rights and ethical trade for decades, working on significant programmes in small holder supply chains, factories and on farms. We know that there is often a direct link between how well people are treated, the quality of the goods we sell and the reliability of the supplier.

B U S I N E S S B E N E F I T S O F E T H I C A L I M P R O V E M E N T S

“ Over the past 10 years I have seen many M&S suppliers demonstrate significant commitment to the helping their staff, their biggest asset, achieve company goals and objectives, in improved working conditions. ”

Caroline Hughes – M&S Ethical Validator from 2016 to 2019

Many of our suppliers have experienced significant business benefits from making improvements in this area, including1:

• Reduced absenteeism

• Reduced costs of recruitment because of improved retention, internal progression and becoming ‘employer of choice’

• Cost savings from improved time keeping

• Savings gained from less overtime worked (therefore fewer premiums paid) and also reduced use of temporary labour and reducing where there had previously been situations of over-manning

• Reduced cost of H&S problems, time lost from accidents and insurance premiums because of improved H&S record

• Improved staff management, motivation, loyalty and cohesion, all contributing to improved performance, productivity, quality and innovation

• Improved compliance and relationships with customers and local community

• Improvements to quality and performance through better planning, recruitment, induction, training and assessment

• Reducing sick absence and accident rates

• Better worker representation and progression opportunities, measured through staff surveys

• Considerable improvement in staff retention and engagement which has been particularly important within the competitive UK manufacturing sector in a tightening labour market.

ETHICAL

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1 B U S I N E S S B E N E F I T S

1 Findings of research commissioned by M&S and carried out by Ergon which included an extensive study of a few key M&S Food suppliers to quantify the business benefits of sustainability improvements over 5 years (2007-2012).

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1 BUSINESS BENEFITSEthical improvements can have quantifiable business benefits.

2 HUMAN RESOURCES MANAGEMENTA HRM is a formal framework to manage your workforce, this section will help you set strong foundations for your business.

3 RESPONSIBLE RECRUITMENTRecruitment must be professionally and ethically managed at all stages, for agency and permanent staff.

4 AGENCY LABOUR MANAGEMENT This section will build on responsible recruitment practises to help you effectively manage agency labour.

5 EQUAL OPPORTUNITIES AND INCLUSION Everyone in your business must be treated equally and with respect and have opportunities to progress.

6 HEALTH AND SAFETY Every person on site must feel safe when they are on site, this section will help you to ensure your workplace is a safe and healthy environment.

7 MANAGING WORKING HOURS Working hours must be properly managed to meet legal requirements and can help improve worker productivity.

8 FAIR REWARD Everyone must receive fair pay for the work they do.

9 REPRESENTATION AND ENGAGEMENT This section will give you the resources to enable two way communication between workers and management.

10 GREAT PLACE TO WORK Outlines how to ensure your business is moving beyond compliance to create a great place to work.

11 TALENT MANAGEMENT All workers must have equal opportunities to progress and develop.

12 YOUNG WORKERS This section provides tips and resources on offering work experience to young workers.

13 HUMAN RIGHTS This section provides an overview on Human Rights Due Diligence and key resources and learnings on how to tackle modern slavery.

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Strong Human Resources Management is one of the foundations of good business, since one of your biggest competitive advantages are the skills and productivity of your workers.

Human Resource Management (HRM) is the term used to describe formal systems devised for the management of people within an organisation. If there are systems in place to ensure all your workers are well looked after, are able to thrive and grow, and that they properly understand what is expected from them, then your business will benefit from their commitment to achieving your business’ goals.

2 H U M A N R E S O U R C E S M A N A G E M E N T

KPIs, MEETINGS to review and track progress

and set actions

KEEPING TRACK of changes to legislation

and requirements

PEOPLE STRATEGY AND HR MANAGEMENT THAT DELIVERS IMPROVEMENTS

for staff and business (including gender, diversity and agency work)

SENIOR MANAGEMENT responsible for HR

POLICIES set, communicated, trained and applied

HR MANAGEMENT EMBEDDED AND ALIGNED

across the business

REVIEWREVIEW

S U G G E S T E D S T E P S F O R D E V E L O P I N G G O O D

H U M A N R E S O U R C E S M A N A G E M E N T S Y S T E M S

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o Proactive HR that delivers improvements to the business, including trialling and adopting new and innovative approaches (such as technology systems) to deliver a better and more supportive workplace for workers that meets the changing world of work.

o HR collaborates and shares best practice internally, to share knowledge, experience and relevant changes, across the business/group and also with other suppliers.

o HR networks externally with industry groups and key stakeholders and brings new ideas and best practice back to the business.

o Leading excellent HR management systems with HR professionals qualified to an appropriate level (e.g. CIPD level 7), having initiated and implemented innovative projects and activities that have made a demonstrable difference for the workforce (surveys, improved retention/attendance etc).

o Gender and diversity. Proactively reviews organisational structure, ensuring roles at all levels reflect the workforce in terms of gender and diversity.

o Proactive Ethical Labour Standards & Human Rights Management, with HR systems linked to and supporting the delivery of relevant UN Sustainable Development Goals. Involved in external ethical trade and human rights activities and training.

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LEGAL/MINIMUM REQUIREMENTS

o Meeting local and national legislation and keeping up with changing employment legislation. In the UK this includes the Equality Act, Agency Workers Regulations and UK Immigration Policy as well as the General Data Protection Regulations (GDPR).

o HRM systems are owned and managed at senior level including having a senior manager responsible with the skills and experience in HR needed (or access to professional advice). This person must be able to manage worker communication, agency management and on-boarding new starters. Discussions on HR systems take place at senior management level, where HR policy, KPIs and direction is set.

o Managers understand their roles and responsibilities, with clear documentation provided and clarity on how roles fit into organisation structure.

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o Up to date and embedded Basic HR policies which are clear, documented, visible, understood and communicated to all levels.

o Responding proactively to required changes in legislation (Employment, H&S, Modern slavery) and also to customer requirements. This means keeping actively up to date and discussing changes at senior management meetings, with prompt actions agreed.

o Using basic HR KPI measurements to drive HR decisions and actions; which are measured on a regular basis, used to track site performance, get feedback from workers and highlight areas for investigation and are discussed at management meetings to agree actions.

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o A clear approach/strategy to managing people is developed and agreed with senior management.

o The HRM system is effective, comprehensive, integrated and embedded. This means processes are aligned across the business and are embedded as ‘the way you do business’, including effective performance management down to workers, effective workplace communications, management of conflict and agency management partnerships.

o HR ensures worker privacy is considered and safeguards are built into policies and practices.

o HR KPIs are business relevant and used in a proactive way, embedded in the decision-making process and driving action plans. KPIs are reviewed regularly and amended as needed.

o Organisational structure and roles are reviewed and updated to meet the needs of the business, including gender balancing and promoting diversity.

o Internal ethical labour standards are effectively managed.

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NOEL - Adapting the HR Model to meet business needs Noel is one of the leading companies in the Spanish meat sector, specialising in high quality meat and sausage products. Over the last 10 years they have tripled the size of their workforce and the complexity of the business has increased. The structure of their organisation was not ready to face these changes, and it resulted in some challenges and inefficiencies. The company has 1,500 employees in an area of about 60,000 inhabitants and with an unemployment rate of about 8%.

ACTIONS TAKEN In response to these challenges Noel made the decision to undertake a comprehensive Project, to ensure that the Human Resources Function could contribute real value to the achievement of the Company’s challenges and objectives. The HR Project is structured in 3 phases:

Phase 1: 2017-2020. Design & Implementation of the HR Model defined for NOEL Alimentaria.

• Redefined their organisational structure with the aim of ensuring the salaries and conditions for all the professional positions were coherent internally and competitive externally.

• Worked to develop HR processes that help them to develop talent in an objective way, and ensure they have the skills they need for the present and the future. This has included a more formal process to evaluate job requirements, employees’ capabilities and competencies and to define individual development plans, talent matrices and performance appraisals.

• Improved internal communication with employee surveys and proactively managed diversity.

• Formal definition of salary policy and salary review process, resulting in increased salaries as employees achieved their objectives, aiming to increase employees’ commitment and satisfaction.

Phase 2: 2021. Consolidation & Measuring.

In this phase the company aims to embed the implementation of the adjusted HR model and cycle so that it works well with the Business Cycle, ensuring that all staff are aware of what they need to do and at what time of the year each process needs to be

managed. The other area they aim to work on is to ensure the impact of HR on the business is measured and tracked through an HR Dashboard.

Phase 3: 2022-2025. HR dashboard in place and value creation.

Starting in 2022, and on an annual basis, KPIs and progress will be measured, against the baseline situation, in order to ensure the achievement of the objectives (2025), in each of the areas.

RESULTS • Preliminary results indicate a reduction in

absenteeism of about 10% and the company is currently working on refining their KPIs to increase the reliability of their statistics. They are also working on measuring the change in turnover.

• In terms of progress, in mid 2020 they had a clear HR Model and almost all processes had been designed and many of them already implemented. A transformation of the Company’s culture is taking place towards a proactive HR management that in the long term ensures business continuity and growth.

LEARNINGS • They found that good engagement with all

departments using the processes was key as they needed to own it and use the tools to develop their teams and manage present and future needs.

• The company believe that it is essential for HR departments to be involved in the strategy of the company and be clear on customer needs, so they can ensure that the capabilities of employees will support the future direction of the company.

C A S E S T U D Y

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Recruitment is professionally and ethically managed with clear processes and standards from sourcing labour to on-boarding. This includes application and selection processes, right to work checks, ensuring workers fully understand conditions of employment before and after entering the workforce, effective induction and fair probation processes. With Modern Slavery a growing issue businesses need to understand that how people are recruited must be carefully managed to ensure there is free choice, freedom of movement and no worker pays for a job. How this applies to agency labour is expanded in the Agency Labour Management Section.

B E S T P R A C T I C E F O R R E S P O N S I B L E R E C R U I T M E N T

APPLICATIONSOpen to all including internal and agency

CLEAR UNDERSTANDING OF T&Cs

and what role involves

RIGHT TO WORK CHECKS

EFFECTIVE INDUCTION PROCESS

FAIR PROBATION PROCESS

EASY ACCESS TO INFORMATION about the workplace

CONTINUED EMPLOYMENT

ENTER EMPLOYMENT

PRIOR TO EMPLOYMENT

GOOD RECRUITMENT POLICIES, PROCESS

AND PRACTICES

RESPONSIBLE RECRUITMENT RISK

ASSESSMENT

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S U G G E S T E D S T E P S F O R E N S U R I N G

R E C R U I T M E N T I S R E S P O N S I B L E STEPPING BEYOND

o Well established and understood recruitment process, with a high level of transparency about what it is like to work there, which could be communicated through the company website and/or facebook page, worker spokesperson talking to potential recruits, handbook, DVD showing worker experience and factory tours before signing the contract. This is especially important for workers from abroad.

o Embedded Responsible Recruitment Policy that includes the ‘Employer Pays Principle’, which means the cost of recruitment should not be borne by the worker and if any fees are identified, the full cost should be re-imbursed to the worker.

o Embedded Responsible Recruitment Risk Assessment carried out on an annual basis, fully aware of modern slavery risks, proactive actions agreed and implemented.

o Collaborations with customers and other suppliers in tackling issues of modern slavery in direct recruitment and labour provision.

o Innovative and creative solutions are sought for resourcing challenges, to ensure quality skilled labour is recruited, prioritising upskilling, retention and re-training (especially during re-structures).

LEGAL/MINIMUM REQUIREMENTS

o Recruitment process meets local and national legislation

o All workers receive a written contract in a form they can understand (in line with current employment legislation and GDPR or local law equivalent).

o Signed contract for each worker on file wherever possible and workers have a copy of their contract.

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STEPPING IN

o Basic recruitment process including interviews and job descriptions.

o All workers get the opportunity to apply for job vacancies. Vacancies need to be advertised internally (e.g. notice boards, news bulletins, supervisor briefings) and all workers (including agency workers) understand the application process. Agency workers should understand the temporary to permanent process.

o Effective HR process to manage ‘right to work’ checks. There is a formal process to check all workers’ ‘right to work’ before they start work by checking documents (e.g. passports, visas, residence permits, ID cards) or via online Government checking services to establish a statutory excuse, to keep a copy of these checks in personnel files and to have an ongoing process to monitor expiry dates.

o Effective induction process is in place, which is crucial to worker safety and effectiveness. This needs to be in a format all workers understand and should include company overview, site rules and regulations, policies and procedures, modern slavery resources, introduction to worker/TU reps and contacts for further info. Training records should be kept showing attendees.

o Fair probationary process, with a clear documented policy, during which appropriate support and training is given for all workers (permanent and agency). A clear and transparent review is given at the end of the period. If a new workers’ performance isn’t meeting expectations, supervisors make every effort to give support, explanation and training to enable them to improve. The trial periods are based on the expectation of time needed to reach full skill competency.

2 STEPPING UP

o Easy access to information about the workplace for all workers. For new workers this should include a copy of the site rules and how to use the confidential complaints mechanism (in accordance to your business language policy). Other ideas could include posters on site and DVDs in the canteen re-emphasising site rules/H&S.

o Workers understand their T&Cs of employment prior to joining and if employed abroad, understand the job role before travelling to the place of work. This requires more deliberate effort where English (or relevant local language) is not first language (see the ‘Effective Communication for Multi-Language Workforces’ Toolkit in the resources section). Written contracts/terms of employment provided before starting work (translated where necessary), for workers within and outside the country of employment. If a separate company is used to assist in recruiting from abroad, check the company has effective systems to do this.

o Proactive management of entitlement to work, so that it is embedded with proactive checks of data so that dates are flagged, trends identified and action taken. Keeping up to date with issues and legislation, working proactively with relevant authorities on identified issues.

o Recruitment Policy in place which states no recruitment fees are paid to agencies or down the labour supply chain.

o Formal recruitment procedure and practices that ensure interviewers have the right skills, there is a interview guide/checklist for consistency, written job descriptions and opportunities to ask questions in interviews.

o Detailed manpower plans support recruitment plans, so that labour requirements are analysed using detailed capacity data, commercial forecasts and historical data. Short and medium term labour plans are developed with core manning levels, temporary and agency worker requirements and maximising the retention of existing workers.

o Responsible Recruitment Risk Assessment is completed, bearing in mind the potential Modern Slavery risks in the recruitment process, with the resulting actions being implemented.

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USEFUL LINKS AND RESOURCES FOR RESPONSIBLE RECRUITMENT

The Responsible Recruitment Toolkit (RRT). Responsible Recruitment is a strategic priority for M&S, understanding that this can be a crucial step in tackling labour exploitation. In 2019 M&S became a Founding Sponsor of the Responsible Recruitment Toolkit. This enables businesses throughout our global supply chain to gain free access to an online capacity building and self-assessment tool with supporting training on embedding ethical and professional recruitment and labour supply practices. https://responsiblerecruitmenttoolkit.org/

Effective communication for multi-language workforces. M&S worked with Co-op and partnered with nGaje and allianceHR to develop this practical toolkit which will be helpful across many sections of this toolkit and is a useful guide on how to effectively communicate with a multi-language workforce during recruitment and induction. https://www.stronger2gether.org/product/effective-communication-with-a-multi-language-workforce-toolkit-for-employers-and-labour-providers/

Leadership Group for Responsible Recruitment - Institute for Human Rights and Business M&S is a member of this leadership group, which is a collaboration between leading companies and expert organisations to drive positive change in the way that migrant workers are recruited. Part of this initiative is to apply the ‘Employer Pays Principle’, which is a commitment to ensure that no worker should pay for a job. It is increasingly being adopted by companies across a range of industry sectors and locations and is an essential element of combatting exploitation, forced labour, and trafficking of migrant workers in global supply chains. https://www.ihrb.org/employerpays/leadership-group-for-responsible-recruitment

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WORLD WISE FOODS – Recruitment in South East Asia Responsible recruitment practices are key to addressing risks for migrant workers. World Wise Foods has a cluster of supplier partners in SE Asia where recruitment fees are the norm. To begin to address this issue, the company developed a Human Rights policy which includes specific requirements that require supplier partners to understand the risks and strengthen recruitment policies and procedures.

Reviewing compliance to the policy collaboratively with supplier partners has given World Wise Foods a clear understanding of where recruitment risks are, and has given supplier partners clarity on what the end goal is, as they work towards compliance. Translating the policy into Thai has ensured the requirements are accessible to the HR Managers who are implementing change in this area.

BRITISH PEPPER AND SPICE – Diverse routes give recruitment success British Pepper and Spice (part of the SHS Holdings Group) is the leading manufacturer of herbs and spices in the UK. In a highly competitive job market they introduced a new Sourcing Model to improve their recruitment, with diverse methods including a new Partnership Agreement with recruitment agencies, a direct online method as well as utilising their own website, recommend a friend scheme and a partnership with the job centre ‘Working Together’.

Their site at Chandlers Ford has a long history of working with agency suppliers and moving people from temporary to permanent positions. As the (expected)

impact of Brexit was publicised they found the available pool of temporary labour that was willing/able to move to permanent positions was diminishing. So they formed a relationship with the local Job Centre, inviting Job Coaches to the site and Factory Managers giving presentations to local Job Centre Plus groups.

As a result, they filled all their available positions and their Time to Fill vacancies was reduced by 36%, with a cost saving of over 17% through utilising direct recruitment methods. They successfully recruited 35% of their employees at the site through this route, with two employees going on to become Team Leaders over a 3 month time period.

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4 A G E N C Y L A B O U R M A N A G E M E N T

Effective management of agency labour means ensuring compliance with recognised standards, risks are assessed and mitigated, and there is a drive to continually improve the working lives of agency workers. To get this right, it’s important that you ensure you have the right support and advice through a member organisation such as a relevant trade association.

Since the agriculture and food manufacture industries are highly seasonal, the fluctuating demand for labour means that many of our suppliers have a heavy dependence on temporary and agency labour, often organised and provided by Agency Labour Providers (LPs). Many of our suppliers have worked hard to increase the transfer of workers from temporary to permanent positions and to reduce the dependence on agency labour, but it is still a very major feature in the industry. The fact that these workers are often not

directly employed by the supplier means that they

may be vulnerable to exploitation, especially if the

relationship with the LP is not managed carefully

and dutifully.

All workers involved in marking or growing a product are treated with respect and dignity, whether or not they are directly employed by the supplier. This has been

a key area of action and progress for our suppliers in

recent years, as legislation and provisions have increased.

USEFUL LINKS AND RESOURCES FOR RESPONSIBLE RECRUITMENT

• ILO Fair Recruitment initiative provides information and resources on fair recruitment of migrant workers including recruitment fees. https://www.ilo.org/global/topics/fair-recruitment

• IHRB - Dhaka principles for Migration with Dignity. https://www.ihrb.org/dhaka-principles

• The International Recruitment Integrity System (IRIS) Standard is designed to serve as a practical tool and guidance for enabling labour recruiters and employers to integrate ethical recruitment principles into recruitment related management systems, procedures, codes of conduct, and social sustainability initiatives. (The Institute of Migration (IOM) is the leading inter-governmental organization in the field of migration). https://iris.iom.int/iris-standard

• Association of Labour Providers (ALP). https://labourproviders.org.uk/

• International Labour Organisation’s Global Action to Improve the Recruitment Framework of Labour Migration (REFRAME). www.ilo.org/global/topics/labour-migration/projects/reframe

• Best Practice Guidance on Ethical Recruitment from the Interfaith Center on Corporate Responsibility. www.iccr.org/sites/default/files/iccrsbestpracticeguidance ethicalrecruitment05.09.17_final.pdf

• Verite’s Fair Hiring Toolkit. http://helpwanted.verite.org/helpwanted

Video on The ILO General Principles for Fair Recruitment https://www.youtube.com/watch?v=omPloHkybZA& feature=emb_logo

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ETHICAL

STEPPING BEYOND

o LP(s) and any 3rd party sourcing agencies adopt the ‘Employer Pays Principle’ (no charges directly or indirectly of any recruitment fees or costs to workers)

- LP provides supplier with all costs involved in the recruitment process and has a process in place to reimburse current and ex-workers that have been charged fees or costs

o Clear manpower plan, to enable the majority of workers to benefit from permanent secure jobs

- Documented monitoring and analysis of agency vs. headcount that is reported at senior management meetings

- If business increases, evidence to show increase in core headcount (as % of total workforce)

o Improvements in ethical labour standards are actively driven by the supplier and LP in partnership, to achieve ‘beyond compliance’

- Including more consistent working hours and employment for agency workers

o Leading role in effective agency labour management - Initiates and implements innovative approaches to manage

agency worker issues and shares best practice with other companies including being members of multi stakeholder initiatives

o Accredited LPs are used - Supplier and LPs can demonstrate they are operating to

recognised global standards

5 M&S recommend using the Sedex E-Learning tool for training on FPC Guidance. Specific country guidance may be found through local ethical trade organisations such as the Spanish Ethical Trade Forum.

2 https://www.gov.uk/agency-workers-your-rights/basic-information-you-should-receive3 https://labourproviders.org.uk/resources/?_sft_filed=resources-for-labour-users

https://labourproviders.org.uk/services/complyer-agency-labour-audit-tool/4 HMRC guidance on the use of labour providers and advice on due diligence, “any business charging less than the suggested hourly cost of supply suggest unsustainable practices”.

Further information can be found in the Association of Labour Providers’ (ALP) Charge rate guidance, updated annually. Search the site for ‘charge rate guidance’ to find the lasted www.labourproviders.org.uk

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LEGAL/MINIMUM REQUIREMENTS

o Meeting local and national legislation and acting as a responsible user of agency labour

- Screening process to check standard of labour provider(s) (LPs)

o The H&S of agency workers is protected. A risk assessment (including mitigation measures) and a signed agreement is in place for each LP

o Compliance with Agency Worker Regulations (AWR) or equivalent local law

- Signed agreement with each LP which clearly defines AWR responsibilities (or equivalent local provision) of both parties

- Agency workers receive worker employment rights from Day 12 - Agency workers receive equal treatment after 12 weeks to those

directly employed

o Terms of employment - Key Information Document (KID) and details of each assignment

given to agency workers before work starts or when an assignment is offered (e.g. an assignment schedule). (This is a legal requirement in the UK3. Compliance with relevant local laws for non UK suppliers)

o LPs fully understand and comply with local law on working hours (Working Time Regulations for UK)

- This includes maximum working hours per week, rest days, breaks, night working, compensatory rest

- Opt outs are voluntarily signed if workers are prepared to work over 48 hours (UK only) and overtime is paid at a premium rate of 125%

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STEPPING UP

o Proactive Agency Labour Management. Supplier specifies number of LPs used and for each one has contract, SLA and KPIs in place.

o Detailed labour forecasting in place, which is shared with LP(s) - This could include core manning levels agreed for peak and non-peak,

covering short, medium and longer term labour needs, giving regular updates to the LP(s)

- LP(s) provide detailed plans of how they will supply required labour - Process for changing the plan is agreed, including minimum notice periods

o Effective management of working hours with the support of the LP(s) - LP tracks hours and manages to the legal levels. (For the UK: max work

week 60 hours and only more than 48 hours if workers have voluntarily signed an opt out)

- Process in place to flag any situation in which, ‘if a worker continues to work at this rate they will go over 60 hours’ then action is taken to avoid over 60 hours working

- If there is an ‘exceptional circumstance’ this is agreed and signed off by a senior manager

o Proactive temporary to permanent management - Clear documented policy and process for agency workers to apply

for permanent roles, effectively communicated to agency workforce (e.g. notices, briefings) in key languages

- Temporary to permanent review reports held for all agency workers who have completed an agreed period of working at the site

o Efforts to increase average hours of work for agency workers (both supplier and LP)

- Where possible agency workers given guaranteed hours pw, even if only for a fixed period

- Where zero hours contracts are used, agency workers are given as much notice as possible when required to work and LP has very good communication links with them to keep them informed

- Minimum hours agreement included in signed SLA

o Written minimum notice periods agreement in place with LP(s) - Documented list of all exceptional circumstances in which 24hr notice

could not be given and analysis of reasons for exceptional circumstances and actions to mitigate in the future

o Modern Slavery awareness training and understanding is embedded - Key LP(s) staff (operational and senior managers) attend training - Supplier and LP(s) have a clear and confidential procedure for raising

issues related to modern slavery

o Supplier is not dependent on agency labour and this does not replace regular employment, instead agency workers are used to cover absence, holidays in non-peak and additional labour in peak periods

- Peak and non-peak periods are defined - In non-peak, reasons for using agency are identified and daily attendance

data shows agency is used just for absence /holiday cover or exceptional circumstances

o Opportunities are available for agency workers to develop - LP(s) have discussions with workers about development including

training and apprenticeships where possible

o Provision of accommodation and transport meets required standards - Supplier knows the type and standard of accommodation and transport

provided, understands the regulations for transport provision and accommodation5 and audits LPs to these requirements

- LP has procedures to regularly check accommodation and transport provision and resolve issues. Supplier also carries out respective checks.

o Ensure LP(s) are effectively dealing with bullying and harassment - Supplier has discussed bullying and harassment issues with LPs - LPs have written procedures for handling issues of bullying and

harassment and can give examples of where it’s been effectively and appropriately dealt with

- LPs have evidence to show supervisors have received training (internal or external)

- LP(s) reassures individuals that there will be no repercussions when they give feedback or raise complaints

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STEPPING IN

o Terms of business and Service Level Agreement (SLA) agreed and signed with each LP and both parties have copies

- Minutes kept of update meetings including progress on issues identified and further actions

- ETI Base Code communicated to LPs and they are required to meet those standards

- SLA covers recruitment of workers and the individuals/organisations involved at every step

- Non-discriminatory recruitment methods - Mechanisms to detect and prevent finders fees and bonded labour

(workers trapped in work due to debt to the recruiter or LP) - Commitment to inform GLAA of concerns regarding bonded labour - SLA covers arrangements for induction training, how payment is made

and how cost is allocated between LP and supplier

o LP(s) have effective HR systems and a formal process to check ‘right to work’ where necessary and understand its importance

o Effective induction and training for all agency and temporary workers to operate safely and to the required standard

- Evidence of this is kept, such as a form signed by workers, showing training received

- Training records for all workers and assessment of competency for different roles

- The training process/programme is company specific, documented and is reviewed at least annually to assess effectiveness and identify improvements

- Same level of training as permanent staff for same task

o Your business conducts regular on-site visits and audits of your LP(s) - Written visit reports covering compliance to the GLAA licensing

standards (in the UK), issues identified, actions agreed to address these, KPIs for LP and supporting photographs

- Regular update meetings to review progress

o Agency worker views are known and acted upon, with issues raised being effectively addressed and any changes/progress communicated to the workforce

- TU/Workers Committee/Employee forum effectively represents agency workers and reps actively gather their views. Meeting notes that show the issues raised and the reps give feedback to agency workers

- LP and supplier hold surveys to understand agency worker views - Senior manager with HR responsibility meets regularly with a rep from

the LP

o Modern Slavery Training completed by HR staff

o LP has completed a robust risk assessment to identify and address any examples of potential modern slavery risks, with evidence of actions taken

o Commercial terms support the LPs to operate in a legal and ethical way4 - This means the charge rate agreed covers statutory charges (in the UK

this includes NMW/NLW, EERs NIC, Statutory holiday, apprentice levy and pension), LP overhead costs and service charge, sustainable net margin (according to their legal equivalent)

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M A N A G E M E N T O F A G E N C Y L A B O U R

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K E E P I N G T R A C K

It’s important to keep track of where your business is at on agency labour management. One way of doing this is keeping data on the following and setting KPIs for your business.

% OF PERMANENT AND TEMPORARY

WORKERS

% OF WORKERS ON SHORT HOURS/NON-GUARANTEED (aiming to reduce this and increase number

and consistency of hours)

AGENCY IN NON-PEAK

AGENCY IN PEAK

NUMBERS OF INCIDENTS

when agency workers worked

over 60 hours

NUMBER OF AGENCY WORKERS

transferring to direct employment

over the past 12 months

YOUNG’S SEAFOOD – Agency management and Temporary to Permanent process Young’s have a strict policy of ‘agency parity’ and their ultimate vision in this area is to reduce reliance on LPs and transfer workers into permanent employment with the company to give job security, enabling them to plan their lives better.

All agency workers are on the same pay scheme as their employee counterparts. They have the same training and break allocation as the permanent workforce, are able to utilise the same company facilities and are included in all the company activities and rewards. They are encouraged to utilise the company’s ‘Safecall’ facility for confidential whistle blowing. The company actively discourages the use of zero hour contracts and all workers, including agency, are paid through bank transfer and have their payslips emailed to them. Once on site, the agency workers are under the company’s H&S responsibilities and each worker is required to sign and complete the risk assessment attached to each SOP. Agency workers are encouraged to become part of the H&S Committees, the Safety Champion programme and the employee forums. In the survey carried out by the LP, 80% of the agency workers are happy with working at Young’s.

The company audits their LPs twice a year, announced and unannounced and this includes interviewing workers,

checking payslips, induction details and ID copies etc. They have meetings with the Agency Provider every 6 weeks with a weekly email to resolve any issues. A system of ‘buddies’ has been set up to accompany new workers, to check in with agency workers at the start of their shift and provide training and deal with any queries. Modern Slavery training has been carried out to help line managers identify at-risk workers

and to report potential issues.

They also take a proactive stance when it comes to progressing workers from temporary/agency work into permanent direct employment. They assess and keep track of the % of agency workers and set a target (generally 5%) that they do not want to exceed. The senior management and HR team assess and discuss the business requirements ongoing to understand where the opportunities are to take on new permanent staff and they meet weekly to discuss the ‘12 week review’ of agency staff. They check the records for the agency workers to see who has been there longest and has the best attendance record, attitude and performance. If they have capacity they offer the best workers a permanent job and if there isn’t capacity they offer contracts with guaranteed hours a week. As they open more shifts they offer opportunities for people to transfer. Once a person is employed, in the initial period their performance is reviewed every month and ‘transfer sessions’ happen every 6 weeks or so, to support the individuals in their development and transition to permanent employment.

C A S E S T U D Y

• The Gangmasters and Labour Abuse Authority (GLAA) operates a licensing scheme that regulates businesses who provide workers for the processing and packaging of all fresh food, drinks and other produce, to the agricultural, horticultural and shellfish gathering sectors to ensure they meet the GLAA Licensing Standards required by law. LPs are assessed to check they meet the these licensing standards which include a Fit and Proper Test, prevention of forced labour and mistreatment of workers, health and safety, accommodation, pay, transport, recruiting of workers and contractual arrangements. It is illegal to supply workers without a license or to use an unlicensed labour provider. The GLAA provides resources for labour users https://www.gla.gov.uk/i-am-a/i-use-workers/

• The Association of Labour Providers (ALP) provides resources for using labour providers https://labourproviders.org.uk/resources

• UK Government Advice on Labour Providers Due Diligence https://www.gov.uk/government/publications/use-of-labour-providers/use-of-labour-providers-advice-on-due-diligence

• UK Government advice on ‘Right to work’ checks https://www.gov.uk/check-job-applicant-right-to-work

USEFUL LINKS AND RESOURCES FOR AGENCY LABOUR MANAGEMENT FOR UK SUPPLIERS

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ETHICAL

5 E Q U A L O P P O R T U N I T I E S A N D I N C L U S I O N

A strong culture of equality and inclusion for all workers is important for your business to thrive.

Consistent research shows that diverse businesses perform better – through innovation, better decision making, and attracting and keeping great people, meaning they’re likely to be more financially successful, increase market share, and capture new markets. Every person must be treated equally and be free from any discrimination, whether that is based on gender, race, disability, age, religion, sexual orientation or any other factor. All UK organisations with over 250 employees are now required to share details of their Gender Pay and Bonus Gaps, the percentage of men and women receiving a bonus, and the proportions of men and women in each pay quartile of the workforce.

Equal opportunities and inclusion is a very high priority for M&S, not only within our own business but also within our supply chain. We are working hard to make improvements in this area ourselves and we expect our suppliers to also prioritise this.

H O W D O Y O U E F F E C T I V E LY E L I M I N A T E B U L LY I N G

A N D H A R A S S M E N T F R O M T H E W O R K F O R C E ?

It is important to take a close look to make sure that bullying and harassment is not happening in your workplace, even in subtle ways.

• The workplace must be free from all harassment, intimidation and bullying. This means there shouldn’t be shouting in the workplace or harsh treatment of workers, even in busy times.

• The workplace is free from all sexual harassment, even subtle forms of inappropriate language and behaviour.

• There is a culture of respect in the workforce.

• Supervisors and team leaders are trained effectively to eliminate these practices.

• Take a look at policies and practices to make sure there are no inappropriate or unacceptable

punishments or penalties. What happens when a worker does something wrong? Are they shouted at? Or subjected to any other forms of emotional/mental or physical punishment? Are workers fined? Have you ever heard of these things happening? None of these forms of punishment are acceptable.

• Ensure payment/wage procedures do not include financial deductions as punishment for bad behaviour, quality mistakes etc. You may need to think of more creative ways to reward good behaviour and production.

• There must be an effective system for grievances or concerns to be raised (anonymously if preferred) and dealt with appropriately, without any negative repercussions for those who make a complaint (see Section 9 – Representation and Engagement).

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S T O P

16 17

ETHICAL

S U G G E S T E D S T E P S T O I M P R O V E E Q U A L I T Y

A N D I N C L U S I O N I N Y O U R W O R K P L A C E

It is important that your policies and actions on diversity and inclusion also go beyond gender. Here are some resources to help.

• Closing the Gender Pay Gap The UK Government provides advice on actions that can be taken to close the gap. https://gender-pay-gap.service.gov.uk/actions-to-close-the-gap

• Toolkit for Gender Equality at work in practice, 100 initiatives by social partners and in the workplace across Europe http://erc-online.eu/gendertoolkit-etuc/

• Chartered Institute of Personnel and Development provide various resources on Diversity at work https://www.cipd.co.uk/knowledge/fundamentals/relations/diversity

• ACAS advice on improving equality, diversity and inclusion at work, including their provision of training https://www.acas.org.uk/improving-equality-diversity-and-inclusion

• Effective communication for multi-language workforces M&S worked with others to develop this practical toolkit which will be helpful in ensuring information and on site communication is inclusive where the workforce speaks many languages. https://www.stronger2gether.org/product/effective-communication-with-a-multi-language-workforce-toolkit-for-employers-and-labour-providers/

• Business in the Community resources on race equality, including a toolkit on tackling racial harassment https://www.bitc.org.uk/race/

• Personnel Today provides Steps to take action on ethnic diversity at work https://www.personneltoday.com/hr/time-for-action-on-ethnic-diversity-in-the-workplace/

• LGBTQ+ Inclusion in the workplace https://www.myhrtoolkit.com/blog/lgbt-inclusion-in-the-workplace

USEFUL LINKS AND RESOURCES FOR EQUAL OPPORTUNITIES AND INCLUSION

o Managers and supervisors demonstrate the right behaviours to uphold equal opportunities, diversity and inclusion. This means they need training on these topics to encourage the right behaviours. This training should be actively managed and ongoing, given within 6 months of employment and could be by internal or external providers.

o Migrant/minority groups are supported to integrate in the workplace. This could include:

- Assistance setting up a bank account and getting a social security number

- Opportunities to meet other workers outside work

- Mentoring programme with experienced migrant/minority workers

- Language/conversation classes

o Celebrate Cultural Diversity. You can develop a cultural matrix to identify the different nationalities, build knowledge of their different cultural trait and use the information to

positively manage cultural differences within the workplace including documentation, signage, training, HR policies, workplace activities e.g. home

country food theme days (see the Multi-language Workforce Toolkit).

o The demographics of supervisors/managers are proportionate to the entire workplace diversity.

o Non-discriminatory workplace language policy, to ensure workers can integrate, understand and communicate whilst at work. The policy approach on English Only or Not English Only has been agreed, can be justified as legitimate and shapes the language policy. The Multi-language Workforce Toolkit has a decision matrix to assist in making this decision and guidance for developing the appropriate policy.

o Proactive gender pay gap management. At this level a supplier would be calculating gender pay gap (or local equivalent) regardless of number of workers and provide a narrative with the results, explaining them and giving actions taken to reduce the gap.

STEPPING UP 3

ciao

namasté

hello

Check your progress

SUPPORTING MIGRANT/MINORITY GROUPS TO INTEGRATE IN THE COMMUNITYIf your business is at the advanced level of ‘Stepping

Beyond/excelling’, this could go beyond the support

that was suggested in ‘Stepping Up’, extending beyond

the workplace, into the community. This could include: • Providing local information in first language

(e.g. providing a ‘Life Guide’ with info on UK/local law,

police, schools – some local authorities provide

these free)• Road safety training (e.g. www.roadwise.co.uk)

• Introductions to local families• Working with local council and local health authority

to provide information • Connecting with local schools• Proactive support of relevant local charities

• Assistance in getting set up with utilities companies

• Sessions with police to raise awareness of modern

slavery • Link with housing officer to talk about housing issues

e.g. multiple occupancy, landlords etc.

o Migrant/minority groups are proactively supported to integrate in the local community.

o Supplier is leading on diversity and inclusion in the workplace. Understanding the specific relevant inclusivity challenges and has an action plan to tackle these. Implemented innovative projects and activities that have made a marked difference to inclusivity in the workforce and have shared this best practice/learnings with other sites and where possible with other companies/suppliers to M&S. May involve external experts to support/verify approach and may have external recognition.

o Supplier culture is inclusive and encourages right behaviours, with an ongoing programme of diversity training for the whole workforce within 1 year of employment and ongoing support that could include information/resources and mentoring.

o Gender balanced management teams, supported by an action plan, aiming for a specific target % of management being female, and a target to reduce the gender pay gap, with programmes to promote gender equality and women’s empowerment. Could include also measuring other pay gaps (disability, ethnicity, age etc).

o Proactively celebrates cultural differences.

STEPPING BEYOND 4

WHAT’S THE DIFFERENCE BETWEEN

GENDER PAY GAP AND EQUAL PAY?

Equal Pay means that men and women

performing equal work should generally

receive equal pay.

The Gender Pay Gap is the difference between

men’s and women’s average hourly pay across

an organisation, expressed as a percentage.

It is reported as a mean average and median

average (mid-point) figure. A Gender Pay Gap

exists in most organisations, the aim of course

is to reduce it. The current UK average can be

found in the latest Office for National

Statistics, ASHE Survey.

o Gender Pay Reporting. This is a legal requirement in the UK if your business has

more than 250 workers including public disclosure of: Gender pay gap (mean and average), Gender bonus gap (mean and average), proportion of men and

women receiving bonuses and proportion of men and women in each quartile of the site’s pay structure (confirmed in a written statement by an appropriate person).

1 LEGAL/MINIMUM REQUIREMENT

o Equal opportunities and Inclusion Policy is defined, documented, explained to all workers in induction or other training and a summary is displayed on a notice board. It includes ensuring the rights of women and other minority groups are protected, there’s no restriction on worker movement and there’s no retaliation for those who raise concerns or complaints regarding these issues.

o Workforce demographics are known and extra support is provided for certain groups where needed.

o Worker/TU reps are aware of the different groups represented in the workforce and work to support them. This might include internal or external training for reps on specific diversity issues and a named rep being responsible for raising issues for a specific group at meetings.

o Pay structure is fair to all and supports Equal Opportunities policy. Equal opportunities for all, pay based on knowledge, skills and experience with no bias to any one group e.g. women are not paid less for the same role.

STEPPING IN 2

18

G E N D E R E Q U A L I T Y I N T H E W O R K P L A C E - G O O D P R A C T I C E

Many of our suppliers have put in place various elements of good practice in supporting Gender Equality in the workplace, which include:

Innovation in flexible working and part time work, not just for women

Improving communication about flexible working options and opportunities during recruitment, induction and through awareness raising campaigns

Connecting to regional ‘Women in Work’ groups

Improving maternity process, maternity pay and also paternity leave

Providing support and mentoring for people taking family leave

Female to female mentoring/coaching within the business

Diversity and inclusion forums, workshops and discussions

Focus on training, leadership development and internal progression plans for women

Endorsing the UN’s Women’s Empowerment Principles, including signing the WEPS CEO Statement6

Promoting and celebrating Women’s Day

THE CHALLENGE Their Langford site near Bristol was

experiencing high levels of employee turnover, particularly with new starters and also general difficulty in sourcing candidates. These issues coupled with the challenge of packhouse employees being from 7 different nationalities with varying levels of English, led them to carry out a review. Working with management, HR and Employee Works Council, they looked at each stage of the employee lifecycle with an aim of increasing retention and identified onboarding as the primary focus for action.

ACTIONS TAKEN • Since many of their employees are migrants,

for whom this is their first time living and working away from home, they appointed a multi-lingual Employee Liaison Officer to provide additional support. This includes greeting them at the airport, supporting them as they seek accommodation and assisting them in setting up bank accounts and registering for tax.

• In addition to existing probation reviews, retention interviews were introduced which consist of regular ‘catch ups’ with the Employee Liaison Officer to ensure that employees are settling in and to address any issues.

• As part of the review of induction, a section was added about development opportunities, giving a sample development path within the company.

• A six month training scheme was introduced to accelerate employee progression.

• The Employee Welcome Pack contains a welcome letter, names, titles, roles and photos of key people on site and local amenities information. There’s an electronic newsletter, regular updates and the company intranet has policies and benefits information in multiple languages.

• English classes for employees including new starters have been introduced.

• Employee initiatives including nationality days to celebrate the diversity of each country’s food and interests have helped to integrate new starters.

THE RESULTS The changes have resulted in many benefits

including a 14% reduction in worker turnover. The employee engagement survey results saw an increase of positive responses of 10% over the course of a year. The company found that the savings made through the improvements have far outweighed the investment required and would recommend similar actions to any supplier.

MONAGHAN MUSHROOMS – Improved onboarding for migrant workers increases retentionMonaghan Mushrooms sells 1,800 tonnes of mushrooms every week, grown in 29 locations worldwide, supplying to 5 out of 10 of the world’s top grocery retailers, including M&S.

C A S E S T U D Y

18

“ The best thing about my job is communicating with people from all different backgrounds and watching them grow in the Company. ”

Magdalena Tomova, Employee Liaison Officer (started as Mushroom Harvester)

Assistance in getting a bank account

19

ETHICAL

6 H E A L T H A N D S A F E T Y

Health and Safety is the responsibility of all. Focus needs to be on good H&S management systems, reducing H&S risks in the workplace, protecting the health and well-being of workers and developing a safe workplace culture.

Ensuring the workplace is safe and healthy for all workers, both direct and agency, is an absolutely essential requirement for all our suppliers. A safe workplace contributes to good productivity and quality and also reduces risks of health issues, accidents and injuries, which not only have a human cost but also a financial cost to the business in lost work hours, insurance premiums and possible legal action. We are proud of how seriously our suppliers take these issues, with a high focus on H&S Systems.

GREENCORE reap the business benefits of focused H&S action Greencore is a convenience food company supplying M&S with chilled prepared meals and sandwiches. Over the years they have undertaken various H&S projects including:

• Building capacity and development of relevant staff through training and promoting changed behaviours and H&S culture awareness

• Improving the safety infrastructure through investment in resource and ways of working

• Improving governance and simplifying the integration of H&S actions into a way of life in all manufacturing facilities and activities

• Introducing bespoke H&S Coordinators, union reps and improvement working groups (these individuals are not members of the SHE department at Northampton, they are line operatives and colleagues from all functions of the organisation)

C A S E S T U D Y These various workstreams produced significant business benefits including:

• 49% reduction in total accidents from 2007 to 2019

• 65% reduction in RIDDOR reportable accidents 2007-2019 (reduction is significant since the company more than doubled in headcount in the same period)

• Reduced insurance premiums for employers liability/property insurance

• Reduced lost production time and management time dealing with problems

• Longer-term employee health benefits which generate savings for business

• Increased awareness across all colleagues in the business

• Recognition and Awards - Commended by The Royal Society for the Prevention of Accidents (RoSPA) in 2020 as industry sector winners in the food, drink and tobacco manufacturing industry and sustaining 16 years of RoSPA Gold Medals

6 https://www.weps.org/

BAKKAVOR raising H&S up the agenda and reducing accidents

THE CHALLENGE Bakkavor’s Highbridge site provides M&S with

Breakfast pots. In 2016, on average just over 1 person a week was being injured and the site had been ‘red rated’ by their business and put on special measures. They took the challenge very seriously and took action to change the site culture and behaviours to embrace safe work.

ACTIONS TAKEN • Raising H&S up the agenda in meetings at all

levels, from Senior Leadership Team to factory floor team briefings.

• Introduced ‘Positive Observation Process’ (POP) cards, generated for ‘good’ as well as ‘poor’ behaviours, not linked to any disciplinary process, with targets to report, to promote positive discussion and problem solving. Raising issues seen as positive, as opportunities for progress.

• Improved hazard reporting using ‘Heinrich pyramid’, aiming to increase reporting.

• Target of Zero Accidents. Every minor accident now treated as major with full investigation and root cause analysis.

THE RESULTS • 65% reduction in accidents in 2019 (only 10 in

the year), with no major or lost time injuries.

• In 2018 received the group’s Safety Culture Award for improvement of site behaviours.

C A S E S T U D Y

20 21

S U G G E S T E D S T E P S T O T A K E T O E N S U R E

Y O U R W O R K P L A C E I S S A F E A N D H E A L T H Y

Check your progress

LEGAL/MINIMUM REQUIREMENTS

Meets all local and national legislation on H&S

Decent standard of facilities for all staff including agency - Access to secure lockable facility during working hours - Clean and hygienic personal protective equipment (PPE) free of charge - Where possible – own boots, overalls and safety gloves - If short term workers have PPE which may have been used by others,

it is clean, hygienic and carefully stored.

H&S Management Systems owned and managed at senior level - A named senior manager is responsible (Director for a large site,

Senior Manager for a small site) who has the relevant skills and experience in H&S or access to professional advice (e.g. IOSH).

- Discussions on these systems happen at senior management meetings to set H&S policy, KPIs and direction.

1

STEPPING IN

Clear H&S Policy documented, covering all areas of the business, making H&S a clear focus and priority

Risk assessments to identify potential risks and guide focus/resources

H&S KPIs are established, monitored, communicated to all staff and used to improve H&S performance (e.g. accidents, near misses etc.)

Regular audits are carried out to ensure H&S policy intentions are effectively being applied.

- Audits at least annually with progress follow-ups at least every 3 months, either by 3rd Party auditor or internally trained auditor with appropriate recognised qualification.

- Named senior manager responsible for ensuring actions arising are completed and progress is documented.

H&S Safety Committee established and meets regularly - The number of worker reps is equal to or more than

management reps on the committee - Documented minutes and written evidence of improvement actions

agreed and completed

Effective, focused H&S training to drive improvements - Written analysis of roles and tasks and what training is needed for each. - H&S training programme is documented and carried out by appropriately

qualified internal trainer or suitable external provider. - Carried out at start of employment and also when roles/tasks change. - Available for all workers, including agency workers, with key materials

translated into key languages if necessary.

Robust accident investigation (recorded and investigated by a trained person immediately), cause of accident identified, preventative action taken (e.g. change of procedure, re-training, ergonomic assistance) and learnings reviewed and applied elsewhere.

Absence monitoring system in place, to record all absences and reasons, with level of sickness. Absence tracked as KPIs and actions taken to reduce high levels of absence.

Robust fire safety policy and procedures including fire evacuation procedure, regular fire drills and fire wardens identified and trained.

2

STEPPING UP

Regular H&S risk assessments and action plans developed to reduce the key risks, using H&S KPIs/ SMART objectives to monitor and drive improvements

Active Crisis Management procedure, with documented list of possible risks and crises and actions to be taken (crisis manual), to minimise impact of incidents.

- Appropriate training for senior management on crisis management from external provider

- If a crisis occurs it has been documented with root causes and actions taken to reduce likelihood of re-occurrence.

H&S KPIs proactively managed, communicated and monitored to drive improvements.

- Worker input on KPIs sought - Clear targets set and benchmarking record

against industry standards - Written performance and progress is reviewed in senior

management meetings.

Worker Committees (WC) and TU fully consulted, so that workers are driving the approach.

- Management discusses proposed actions/improvements/ training with TU/WC before implementation

- Minutes of meetings with WC/TU include H&S issues and actions or refer to H&S committee minutes

- H&S Committee feeds into the WC.

Effective accident and near miss management - Relevant statistics are recorded, tracked, reviewed and

action plans in place to reduce. - Near miss reporting seen as positive, as opportunities

to improve - Accident levels decreasing

Proactive Absence Management Policy that is communicated to all levels, with training for managers.

- Absence KPIs regularly reviewed with managers and action plan in place to reduce levels

- Support given to help workers to return to work as quickly as possible and for workers with long term health conditions

Proactive Occupational Health support for workers. - Key risks identified (e.g. manual handling, RSI, stress) and

evidence is present of actions being taken to address risks - First aiders in place and trained

Access to immediate medical care if workers are injured. This may include:

- Required level of trained first aiders - Medical room on site - Access to occupational health (on site or outsourced) - Procedures to get staff to hospital/doctor quickly - Links with local health provider/hospital for immediate

care in an emergency

3

STEPPING BEYOND

Demonstrating a leading H&S record, with H&S stats significantly better than average, innovative projects that have made a marked difference and are shared as best practice with other businesses. May include external recognition (e.g. ROSPA Gold medal for H&S, British Safety Council, 18001 or equivalent).

Leading levels of audit management and procedures. This could include regular internal H&S checks, behavioural safety tours, weekly monitoring of H&S KPIs at senior management meetings, feedback from workers (e.g. survey, H&S focus groups).

Strong H&S culture, with behavioural safety training so everyone takes responsibility for H&S and H&S is embedded. H&S implications of operational changes are considered.

Proactive to make constant improvements. Working with local health providers/doctors to provide H&S needs assessment, training/mentoring of H&S committee or free health checks.

4

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ETHICAL

22 23

2. ETHICAL

7 M A N A G I N G W O R K I N G H O U R S

2322

ETHICAL

Managing working hours means that they are controlled and meet the Ethical Trading Initiative Base Code and that exceptions are investigated and preventative action taken.

Getting working hours right is not only a legal obligation but also ensures that workers are well and productive. Excessive working hours result in hidden costs, not only for workers but also for the business. Various studies have shown that injury rates increase and productivity falls with higher working hours, which brings costs to the business of reduced output, higher staff turnover, more sick days, absenteeism and medical costs.

PROACTIVE MANAGEMENT OF WORKING HOURS

SYSTEM TO MONITOR WORKING

HOURS

ACTIONS TAKEN TO ENSURE

SAFETY

ACTIONS TAKEN TO REDUCE OT

POLICIES AND PROCEDURES

for working hours, holidays, voluntary OT 48 hour opt-out

CLEAR DOCUMENTED

WELL COMMUNICATED

REVIEW SHIFT PATTERNS

WORKFORCE OR COLLECTIVE AGREEMENT

on average hours

REAL TIME ANALYSIS REPORTS

RISK ASSESSMENTS

MANAGERS RESPONSIBLE for monitoring hours

in their areas

REVIEWED BY MANAGEMENT

ACTIONS TAKEN TO REDUCE OT

S U G G E S T E D S T E P S T O E F F E C T I V E LY

M A N A G E W O R K I N G H O U R S

Check your progress

o Managers and HR have a thorough understanding of the importance of managing hours effectively and of the WTRs and relevant requirements e.g. ETI Base Code

- Evidence that managers are proactively monitoring hours and taking action to ensure compliance e.g. rest breaks, holiday entitlement, reducing overtime

- Using average hours and compensatory rest to manage OT - Able to explain the importance to workers

o Proactive and innovative approach to reducing OT hours - Set key KPIs to reduce OT and trend is downwards - Trialled new approaches/working practices to reduce OT.

These are assessed and those which are effective and feasible are adopted and well communicated to the workforce.

o Regular discussions with customers to minimise excessive hours due to ordering patterns

- Discusses order flows with customer at least monthly, with written notes

- Identifies ‘pinch points’ with customer and finds possible solutions

- Works with customer to trial innovative approaches to smooth order flow, to reduce hours

- Improving order flow has improved labour demands (e.g. reducing reliance on agency labour)

o Annual Review of working hours takes place to assess effectiveness of managing and improvements are implemented

4 STEPPING BEYOND

LEGAL/MINIMUM REQUIREMENTS

o Meeting local and national legislation (non UK suppliers should apply the relevant county law)

o Complies with Working Time Regulations (or equivalent) - Including maximum working hours per week,

rest days, breaks, night working, compulsory rest - Opt outs are signed if workers are prepared to work over

48 hours (in the UK).

1

o Workers know their working hours arrangements and holiday entitlement and how to take them

- Contracts clearly communicate contracted hours, paid and unpaid breaks, rest days, voluntary overtime (OT) hours

- Clear holiday policy and procedure for applying, included in contracts, induction manual, staff handbook, notice board etc.

o Clear, documented Voluntary Overtime Policy in place - Workers clearly understand which working hours are

overtime hours and therefore voluntary (e.g. contracts, induction manual, notices)

- All workers feel able to turn down overtime hours (agency Labour Provider (LP) ensures workers know this)

o Workers can travel home safely at night. Supplier has reviewed transport requirements of all staff and ensures they will be able to get home safely, either by providing or helping workers access safe transport

o 48 hour opt out is managed in line with legislation (in the UK) - Documented copies of 48hour opt out clauses signed by

all workers that it applies to - Ensure workers do not feel they have to sign the opt out

form and are given an opportunity to cancel it

o System in place to monitor working hours, to ensure there are no excessive hours worked

- May include Electronic Time and Attendance system or clocking in/out cards

- Identify when workers have exceeded 60 hours and take action

2 STEPPING IN

o Detailed and clear Working Hours and OT Policies in place and communicated to managers and workers, so that managers understand and implement the policies and workers have access to and understand them.

o Proactive management of working hours, to ensure workers are not working more than 60 hrs per week

o System used to measure hours is accurate enough to give real time analysis reports

o Proactive reviews of shift patterns to meet both business and worker needs and which are structured to avoid excessive hours and evidence that this has been effective

o Effective and documented risk assessment process to assess and define safe working limits in different production areas. Evidence of actions taken when workers exceed safe working limits.

o Workforce or collective agreement in place, to average working hours

- Signed by worker reps/TU reps and management - Details how the site will manage working hours in line

with the WTRs (or equivalent) - Specifies and agrees reference period that average

hours will be calculated over

o Managers responsible for monitoring working hours in their area (not just HR) – listed on JDs and KPIs

- Understand contracted hours vs. OT hours and that OT is voluntary

- Taking action when necessary to actively monitor and reduce OT

o Proactive to raise incidents of over 60 hours working with customers (without being prompted), so reasons can be discussed and actions taken to do things differently to avoid re-occurrence

o Safe working hours risk assessment is part of Standard Operating Procedures (SOPs), with evidence of actions taken to address safety risks e.g. extra lighting in car park, changing shift end times etc.

3 STEPPING UP

24

The Partner Africa Business Toolkit7 explores a number of strategies to tackle long hours on pages 58-63, including ‘Direct approaches’ such as changing shift patterns and employing more workers and ‘Indirect approaches’, which involve reducing the need for excessive hours through productivity, quality, HR, communications and production planning improvements. https://www.aim-progress.com/files/125/business-toolkit-complete-final-20-feb-2018.pdf

Ethical Trading Initiative guidance on working hours. https://www.ethicaltrade.org/sites/default/files/shared_resources/eti_working_hours_guidance.pdf

USEFUL LINKS AND RESOURCES FOR MANAGING WORKING HOURS

2 SISTERS - Reducing costs, overtime and dependency on agency labour Gunstones Bakery in Derbyshire is part of the 2 Sisters Food Group and provide various bakery products to M&S. Before taking the actions described in this case study, the site was making a loss and recognised the need to be ‘fit for the future’ and to challenge costs, to be as lean, efficient and commercially competitive as possible. As a business, they also wanted to pay fair and competitive rates for all colleagues. The site identified the need to mitigate for the rise in National Living Wage and subsequent annualised impacts and reduce a high reliance on overtime and agency usage. They had a complex payroll and pay structure in place that they wanted to simplify.

The site worked to develop a number of different working pattern scenarios, harmonisations of terms and conditions, moving from 8 hour to 12 hour working, reducing overtime and use of agency labour. The various shift patterns were put to the workforce who opted for a fixed shift of 3 days one week, 4 days the next instead of a rotating 4 days on, 4 days off shift pattern. All shift patterns proposed were 12 hours with longer periods away from the workplace, to give colleagues a better work life balance whilst giving the

business less shift changeovers and improved continuity in terms of production. They entered negotiations with the Bakers, Food and Allied Workers Union on a phased plan to harmonise contracts over a 2 year period, after which they had successfully negotiated and balloted the changes.

There was a reduction in agency labour use (from around 30-40% of the workforce to around 10%) and also a reduction in the need for overtime hours, which not only saved the site significant costs but also resulted in an improved work life balance for colleagues. They also received a positive result for their ethical audit in the same year. Their scores for employee engagement surveys improved and colleagues responded that shift patterns were one of the top 3 positive aspects of working at the site the following year. Although the site previously had strike action in 2015 following pay negotiations reaching an impasse, it seems that this time, the timing was right for them to make a major change and they were able to negotiate in such a way that kept employees engaged and positive about the changes.

C A S E S T U D Y

7 The Partner Africa Business Toolkit. This toolkit is written and produced by Partner Africa, with the support of ABInBev, The Cola-Cola Company, Diageo and AIM-PROGRESS.

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• Living Wage Foundation UK. https://www.livingwage.org.uk/what-real-living-wage

• Ethical Trading Initiative Base Code Guidance: Living wages. http://www.ethicaltrade.org/resources/base-code-guidance-living-wages https://www.ethicaltrade.org/issues/living-wage-workers/living-wage-resources

• Fair Trade International’s resources on Living Wages. https://www.fairtrade.net/issue/living-wage

USEFUL LINKS AND RESOURCES FOR FAIR REWARD

8 F A I R R E W A R D

Fair reward means that all staff are paid fairly for the job that they do and there is a commitment to find ways to provide sustainable higher earnings.

Everyone involved in the M&S supply chain needs to be fairly rewarded for their work, which means both fair wages and benefits. This is essential for the wellbeing and health of those workers and their families as well as being important for morale and commitment to the business they work for. Getting this right makes a big difference to staff motivation and therefore productivity and reduces turnover and associated costs.

W H A T I S A ‘ L I V I N G W A G E ’ ?

In many cases workers who are paid the legal minimum wage still are not able to live on that salary and support their families. The ideal is for your business to work towards what is called a ‘Living Wage’, both in your own facilities and in your supply chain, which enables a family to meet their basic needs and some discretionary income. Social Accountability International breaks down “basic needs” into: “a standard level of nutrition, housing, transportation, energy, healthcare, childcare, education and savings within regulated working hours (e.g. without overtime hours).”

In the UK, the government required National Living Wage (NLW) is just a higher National Minimum Wage (NMW) for over 25s and is considered a ‘fair wage benchmark’ but is not based on an assessment of basic needs. In the UK, the ‘Real Living Wage’ is a rate that is based on what people need to live on, is higher than the NLW and is set by the Living Wage Foundation. The Living Wage Foundation aims to encourage employers to pay a Living Wage by publishing an annual Living Wage figure and accrediting employers who pay the wage (nearly 6,000 UK employers).

?

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S U G G E S T E D S T E P S T O T A K E T O M A K E S U R E

Y O U R S T A F F A R E F A I R LY R E W A R D E D

o Committed to paying Real Living Wage (see Living Wage box for definition)

- Committed to increasing pay rates to Real Living Wage and has a plan to get there in a sustainable way. For many this is a journey, but there needs to be a plan.

- For suppliers who are not there yet, there are additional benefits that make the total package attractive.

- For non-UK suppliers, use a local equivalent real living wage rate.

o Progressive, fair and competitive reward package, more than legal requirements

- Competitive when compared to comparable local businesses in a review (holidays, pension, health benefits etc)

- Can use an externally recognised comparison/benchmark (e.g. Local Chamber of Commerce) or conduct own review (minimum of 10 businesses with more than 100 people)

- There is a link between performance and reward at all levels

- Where possible, employee ownership is considered (e.g. share option schemes)

- Board level pay compared to average worker pay is understood

o Aligned gender pay achieved, as shown by gender pay gap reporting.

This requires proactive management of pay to ensure that genders are aligned.

o Proactive in tackling ‘in work poverty’, using a number of initiatives such as:

- Re-training opportunities, especially where jobs are eliminated through automation or other reasons

- Job creation - Helping long term unemployed back to work - Supporting households to have more than one person

in work - Support for the provision of child care to enable the

parent to work

LEGAL/MINIMUM REQUIREMENTS

o Meeting local and national legislation on wages and benefits for all staff and that they are non-discriminatory i.e. where there is an increased pay rate based on age (e.g. higher rate for workers over 25 in the UK), all workers receive the higher rate of pay, even if they are younger.

o Agency workers receive pay parity - After 12 weeks in the job (or after finishing the training

period) agency/temporary workers receive the same basic pay and overtime premiums as permanent staff, documented in the payroll.

o Workers are employed on appropriate contracts - No zero hours contracts in the core workforce - Workers who work regular hours over a

continuous period are not on zero hours contracts, but a more appropriate one

- If zero hours contracts are used they have passed the ‘appropriateness’ test e.g. single parent may only want to work occasionally and not want to commit to definite hours of work.

++

Check your progress STEPPING BEYOND

1

4

o Workers (including agency) have detailed payslips, every time they are paid

- Payslips show clearly how their pay is calculated including hours and show any deductions

- Fully understood by all workers (training and explanations given)

- Workers can approach appropriate senior staff to ask questions and it is made clear to them how to do this

o Piece rate workers earn at least the National Minimum Wage (NMW)/ National Living Wage (NLW)

- Fair test to establish piece rates, using workers of average skill, in a fair timed environment

- Where conditions vary, piece rates are varied - Documentation available regarding tests and

calculations

o Clear transparent and non-discriminatory pay structure - Pay scales are documented and reviewed regularly

(e.g. annually) - Pay scales reward skills and performance (content,

responsibility and scope) - Same job, same rate of pay, regardless of age

(under 25s paid NLW) - Trial periods for permanent and agency workers

are based on expected training time - Authorisation procedure to ensure correct pay scale

for the job

o Agency workers rates of pay are in line with the company pay scale after 12 weeks with a fair rate of pay for all

- As above, pay scales reward skills and performance

o All workers (including agency/temporary) receive a premium for working voluntary overtime

- OT hours should be paid at a premium of at least 1.25 (ETI Base Code minimum standards)

- OT Policy clearly states which hours are OT hours i.e. what are the normal working hours after which OT is paid

- Any differences in approach to paying OT should be in line with the SEDEX Enhanced Payments guidance or negotiated with a recognised trade union

o All workers (including temporary and agency) are paid in line with the National Living Wage Regulations (National minimum wage if outside the UK)

- Site understands and complies with the NLW calculations and regulations (also understands the offsets that apply e.g. transport costs deducted through the payroll, accommodation costs above the offset limit)

- Working time is calculated as well as paid and unpaid breaks

£+

STEPPING IN2

o Wage rates are fair and competitive, compared to local area

- Regular review of local pay rates at comparable businesses - Evidence of internal and external pay benchmarking

demonstrating equal pay for equal work. If it is below average, action is taken to improve.

o Remuneration package is more than just wages - Additional benefits for staff – some paid for by the

business, some that staff pay for at a reduced cost (e.g. retail voucher schemes, dental care etc)

- Looking into introducing new benefits e.g. health care/critical illness, bonuses etc.

o Understands the difference between National Minimum Wage and Real Living Wage for their country - In the UK the Real Living Wage is published

by the Living Wage Foundation - Suppliers in countries outside the UK need to

research the “Living Wage” for their country/region

o Supplier is working towards paying the Real Living Wage in the future

- Completed a comparison against the Real Living Wage (this is NOT the same as NLW)

- Considering ways to move towards the RLW, with an outline plan developed to take the supplier on the journey

o Gender Pay Gap Action Plan in place - Understand the pay gap that exists based

on reporting and has an action plan to address these issues over a reasonable length of time

- Critical issues identified and addressed quickly

o All workers (including temporary and agency) have the opportunity to be paid digitally

- The benefits to workers is explained - Payment in cash is not allowed

unless there is no other option

RLWNLW v

STEPPING UP3

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9 R E P R E S E N T A T I O N A N D E N G A G E M E N T

Engaged workers have a real sense of belonging, they feel valued and listened to and they want to give their best.

Businesses with effective representation and full engagement of their workforce can harness the ideas and contribution from their workers, which will lead to improvement in business performance. This includes workers feeling able to put forward practical suggestions for improvements and able to raise concerns and those suggestions and concerns being acted upon. Employee engagement unlocks the ‘discretionary effort’ of the workforce, which is the ‘above and beyond effort people could give if they wanted to’.

If workers do not feel they are properly represented, or if they feel scared or there is a blame culture, they are unlikely to put forward suggestions or report a problem. If they feel that their voice is not welcomed, valued or

acted upon they will not speak up. This could mean that ideas and suggestions are never heard, and issues remain unsolved which impacts on productivity, morale and can result in increased turnover. Employees with lower engagement are 4 times more likely to leave their jobs than those who are highly engaged8.

Getting this right has significant business benefits, as shown in the diagram to the right, including higher productivity, greater innovation and reduced costs of employee turnover and absenteeism.

This section covers how to practically increase that engagement and representation so that there is effective two way communication in your workplace,

including worker rights training and an effective grievance procedure. Effective communication in the workplace can take many forms including Trade Unions and Worker Committees, employee surveys, notice boards and newsletters, focus groups and workshops, complaints and suggestions schemes including hotlines.

8 Employee Engagement. Who’s sinking your boat? https://www.youtube.com/watch?v=y4nwoZ02AJM 9 Weak Workplace Cultures Help Explain UK’s Productivity Woes, by Steve Crabtree, October 6, 2017 https://news.gallup.com/opinion/gallup/219947/weak-workplace-cultures-help-explain-productivity-woes.aspx

• Employee Engagement. Who’s sinking your boat? https://www.youtube.com/watch?v=y4nwoZ02AJM

• ACAS gives some useful guidance and advice on employee engagement in their two publications: ‘The People Factor’ and ‘Placing Trust in Employee Engagement’, found at the end of this page https://archive.acas.org.uk/engagement

USEFUL LINKS AND RESOURCES FOR REPRESENTATION AND ENGAGEMENT

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W H A T A R E T H E B U S I N E S S B E N E F I T S O F E F F E C T I V E

E N G A G E M E N T A N D R E P R E S E N T A T I O N ?

ENGAGEMENT LEVELS IMPACT PRODUCTIVITY

A poll9 showed that, of the workforce in the UK:

B E N E F I T S T O M A N A G E R S O F G O O D

W O R K P L A C E C O M M U N I C A T I O N S

?

only 8% are engaged at work (being highly involved and enthusiastic about their work and workplaces)

73% are psychologically unattached to their work, putting little energy and passion into it

The analysis across many countries and industries showed a clear link between engagement and productivity, showing that the units in the top quarter of engagement scores were 17% more productive and 21% more profitable than those in the bottom quarter.

We know that our suppliers put a huge amount of effort into engaging their workforce, listening to their views, supporting career and personal growth, so we know that the engagement percentage would certainly be higher than this startling UK average.

?

?

What do you think the engagement figure would be at your business?

Can you imagine the productivity benefits of increasing it even further?

19% are ‘actively disengaged’, resentful and unhappy at work

Trust• Builds trust and openness between you and your workers• Workers tell you their concerns so that you can easily resolve them• Increased confidence in workers to do the right thing

• Improved worker performance• Contributes to improved overall business performance

• Increased job satisfaction and quality of work• Workers feel valued and want to stay• Workers will feel more involved in the business and engaged

• Workers are part of the continuous improvement process• Many issues in your area are addressed before they become major problems

• You and your workers understand each other’s point of view• Workers are well informed and want to communicate with you• You regularly receive ideas and feedback from workers

Two way communication

Problem solving and decision making

Employee engagement

Improved performance

S U G G E S T E D S T E P S F O R R U N N I N G A N E F F E C T I V E

W O R K E R C O M M I T T E E O R T R A D E U N I O N

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“ Listening to, and learning from, elected representatives of Manor Fresh staff enables us as managers to have a focused, engaged and knowledgeable work force, and is an essential element to the effective ‘day to day’ operation of our business. ”

Michael Scott, Managing Director, Manor Fresh

A worker committee/council/forum (WCs) should consist of elected worker representatives who represent workers across all areas of the business, ensuring their opinions are heard, issues are raised and consulting on matters such as pay, T&Cs and hours with senior management to improve working conditions for the workers they represent. In a supplier with a recognised trade union, they will represent the non-union members and work together with the trade union on improvement projects, and in parallel on terms and conditions of employment. Trade Union Representatives should sit on the Worker Committee but may wish to have separate meetings with the business for collective bargaining purposes.

Trade Unions (TUs) with a recognition agreement with a supplier will have elected trade union representatives who have a legal right to negotiate the terms and conditions of employment of their members with senior management through collective bargaining. They will represent workers that are trade union members within the supplier,

although any collective agreements negotiated by trade unions will apply to all workers within the bargaining unit. Collective agreements cover terms and conditions, rates of pay, disciplinary and grievance procedures, handling disputes,

health and safety, handling redundancies and changes to employment terms.

Workplace Communications ResourcesM&S has developed some useful materials on Workplace Communications for our food suppliers. We encourage our suppliers to support different communications channels, including a Workers Committee for sites with more than 50 workers.

• M&S has produced some guidelines on the Workplace Communication Programme (WPC) for managers, project managers and workers. These give more detailed guidelines on Worker Committees (including election process and worker rep training) and also exploring other means of communication. There are also templates for WC agendas, meeting notes, nomination forms etc. These resources can be accessed here: https://www.dropbox.com/sh/lbxku5il6p3exab/AAClawsf4guKjW6BYUqJwF2pa?dl=0

• Ethical Trade Initiative (ETI) Resources on Worker Representation - Entry Points to worker representation

https://www.ethicaltrade.org/resources/entry-points-to-worker-representation

- 5 Steps to implementing Freedom of Association https://www.ethicaltrade.org/sites/default/files/shared_resources/Implementing%20freedom%20of%20association%20-%20a%20five%20step%20plan.pdf

USEFUL LINKS AND RESOURCES FOR WORKER COMMITTEES OR TRADE UNIONS

Worker Committee Principles

An organised Group

representing workers and

managers

Two way communication

between Management and Workers to share

information and ideas

Democratically and confidentially elected by other

workers and managers

A Senior Manager

attends (can be the Chair) to

ensure decisions can be made

It finds solutions to worker and

business problems

Minutes record

discussions, actions and feedback to workers and

managers

Holds regular, ideally monthly,

meetings

It represents all areas of the

business

Fair gender / ethnic

representation have been considered

Workers and Management contribute to the agenda

Check your progress

o Effective bargaining on terms and conditions of employment (meeting minutes show evidence of this happening on pay and conditions)

o For unionised suppliers this will be through the collective bargaining process, and for non unionised suppliers there must be a clear consultative process which shows 2 way negotiation (not just consultation).

o Evidence of at least 2 changes made to pay structures and/or working conditions as a result of workers bargaining collectively.

o Worker representatives truly represent the views of workers and bring these to meetings.

4 STEPPING BEYOND

LEGAL/MINIMUM REQUIREMENTS

o Positive attitude towards TUs and their activities (doesn’t impede workers’ rights to join a TU, understands and supports workers’ right to freedom of association)

o Union meetings take place without opposition or obstruction.

o Workers have the right to join or not join a Worker Committee or TU, they must not be obliged to join and must not be discriminated against in any way for either choice.

o Where possible providing necessary support e.g. private facilities/ location.

1

o Worker Committee is established or a more informal worker group for smaller suppliers with less than 50 workers even if there is also a recognised TU, so that non-union workers are also represented

o Where suppliers recognise unions, the Union Representatives and Employee Representatives sit on the Worker Committee together

o Where suppliers recognise unions, the role and legal responsibilities of the unions are understood and supported.

o The Workers Committee should function according to the following points (in addition to the points in the diagram above):

- More worker reps than management reps - Role of the committee and reps is defined and understood - All workers know who their WC rep is and how to contact them - Also documented: how and when actions were

implemented, changes that happened and how those were communicated to the workforce

- Regular two way communication embedded and resulting in changes

- Worker committee performance reviewed annually - Annual objectives set and reviewed - Worker Committee monitors its effectiveness (survey)

and can demonstrate it is adding value for workforce

o For Worker /Trade Union Representatives: - Worker reps on WCs should include union reps,

welfare committee members etc - All representatives are paid for their time performing

these duties at their normal hourly rate (or average hourly rate if paid by piece)

- Have a clear job description with responsibilities - Receive training and investment on consultation,

representation, influencing and communication skills, attending meetings and raising issues, taking information back to the workers they represent and disciplinary and grievance handling (theory and practical/interactive training). Consultation is a key skill for both management and worker reps.

- Given the time (within paid work time) and resources to do a good job (shift/line managers should be made aware of this).

o Effective representation: - Worker committee represents all workers including

temporary and agency workers, different nationalities, genders etc. This can include nominating worker reps to be responsible for certain worker groups

- Representation across shifts and work patterns

2 STEPPING IN

o Worker Committee genuinely reflects the make-up of the workforce. T

- This can be achieved by making a documented analysis of the make-up of the workforce in terms of nationalities, genders and types of employment (e.g. temporary/agency) and then ensuring the composition of the TU/Worker committee/ Employee forum is proportional to the composition of the whole workforce in these respects (including at least 1 rep from each major nationality present).

- If this isn’t possible, every effort must be made to ensure a diverse mix of reps are included and that they are able to represent different groups.

o Investments made to train worker committee to be effective.

3 STEPPING UP

W O R K E R C O M M I T T E E S A N D T R A D E U N I O N S

I D E A S F O R D E V E L O P I N G A N D I M P L E M E N T I N G A N

E F F E C T I V E C O M M U N I C A T I O N S P O L I C Y A N D P L A N

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As with every area of continuous improvement, achieving effective two way communications needs a policy and plan to ensure it is implemented systematically and successfully. Communications can take many forms including those listed below. The Workplace Communications (WPC) Programme documents provided in the ‘useful resources’ section on the previous page also give some tips on how to set up these different channels.

IDEAS ON HOW TO COMMUNICATE WITH EMPLOYEES• Employee surveys help to give an overview of staff

attitude, especially useful in a larger workforce. (Further details are given in Section 10 ‘Great Place to Work’.)

• Employee Polls to get feedback on workers views and opinions that can provide senior management with valuable information on how workers feel about their work. These can be run for all or part of the business, are short (shorter than employee surveys) and often run on a regular basis.

• Worker briefings, focus groups and workshops to give business progress updates, with Q&A sessions and opportunities for constructive feedback on what can be improved (in paid work hours). Some suppliers have monthly ‘coffee shops’ for staff to engage with a subject to improve policies and procedures.

• Daily ‘Huddles’ for the whole team in each work area to discuss the plans for the day, to ensure production goes smoothly, which means less wasted time, materials and effort.

• Newsletters and Notice boards (in communal areas such as canteens) – visual displays of information can be particularly useful in a multi-lingual workforce. Information such as recent actions implemented can be shared on boards. Newsletters can help workers feel more motivated and invested in the success of the business and can be published in different languages where needed.

• Open door policy (at all times or certain specified days and times)

• Suggestion boxes – a locked box in a communal area with pens and paper for workers to write anonymous suggestions, which are regularly reviewed by managers, brought for discussion to WC or TU meetings and implemented if beneficial.

Matthew Walker – Monthly ‘Coffee Shops’ to engage staff

T O P T I P S

Make sure workers are informed on business strategy and performance

Try out innovative ways of engagement through technology such as pulse surveys

Support your communication plan with manager training on good communication skills including how to deal with conflict situations

Ensure your plan responds to current business needs

IT IS ESSENTIAL that all workers, including temporary and agency workers, are aware of their

RIGHTS AND CONDITIONS OF EMPLOYMENT

• Understanding contracts of Employment, Terms of Employment and Notice Period and equality and discrimination rights

• Local national minimum wage – Wages and benefits and hours of work and how to decline over time

• Right to Freedom of Association including TUS/ Worker committees and how to be involved

• Workers and employers roles and responsibilities including reasonable expectations of an employer and methods to communicate with management

• Agency workers – how to apply for a permanent contract

Guaranteed hours – who to speak to?

• Discipline and grievance procedures – How to raise a grievance and what to do if there isn’t a satisfactory response

• ETI Base Code – what it is and why it’s important

T O P T I P S F O R E N S U R I N G W O R K E R S

A R E A W A R E O F T H E I R R I G H T S

TOPICS TO TRAIN WORKERS ON

INCLUDE:

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A grievance policy and procedure is a formal process for workers to raise any issues or concerns they have with their employer, without any fear of any negative repercussions for them. Workers should be actively encouraged to raise any issues with their line manager first and line managers should make every effort to create an atmosphere and culture in the team where workers feel comfortable to do this.

The grievance procedure should be clear and well communicated to all employees including agency, with a confidential complaints mechanism in place.

Worker Hotline• Speak Up. Service provider to set up a confidential phone

line for complaints. www.peopleintouch.com

Grievance and disciplinary procedures • UK government guidelines

https://www.gov.uk/solve-workplace-dispute/formal-procedures

https://www.gov.uk/handling-employee-grievance/grievance-procedure

• The UK Advisory, Conciliation and Arbitration Service (ACAS) gives step by step guidance on setting up a grievance and a disciplinary procedure (including example procedures) www.acas.org.uk/disciplinary-and-grievance-procedures

USEFUL LINKS AND RESOURCES FOR GRIEVANCE AND DISCIPLINARY PROCEDURES

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H O W D O Y O U M E A S U R E S U C C E S S

I N E N G A G E M E N T A N D R E P R E S E N T A T I O N ?

You can create your own KPIs to measure your improvement as a company in this area. These could include some of the following:

Staff retention figures

Absence figures

Number of staff involved in worker forums

% of workers covered by workers committee

% of employees covered by collective bargaining

% of workers completed workers’ rights training

% of staff completing staff surveys and other feedback

% of positive responses in staff survey for different questions

Number of grievances/complaints raised (or number of complaints received on a confidential hotline each year). Initially an increase may be a good thing as workers are more aware of the procedure and how to use it, surfacing existing but previously unreported issues

Number of grievances/complaints positively resolved

?T O P T I P S O N C R E A T I N G E F F E C T I V E G R I E V A N C E

A N D D I S C I P L I N A R Y P R O C E D U R E S

Worker hotline – One type of complaints mechanism is a confidential telephone line that can be used to anonymously raise issues, especially for more sensitive subjects.

Key elements of an effective hotline include:

• Workers need to be able to raise their concern in their own language

• It should be independent and confidential

• Workers should know how to access the hotline and use it

• A system is in place to follow up, investigate and remedy concerns and communicate any changes to the workforce

The key outputs of effective grievance policies and procedures should be:

• Workers are able to raise a grievance (confidentially and anonymously if they wish)

• There is a formal process

• They can be accompanied

• There is an appeals process

• There is no retaliation against the worker

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1 0 G R E A T P L A C E T O W O R K

We all want to have a workplace that staff are proud to work for.

Above and beyond being compliant to all the relevant laws and regulations on worker welfare, at M&S we truly believe that making your business a ‘Great place to work’, not only benefits workers but also significantly benefits your business by increasing the positive contribution and commitment of your workforce. Proactively improving your workers’ experience of their worklife means that they enjoy work more and then ‘bring their all’ into their roles, which increases productivity as well as staff retention.

Staff Survey An effective staff survey is a way to understand if your workforce feel your business is a good place to work. In addition it can become a useful tool to ensure your business is increasingly seen as a great place to work, by gaining the views of workers (including agency) and giving the opportunity to raise any concerns and areas for improvement. Using this information to then make action plans for improvement means workers feel heard and see that management are taking action on the things that are important to them. A high response rate demonstrates an engaged workforce and a higher validity of the results. See diagram opposite.

IF RESPONSE <60%, ACTION PLAN

TO INCREASE ENGAGEMENT

EVERY 2 YEARS

at least

ANONYMOUS RESPONSES

ENCOURAGE HONESTY

AVAILABLE TO ALL STAFF

(including agency)

TRANSLATED IF HELPFUL

ON COMPANY COMPUTERS OR ON PAPER

COMPLETION IN PAID WORK TIME

SETTING UP A SURVEY

EMBEDDING AND

ESTABLISHING

THE SURVEY

SURVEY RESULTS TRACKED

and results measured

SENIOR MANAGER responsible

SUPPLEMENTED BY OTHER WAYS

to understand views (including agency)

e.g. ‘Coffee Shops’

EFFECTIVE STAFF

SURVEY

TOPICS COVERED INCLUDE:

SURVEY LEADS TO IMPROVEMENTS:

COMMITMENT Whether they feel FAIRLY TREATED

Whether there’s OPPORTUNITY TO PROGRESS

OPEN QUESTIONS to raise concerns and

areas for improvement

SATISFACTION in work and work

environment

?

SURVEY RESULTS REPORTED AND

DISCUSSED at senior management

and HR meetings regularly

WCs AND TUs themes arising are

discussed and they are involved in action plans

RESULTS PRESENTED TO

WORKFORCE in meetings

FEEDBACK GIVEN TO ALL STAFF (including agency) regarding actions

(using the You Said/ We Did approach)

ACTION PLAN following each survey, to address concerns.

Evidence of actions taken

o Workers have the opportunity to recommend the workplace to others and are proud to do so and this can be evidenced

o Well established and embedded Staff Survey (see diagram), which leads to workplace improvements

o Well established process for developing and promoting internally with target % tracked

o Workers recognised and rewarded for positive contribution and commitment

o Regular feedback on workers views and concerns is gathered and impacts action planning

o Supplier actively supports flexible working

o Strong retention culture

o Health and wellbeing initiatives and services

o Supporting local community projects

S U G G E S T E D S T E P S T O T A K E T O E N S U R E

Y O U R B U S I N E S S I S A ‘ G R E A T P L A C E T O W O R K ’

H O W T O D E V E L O P A N D R U N A N E F F E C T I V E S TA F F S U R V E Y

Check your progress

2

o Communication Policy in place that provides workers with information about the business and a method to give feedback outside of the survey

o Effective Staff Surveys take place regularly to gain workers’ views

o Workplace improvement action plan in place, identifying actions needed to address issues raised by the survey. Evidence of workplace improving each year

o Basic KPIs are measured such as labour turnover, staff survey response, staff overall satisfaction from survey

1 STEPPING IN

STEPPING UP

o Strong culture of trust exists at all levels

o Strong and innovative investment to improve workplace

o Total reward package is innovative and enhances the business’ reputation as a great place to work

o Supporting community and charity projects is embedded and involves all levels

- Projects are diverse and relate to the needs of the community and the make-up of the workforce (e.g. supporting migrant workers in the community)

- Emphasis on increasing workers’ involvement - There are avenues for communities to raise issues,

concerns and suggestions with the supplier - Company facilities made available for charities/

volunteer groups to use - Edible food diverted to human consumption

(workers or local community groups)

o Innovative approach taken to make the workplace a ‘great place to work’

- Initiated and implemented innovative projects and activities and these have made a marked and evidenced difference to workers and their level of contentment

- Projects shared as best practices with other sites and other companies

o Leading approach on staff health and wellbeing that is embedded and invests for the future

- Includes proactive support and training on mental health

- Regular assessment of health and wellbeing at work and health risk assessments (including health checks), used to plan initiatives and support

- Access to healthy food while at work - Actively working to ensure products produced

comply with the M&S Wellbeing commitments

3 STEPPING BEYOND

38

I D E A S F R O M S U P P L I E R S

During Supplier Exchange meetings, our suppliers have shared many ways they are building teamwork and ensuring that workers are valued and that their business is a great place to work. Some of these have included:

Buddy up new and existing workers

Cross functional tasks to broaden team work

Using Myers-Briggs tests for teams to understand each other

Recognition and individuals feeling valued is not just about official recognition (e.g. employee of the month, best teams awards) but also day to day recognition, saying thank you, giving feedback and taking the time to get to know the team

Agenda item on each board meeting for walking the factory floor and speaking to workers, to ensure leadership understand the reality of the workforce

Team and social activities outside work such as family days

Site’s staff canteen providing food for migrant workers from home countries

Researching important religious and national holidays for different groups of workers to provide cover for workers to celebrate

‘When cultures collide’ by Richard Lewis was recommended to build understanding of cultural traits to ensure effective leadership and collaboration

A number of suppliers have given positive feedback about ‘Emerging Leaders’ training at their sites and in their global supply chains. This training is for the whole workforce, to shift mindsets to take responsibility, work together as a team to find solutions and bring about positive change in the workplace and community.

Running a wellness day on specific themes to promote health and wellbeing on your site.

• ‘Mental Health toolkit for Employers’ from Business in the Community, sponsored by Public Health England https://www.bitc.org.uk/toolkit/mental-health-for-employers-toolkit/

• Emerging Leaders training. www.emerging-leaders.net

USEFUL LINKS AND RESOURCES FOR A GREAT PLACE TO WORK

BERRY WORLD – Mental health training Established in 1994, BerryWorld have worked with experts to develop and grow great berries which are supplied into M&S. They source from worldwide growers in 25 countries. In 2018, the company initiated an internal, bi-annual Grower Ethical Forum to assist their UK growers to make progress with ethical and HR issues. At a recent forum, growers raised concerns about worker welfare, related to a changing demographic of labour, particularly around alcohol use, gambling and fights etc. This led to a discussion around mental health and this was identified as an area for further work and support.

Working with MIND, BerryWorld organised two training sessions for growers on mental health (including depression and anxiety) that helped participants to spot early signs of a problem, build confidence to help someone with a mental health problem, prevent people from hurting themselves

or others, reduce stigma and give guidance towards the right support. The 2 day training, aimed at representatives that have direct contact with the workforce, enabled attendees to become qualified mental health first aiders.

BerryWorld has recognised that good mental health means that workers feel and function better and that it can encourage positive work behaviours. It is essential to wellbeing, teamwork and productivity. They are working to ensure their growers have workplaces that are open and understanding where people feel confident to speak about mental health and where they are well supported.

C A S E S T U D Y

Wellness Day at Cranswick, with their Occupational Health Nurse taking blood pressure and running sessions on smoking and healthy eating

ETHICAL

39

11 T A L E N T M A N A G E M E N T

Talent Management means providing opportunities for all staff to develop and progress and building a strong talent pipeline.

For a business to thrive and grow, it needs to give its workforce training and development to empower them to excel, to be able to give their best to the business’ success and to progress within the company. There are many ways you can do that and this section gives some suggestions but you will be best placed to decide what works for your business.

TALENT MANAGEMENT

PEOPLE MANAGEMENT

TRAINING for managers

CULTURE that values and

promotes Training Development

SUCCESSION PLANNING PROCESS

to grow internal talent

I II III

DEVELOPMENT OPPORTUNITIES

for additional skills

ObjectivesAppraisals & Targets

Learning Plans/Training Matrix

PERFORMANCE MANAGEMENT

PROCESS

Includes agency Covers

all shifts

Appropriate for capacity of workforce

e.g. language

COMPREHENSIVE TRAINING MATRIX

AND PLAN for workforce

4140

S U G G E S T E D S T E P S T O T A K E T O I M P L E M E N T

G O O D T A L E N T M A N A G E M E N T

o Meets local and national legislation

o Completes statutory and mandatory training relevant to the business

LEGAL/MINIMUM REQUIREMENTS

ETHICAL

1

o Training and Development is championed by a named senior manager, who promotes and supports learning (detailed in JD and reviewed in appraisal)

- Could be HR manager or another senior manager if there isn’t a dedicated HR resource

- Or named external provider appointed with appropriate experience

o People management training provided to those with responsibility for staff

- Managers receive training on how to manage people as well as dignity and respect training

- Signed records of training for all managers

o Performance management process in place for managers and senior staff including:

- Job descriptions that clearly state what a good job looks like - Objectives and targets are agreed - Documented annual performance review process - Training ‘needs assessment’ completed and Personal

Development Plans agreed

o Basic level of annual appraisal in place below managers - At least down to team leader and key operators, with a plan

in place to include all workers - This should include line KPIs, job performance assessments

and a training matrix - Plan is in place to develop from basic to more formal/

detailed performance reviews

o Basic training matrix in place covering mandatory training and on job training on specific tasks

2 STEPPING IN

o People management is linked to business needs and is understood by all

- Managers have SMART objectives linked to business goals

- Strategic and operations skills and competency training provided

- Managers apply a range of supporting, coaching and delegation techniques

o Effective Performance Management process for all staff in place and supporting improvements in turnover, progression and engagement

o Comprehensive Training Matrix linked to business needs, showing training options for skills/competency based training accessible to all workers including agency workers

o On-site training capability across shifts, so that training is available for workers on all shifts

o Workforce capability assessment completed to ensure effectiveness of training programmes including language, literacy etc. with appropriate support for workers whose first language is not English (or relevant local language) and review process in place to recap training and check understanding

o Development opportunities for additional skills available for all levels of staff, so workers feel they can progress. Relationship with training providers off site to give staff opportunities to use those facilities

o Effective succession planning process to grow internal talent

- Process to identify workers with potential to progress and this is well communicated

- Opportunities for promotion and sideways development are available at all levels

- Gender and diversity analysis is completed and fed into succession plans

- Evidence that workers have progressed (e.g. % of workers promoted and % of roles filled internally by seniority, gender and BAME)

o Well-developed apprenticeship schemes in place, to improve skill levels of the workforce

- Open to internal and external candidates - In the UK, this is maximising the apprenticeship levy

to develop skills at the site - Evidence that the apprentices have found permanent

roles at the end of the scheme (at the site and elsewhere)

3 STEPPING UP

o Staff have access to learning facilities to improve knowledge and skills

- Culture that encourages workers to come forward for training, with a procedure to allow staff to access training and a focussed route for workers to learn more skills

- Can show how many workers benefit from the services - Learning centre is open to staff and actively promoted - Professional development promoted through various learning

methods (e.g. e-learning, blended learning, communities of practice) - On site library/computer room

o Life skills training available to all workers (including agency) - Depends on needs and could include: health, computer skills,

language, maths and English (or local language) - Can demonstrate how many workers have benefited and how

needs were assessed

o Highly trained flexible workforce at all levels (a leader in promoting and providing training)

- High % of workers with portable externally recognised qualification and a high % with accredited training

- Sophisticated training matrix for all workers - Links with external training providers - Union/ workers involved and engaged when developing

learning/training - Opportunities to cross train and learn new skills especially

when there are changing requirements e.g. automation

o Strong culture of internal progression and promotion

o Strong Performance Management Culture embedded at all levels - Embedded feedback environment including formal and

informal performance feedback to staff (less reliance on just a formal process)

- Reward and performance linked - Focus on development and improvement throughout the year

(not just an annual event)

o Proactive talent management, so that succession planning is embedded

- Talent management plan looking at short, medium and long term site needs

- Talent pools identified at all levels to meet needs - Gender balancing is integral to the process and includes

a focus on developing women managers - Diversity also considered as part of process - Most roles filled internally including offering permanent roles

to agency workers - ‘Grow your own’ and ‘Grow your successor’ are embedded

o Strong Leadership Development Programme - Leadership and management capabilities defined and include

customer needs, taking the lead, innovation and motivation - Programme in place to support the development of current

and future managers (including peer evaluation and upward appraisal and coaching for senior managers)

- Managers support a learning and development culture and self-development is encouraged at all levels

- Leaders contribute to wider business, industry and community - Leaders are aware of own management style and seeking

to improve it

4 STEPPING BEYOND

Check your progress

12 Y O U N G W O R K E R S

Systems are in place to monitor young workers and provide them with support and that young people have the opportunity to gain work experience to help them find work.

M&S and our food suppliers have put significant emphasis in recent years on helping young people access and integrate into the workforce. We particularly want to enable young people achieve their potential who might for various reasons have barriers to entering work. We also encourage our suppliers to think beyond this, to support other groups to get back into work. This is extremely rewarding and not only gives sustainable benefit to the community but also benefits the businesses in their recruitment. This section also covers the processes necessary to ensure that no one under the legal age is working and that there is the proper protection and provisions for young people at work.

42

E N G A G I N G A N D E M P L O Y I N G Y O U N G P E O P L E

There are a number of ways your company could consider taking positive action in this area of recruiting and training up the leaders of the future:

• Providing engaging sessions for primary, senior schools and youth groups to share about careers in food manufacture and agriculture and offering ‘work experience’ for young people

• Providing industrial placements during college courses

• Promoting graduate jobs in partnership with local colleges

• Offering apprenticeship schemes

• Young worker summer projects, promoting work opportunities in students summer holidays

• Develop a ‘Movement to Work’ program with work placements that combine employability skills training with on-the-job experience.10

Apprentice Cameron Payling at Dawnfresh

LEGAL/MINIMUM REQUIREMENTS

o Meets all local and national legislation- No workers under the legal age working on

site11, which requires effective and documented policies and procedures for checking workers’ ages, with training for relevant personnel

o Can demonstrate that age-verification checks are done for all workers and records are kept for young workers (15-18)12

o Investing in programmes to “Get People Back to Work” to support local communities and secure trained staff for the future of the business, including employability skills for NEETs and/or programmes for harder to each communities to support them to get back to work e.g. ALP Open to Opportunity Programme, the New Futures Network, Centrepoint.- Programmes developed reflect the needs identified by an assessment

for example ONS data, number of NEETs but also other communities such as ex-offenders and homeless

- Success is demonstrated by the numbers that find work at the end of the programme

o HR Management system clearly identifies young workers

o Young workers supported to advance and achieve learning goals e.g. mentor/supervision scheme

S U G G E S T E D S T E P S TO TA K E O N E M P L OY I N G

YO U N G P E O P L E

43

ETHICAL

• UK information on apprenticeships for employers and apprentices.https://www.gov.uk/topic/further-education-skills/apprenticeships

• CIPD Guide to employing young people for SMEs. https://www.cipd.co.uk/knowledge/work/youth/sme-guide

• Employability programmes in schools. https://www.igd.com/charitable-impact/feeding-britains-future

• Resources for teaching children about food and farming- Farming & Countryside Education (FACE). www.stem.org.uk/

resources/collection/3832/farming-countryside-education- Food a Fact of Life. www.foodafactoflife.org.uk

USEFUL LINKS AND RESOURCES FOR YOUNG WORKERS

DAWNFRESH - Social Mobility Programme ‘Movement to Work’ Many M&S suppliers have participated in the ‘Movement to Work’ scheme and have helped a huge number of previously unemployed youth into work.

Based in Scotland, Dawnfresh is one of the UK’s largest processors of fish and seafood. In order to improve their success at attracting and retaining staff, they worked to provide opportunities for those with no positive destination when they leave school, and those with barriers to work for example with Additional Support Needs (ASN). They have also been engaging with those who are long term unemployed and those with a carer background looking to get back into the workplace. Working with a number of external partners, the programme provides a rotational work experience placement, giving the candidates exposure to the multifaceted elements of food production. Once they have successfully completed

their four week placement, they have the potential to be offered a direct, full time contract with Dawnfresh.

This has allowed the business to reach an important demographic that they see as playing a key role in their company’s success and has also provided a positive destination and a sense of purpose and belonging to participants, helping them to reach their full potential. Existing employees also have the opportunity to share their knowledge and take great pride in seeing candidates progress. There are a number of success stories of people who have come through the employability programmes into permanent employment and into a journey in a career they are passionate about, that previously didn’t seem an option to them.

CHOCOLAT FREY – Apprenticeships Chocolat Frey AG, based in Switzerland and part of the Migros Group, has worked hard to develop a good educational program for both its apprentices and all other employees, which is continually being improved. This program is linked to the employee performance and development process, in order to provide the most appropriate learning package for

each employee, including leadership courses at all levels. One of their apprentices commented, “What I particularly like about my apprenticeship is that it offers a lot of variety. I change department three times a year and see different areas. In addition, I feel valued and respected as an apprentice and get the opportunity to work independently.”

C A S E S T U D I E S

10 www.movementtowork.com11 In England, under 18s must stay on in Full time or Part time education and they cannot work more than 20 hours per week in a work-based scheme such as an apprenticeship scheme

(other parts of the UK have not adopted this and therefore the young person regulations still apply).12 Including copies of passport/ID, birth certificate, school leaving certificate and if in England, the evidence of the apprenticeship scheme they are part of.

13 STEPPING UP

o Well-developed training/ apprenticeship programme to attract young people into a career in food manufacturing or agriculture, presented to local schools

o Established Youth Employability Programme for NEETs that has led to employment for participants

o Established Harder to Reach Groups Programme that has led to employment for participants

o Proactively developed links with youth and adult organisations to promote working in food manufacturing and agriculture (e.g. youth clubs, homeless charities, ex-offenders support, NHS support services)

4 STEPPING BEYOND

Checkyour progress

o Young workers are clearly identified (updated list including agency), hours of work monitored where necessary and extra support is provided

o Clear defined approach to young workers and apprentices, including a documented policy listing jobs/tasks allowed and not allowed e.g. not hazardous work or at night

o Young workers (15-18) are rewarded fairly

o Risk assessment for all young workers to ensure extra support where necessary (e.g. additional H&S protection)

2 STEPPING IN

44

13 H U M A N R I G H T S

Effectively managing human rights means that suppliers meet legal standards and understand and drive ethical labour standards so that the rights of every worker are protected.

Human rights are fundamental principles which allow an individual to lead a dignified and independent life, free from abuse and violations. In today’s complex and uncertain world the upholding of these rights remain as important as ever. Some human rights violations, such as modern slavery, are also serious crimes where some of the most vulnerable people in society are exploited for criminal gain. These are issues which by their very nature are often hidden and the root causes are extremely complex.

In an increasingly interconnected world with high expectations around transparency, there is closer scrutiny of corporate impact on people and communities. It is widely acknowledged that businesses can affect individuals’ human rights and have a responsibility to respect them within their sphere of influence.

At M&S, we have a long history of respecting human rights in the UK and standing up for those values internationally13. Our product supply chains are extensive and global, numbering hundreds of thousands of suppliers located across 70 countries. As both employer and buyer, we know that we are only as strong as the communities in which we trade.

We strive to be a fair partner – paying a fair price to suppliers, supporting local communities and ensuring good working conditions for everyone working in our business and supply chains. This principle is at the heart of how we do business.

13 https://corporate.marksandspencer.com/sustainability/business-wide/human-rights14 Global Slavery Index 2018

M O V I N G F R O M ‘ C O M P L I A N C E ’ T O A H U M A N R I G H T S

D U E D I L I G E N C E A P P R O A C H

As M&S has developed our ethical and human rights approach over the years we have highlighted the limitations of a compliance based approach. We know that this kind of approach in some cases can force the issues underground where they are more difficult to solve. Instead we encourage our suppliers to use the results of ethical audits to produce a realistic action plan with appropriate actions to tackle the root causes of issue.

We encourage transparency with our suppliers and have made significant efforts to support our suppliers to build capacity to make continuous improvement, with an awareness of the root causes behind issues. We have done this through training, Supplier Exchanges and ‘Seeing is Believing’ visits amongst other activities. We are aware that for real change to happen a deep commitment to tackling issues over time is needed. This is the approach we seek to take and we also encourage our suppliers to take this approach with their own supply chains.

T H E R E A L I T I E S O F M O D E R N S L A V E R Y

I N U K F O O D I N D U S T R Y S U P P LY C H A I N S

40.3 million people are in some form of slavery globally14, including 24.9 million in forced labour.

Modern slavery is very much a reality in UK and European food supply chains with unscrupulous gangs and labour recruiters taking advantage of vulnerable people desperate for work. There have

been many cases of people being recruited from abroad, with false claims about the employment they are going to, and then finding themselves in low paid positions, with unsafe accommodation and transport and in some cases being trapped into that situation because they owe the recruiters money for their transport to the country.

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ETHICAL

M & S L E A R N I N G S F R O M ‘ O P E R A T I O N F O R T ’

On 5 July 2019, eight members of a Polish criminal gang were convicted of slavery, trafficking and money laundering offences. They were part of the largest modern slavery network ever to be uncovered in the UK. ‘Operation Fort’ uncovered vulnerable victims who had been trafficked from Poland with the promise of well-paid jobs. Ninety-two potential victims of modern slavery were identified, although police believe that up to 400 victims in total were exploited by the gang. As the story broke in the press, we became aware that a small number of the victims were working at Sandfields Farms, part of the G’s group of companies, who harvest and pack onions for M&S Food.

Since the Operation Fort case came to light, we have challenged ourselves again to ensure our policies, due diligence processes, risk assessment, training and capacity building programmes are as robust as they can be. This case highlights how critical it is that our business, our suppliers and the labour providers

in our supply chains have the systems, processes and capabilities to highlight signs of Modern Slavery so we can identify and prevent cases like this occurring.

Following the case, we have communicated to all our food suppliers that we know that modern slavery is a risk and recognise those who are proactively managing this issue. We have strengthened our Incident Control Procedure for handling cases of Modern Slavery and undertaken awareness training for our Food colleagues on modern slavery and their responsibilities. However, we have identified that we need to do more to tackle modern slavery and we are currently working with our supplier G’s to explore how a cross-sector intelligence sharing platform could play a role in detecting, preventing and disrupting modern slavery.

Modern Slavery

• M&S is a founding member of Stronger Together and recommends their training for all our suppliers. Stronger Together is a multi-stakeholder business-led initiative aiming to reduce modern slavery particularly forced labour, labour trafficking and other hidden third party exploitation of workers. They provide guidance, training, resources and a network for employers, labour providers, workers and their representatives to work together to reduce exploitation. They offer a range of in-depth, specialist training opportunities on tackling modern slavery including open workshops, e-learning modules and bespoke in-house training. They have active programmes in the UK, South Africa, USA and Spain. https://www.stronger2gether.org/

• M&S Modern Slavery Toolkit, includes a checklist of practical actions to take to tackle modern slavery in your business and in your supply chains. https://corporate.marksandspencer.com/documents/plan-a-our-approach/mns-modern-slavery-toolkit.pdf

• Guidance for identifying and addressing cases of forced labour by SEDEX (2017) - Guidance on Operational Practice and Indicators of Forced Labour. https://www.sedex.com/guidance-operational-practice-indicators-forced-labour/

• Modern Slavery Helpline. www.modernslaveryhelpline.org

• UK Government Guidance on Modern Slavery Statements https://www.gov.uk/government/collections/modern-slavery

• ‘Making a plan for remediation. Tackling Modern Slavery in supply chains. A Guide 1.0.’ Produced by the Walk Free Foundation. https://humanrights.wbcsd.org/project/tackling-modern-slavery-in-supply-chains-a-guide-1-0/

In addition to the above, some of the resources mentioned in the Responsible Recruitment section will also be useful.

USEFUL LINKS AND RESOURCES FOR HUMAN RIGHTS

S U G G E S T E D S T E P S F O R M I T I G A T I N G

H U M A N R I G H T S R I S K S

(

o Embedded Ethical Trading and Human Rights Policy - Governance structure in place - Clear targets and standards set - Taking a human rights due diligence approach and being

proactive to identify and tackle potential risks - Progress and compliance with these targets and standards

are reported at Board level and actions agreed - Resources in place to deliver this

o Proactively adopted UN Guiding Principles for tackling Human Rights issues and implementing the Ethical Trade and Human Rights Policy

- This approach is: Commit / Assess / Act / Remedy / Monitor / Communicate

- Using this approach to tackle issues of Modern Slavery - Human Rights risks are included in broader risk

management process

o Involved in providing remedy for vulnerable workers - This may include: financial support, providing work

experience, volunteering with these organisations

- Working with charities/ organisations that support vulnerable workers

o Leading role in developing and responding to issues of Human Rights

- Leading role in collaborative projects to tackle issues (e.g. FNET, Retailer and supplier projects)

- Engaging with internal and external stakeholders - Challenging the ways of working to proactively find

a different way to tackle and respond to these issues - Assessing performance against external benchmarks to

drive continuous improvements e.g. Corporate Human Rights Benchmark, Oxfam’s Behind the Barcodes

- Risks and opportunities are identified and linked to business strategy

- Responds proactively to serious allegations of human rights issues

LEGAL/MINIMUM REQUIREMENTS

o Meets local and national legislation, including Human Rights legislation including the Human Rights Act, Modern Slavery Act and the ILO Conventions

46 47

G’S - Modern Slavery training and procedures G’s produces salads and vegetables and their grower members are located in the UK, Spain, Senegal, Czech Republic, Poland and the USA. For a business employing more than 2,000 seasonal workers, responsible recruitment and reducing the risk of exploitation and modern slavery is a vital area of work. Although G’s group has a central ethical team they have actively decentralised ownership in order to raise awareness in the business units, for example having ‘site champions’ who are responsible for raising awareness, coordinating investigations onsite and delivering a training module internally and on a rolling basis, to all team leaders, accommodation managers and other people-focused roles. They have also rolled out the training and approach to mitigate risks of Modern Slavery in their Spanish subsidiary, adapting it to be practical in the national context, in a country where visibility and awareness on the issue is generally lower.

The training has increased awareness of exploitation, relevant indicators and the complexity of the issues on the ground and has clarified avenues and responsibilities for communication, giving individuals the confidence to report things that might seem insignificant but could be an indicator of a bigger issue. It encouraged individuals in diverse roles to think about how their decisions could affect risk, and

take mitigating actions which could not have been anticipated by a central team alone. The learnings have meant that policies and procedures (for example on responsible recruitment and other areas) have become more practical, people focused and more accurately reflecting the complex reality at site level.

In terms of advice for other suppliers, G’s emphasise that before implementing widespread training, clear procedures need to be developed for escalating indicators of exploitation both internally and to relevant authorities and customers. These procedures need to focus on protecting the victim and the legal case. They also recommend focusing the training resources on those roles most likely to be in contact with victims.

C A S E S T U D I E S

“ The training and awareness we deliver educates more and more people, which results in better treatment of our workforce, better planning for the needed labour, more fair recruitment, improved retention rate, standardisation across the departments and fair treatment of all people. ”

G’s Modern Slavery Site Champion

ETHICAL

1 4

o Member of Sedex - Linked to customer to share ethical data - Self-Assessment Questionnaire is completed and updated

every 6 months - SAQ Management Control Report is reviewed and action

plan agreed every 6 months

o Third party ethical audits take place in line with customer standards. Non compliances are dealt with in a timely manner

o Human Resources have attended Modern Slavery training, at least one person per site (usually HR but could be operations) (In the UK, USA, South Africa and Spain, M&S recommend ‘Stronger Together’, but elsewhere it could be similar modern slavery training that can be demonstrated to be of a similar standard)

- Posters are displayed at the site in appropriate languages - Workers know how to raise concerns - Non UK suppliers need to identify local training providers

that can deliver this training

o Modern Slavery Statement issued in line with regulations (if required)

2 STEPPING IN

STEPPING BEYOND

o Clear and communicated Ethical Trading and Human Rights Policy

- Approved by board and board level responsibility assigned and they own the policy

- Board and senior management level received awareness raising training

- Policy is communicated and monitored for compliance

o Ethical compliance is well understood and embedded - Managers understand the Ethical Trading Initiative Base

Code and customer standards - Third party audits are well managed with minimal non

compliances and of a minor level - This is managed by HR but owned by all managers

o Modern Slavery programme proactively implemented - A number of managers from HR, Operational and

Procurement have attended the training - Awareness training for employee/TU representatives,

managers and workers - Posters visible on site and staff know how to raise queries

o Human Rights risk assessment of own operations and an action plan to tackle risks

- This should include third party suppliers e.g. security, contractors, drivers etc

- Using the forced labour indicators to identify potential risks - Has a process to assess these risks (e.g. ETI HRDD

framework or developed your own) - Action plan is agreed, tracked and progress is monitored

o Review and report on Human Rights on an annual basis - Publish a Modern Slavery Statement (even if not required

by law) or Human Rights update - This is reporting the business’ progress in this area, not just

the actions you have taken - Evidence of steps/actions taken to tackle modern slavery

3 STEPPING UP

Check your progress

MANOR FRESH – Award winning approach to mitigating labour exploitation The UK produce company Manor Fresh Ltd (part of the Fresca Group) has had a long journey with M&S on sustainability, being one of the founding businesses of the M&S Ethical Supplier Exchange. The business has been at the forefront of tackling worker exploitation in the UK for nearly 2 decades. They have been awarded and recognised by UK government (GLAA impact award 2017) and NGO authorities. M&S recognised their outstanding contribution to tackling Modern Slavery with an award in 2017.

• The company is well aware of the shocking realities of modern slavery in the UK, having found cases of gang exploitation in their own supply base, and therefore being deeply committed to tirelessly leading the way in rooting out this crime. Since June 2000 the company have found hundreds of cases of exploitation affecting thousands of victims in the produce industry and since 2001 have provided remedy in every case in their own supply base, where possible.

• In 2019 they were involved in or supported the resolution and remedy of 41 cases of exploitation in the industry and through their charity work provided over 1,000 nights of safe care for rehabilitating survivors.

• Since 2000 they have made a significant impact by delivering awareness training well beyond their workforce and working in collaboration with many partners including Government, NGOs, Law Enforcement, Faith groups, business, local authorities, suppliers, customers, general public and competitors. By 2019 they had trained over 5,500 people (their own workforce is only 172).

• In terms of their own practices and policies they are very focused on looking out for possible indicators of exploitation, with channels available for workers and agency staff to report any concerns,

anonymously if preferred, including a toll free telephone line available in various languages. They have well developed systems to investigate these concerns and provide remedy, in collaboration with the police and local NGOs, where necessary. They have also made their checks on agency providers much more stringent and actively work together with them to prevent exploitation.

• They have been part of many collaborative projects to widen the impact, including inspiring and launching campaigns such as “Investors against Slavery” and

developing a farm-based worker app to provide guidance and reporting tools on modern slavery (search for the ‘Farm Work Welfare App’). They are also now collaborating on an interactive training program with the Wilberforce Institute.

C A S E S T U D Y

“ When you have experienced examples of Modern Slavery, and looked into the eyes of victims affected, as we have, you cannot walk away and must do all that you can to Prevent any reoccurrence and Prepare for when you may find it. Then you have a duty to Protect those you find and work with authorities to Pursue those responsible. This cannot be done alone, and you must collaborate at every opportunity. ”

Shayne Tyler, Group Compliance Director at Fresca Group and Director of the West Midlands Anti-Slavery Network

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A P P E N D I X

S U M M A R Y O F U S E F U L L I N K S A N D R E S O U R C E S

USEFUL LINKS AND RESOURCES FOR RESPONSIBLE RECRUITMENT

• The Responsible Recruitment Toolkit (RRT). Responsible Recruitment is a strategic priority for M&S, understanding that this can be a crucial step in tackling labour exploitation. In 2019 M&S became a Founding Sponsor of the Responsible Recruitment Toolkit. This enables businesses throughout our global supply chain to gain free access to an online capacity building and self-assessment tool with supporting training on embedding ethical and professional recruitment and labour supply practices. https://responsiblerecruitmenttoolkit.org/

• Effective communication for multi-language workforces. M&S worked with Co-op and partnered with nGaje and allianceHR to develop this practical toolkit which will be helpful across many sections of this toolkit and is a useful guide on how to effectively communicate with a multi-language workforce during recruitment and induction. https://www.stronger2gether.org/product/effective-communication-with-a-multi-language-workforce-toolkit-for-employers-and-labour-providers/

• Leadership Group for Responsible Recruitment - Institute for Human Rights and Business. M&S is a member of this leadership group, which is a collaboration between leading companies and expert organisations to drive positive change in the way that migrant workers are recruited. Part of this initiative is to apply the ‘Employer Pays Principle’, which is a commitment to ensure that no worker should pay for a job. It is increasingly being adopted by companies across a range of industry sectors and locations and is an essential element of combatting exploitation, forced labour, and trafficking of migrant workers in global supply chains. https://www.ihrb.org/employerpays/leadership-group-for-responsible-recruitment

49

ETHICAL

• ILO Fair Recruitment initiative provides information and resources on fair recruitment of migrant workers including recruitment fees. https://www.ilo.org/global/topics/fair-recruitment

• IHRB - Dhaka principles for Migration with Dignity. https://www.ihrb.org/dhaka-principles

• The International Recruitment Integrity System (IRIS) Standard is designed to serve as a practical tool and guidance for enabling labour recruiters and employers to integrate ethical recruitment principles into recruitment related management systems, procedures, codes of conduct, and social sustainability initiatives. (The Institute of Migration (IOM) is the leading inter-governmental organization in the field of migration). https://iris.iom.int/iris-standard

• Association of Labour Providers (ALP). https://labourproviders.org.uk/

• International Labour Organisation’s Global Action to Improve the Recruitment Framework of Labour Migration (REFRAME). www.ilo.org/global/topics/labour-migration/projects/reframe

• Best Practice Guidance on Ethical Recruitment from the Interfaith Center on Corporate Responsibility. www.iccr.org/sites/default/files/iccrsbestpracticeguidance ethicalrecruitment05.09.17_final.pdf

• Verite’s Fair Hiring Toolkit. http://helpwanted.verite.org/helpwanted

Video on The ILO General Principles for Fair Recruitment https://www.youtube.com/watch?v=omPloHkybZA& feature=emb_logo

• The Association of Labour Providers (ALP) provides resources for using labour providers. https://labourproviders.org.uk/resources

• UK Government Advice on Labour Providers Due Diligence https://www.gov.uk/government/publications/use-of-labour-providers/use-of-labour-providers-advice-on-due-diligence

• UK Government advice on ‘Right to work’ checks. https://www.gov.uk/check-job-applicant-right-to-work

• The Gangmasters and Labour Abuse Authority (GLAA) operates a licensing scheme that regulates businesses who provide workers for the processing and packaging of all fresh food, drinks and other produce, to the agricultural, horticultural and shellfish gathering sectors to ensure they meet the GLAA Licensing Standards required by law. LPs are assessed to check they meet the these licensing standards which include a Fit and Proper Test, prevention of forced labour and mistreatment of workers, health and safety, accommodation, pay, transport, recruiting of workers and contractual arrangements. It is illegal to supply workers without a license or to use an unlicensed labour provider. The GLAA provides resources for labour users. https://www.gla.gov.uk/i-am-a/i-use-workers/

USEFUL LINKS AND RESOURCES FOR AGENCY LABOUR MANAGEMENT FOR UK SUPPLIERS

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It is important that your policies and actions on diversity and inclusion also go beyond gender. Here are some resources to help.

• Closing the Gender Pay Gap. The UK Government provides advice on actions that can be taken to close the gap. https://gender-pay-gap.service.gov.uk/actions-to-close-the-gap

• Toolkit for Gender Equality at work in practice, 100 initiatives by social partners and in the workplace across Europe. http://erc-online.eu/gendertoolkit-etuc/

• Chartered Institute of Personnel and Development provide various resources on Diversity at work. https://www.cipd.co.uk/knowledge/fundamentals/relations/diversity

• ACAS advice on improving equality, diversity and inclusion at work, including their provision of training. https://www.acas.org.uk/improving-equality-diversity-and-inclusion

• Effective communication for multi-language workforces. M&S worked with others to develop this practical toolkit which will be helpful in ensuring information and on site communication is inclusive where the workforce speaks many languages. https://www.stronger2gether.org/product/effective-communication-with-a-multi-language-workforce-toolkit-for-employers-and-labour-providers/

• Business in the Community resources on race equality, including a toolkit on tackling racial harassment. https://www.bitc.org.uk/race/

• Personnel Today provides Steps to take action on ethnic diversity at work. https://www.personneltoday.com/hr/time-for-action-on-ethnic-diversity-in-the-workplace/

• LGBTQ+ Inclusion in the workplace. https://www.myhrtoolkit.com/blog/lgbt-inclusion-in-the-workplace

USEFUL LINKS AND RESOURCES FOR EQUAL OPPORTUNITIES AND INCLUSION

The Partner Africa Business Toolkit7 explores a number of strategies to tackle long hours on pages 58-63, including ‘Direct approaches’ such as changing shift patterns and employing more workers and ‘Indirect approaches’, which involve reducing the need for excessive hours through productivity, quality, HR, communications and production planning improvements. https://www.aim-progress.com/files/125/business-toolkit-complete-final-20-feb-2018.pdf

Ethical Trading Initiative guidance on working hours. https://www.ethicaltrade.org/sites/default/files/shared_resources/eti_working_hours_guidance.pdf

USEFUL LINKS AND RESOURCES FOR MANAGING WORKING HOURS

• Living Wage Foundation UK. https://www.livingwage.org.uk/what-real-living-wage

• Ethical Trading Initiative Base Code Guidance: Living wages. http://www.ethicaltrade.org/resources/base-code-guidance-living-wages https://www.ethicaltrade.org/issues/living-wage-workers/living-wage-resources

• Fair Trade International’s resources on Living Wages. https://www.fairtrade.net/issue/living-wage

USEFUL LINKS AND RESOURCES FOR FAIR REWARD

• Employee Engagement. Who’s sinking your boat? https://www.youtube.com/watch?v=y4nwoZ02AJM

• ACAS gives some useful guidance and advice on employee engagement in their two publications: ‘The People Factor’ and ‘Placing Trust in Employee Engagement’, found at the end of this page https://archive.acas.org.uk/engagement

USEFUL LINKS AND RESOURCES FOR REPRESENTATION AND ENGAGEMENT

• M&S has produced some guidelines on the Workplace Communication Programme (WPC) for managers, project managers and workers. These give more detailed guidelines on Worker Committees (including election process and worker rep training) and also exploring other means of communication. There are also templates for WC agendas, meeting notes, nomination forms etc. These resources can be accessed here: https://www.dropbox.com/sh/lbxku5il6p3exab/AAClawsf4guKjW6BYUqJwF2pa?dl=0

• Ethical Trade Initiative (ETI) Resources on Worker Representation - Entry Points to worker representation. https://www.ethicaltrade.org/resources/entry-points-to-worker-representation

- 5 Steps to implementing Freedom of Association. https://www.ethicaltrade.org/sites/default/files/shared_resources/Implementing%20freedom%20of%20association%20-%20a%20five%20step%20plan.pdf

USEFUL LINKS AND RESOURCES FOR WORKER COMMITTEES OR TRADE UNIONS

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ETHICAL

Worker Hotline• Speak Up. Service provider to set up a confidential phone line for complaints. www.peopleintouch.com

Grievance and disciplinary procedures • UK government guidelines

https://www.gov.uk/solve-workplace-dispute/formal-procedures https://www.gov.uk/handling-employee-grievance/grievance-procedure

• The UK Advisory, Conciliation and Arbitration Service (ACAS) gives step by step guidance on setting up a grievance and a disciplinary procedure (including example procedures). www.acas.org.uk/disciplinary-and-grievance-procedures

USEFUL LINKS AND RESOURCES FOR GRIEVANCE AND DISCIPLINARY PROCEDURES

• ‘Mental Health toolkit for Employers’ from Business in the Community, sponsored by Public Health England https://www.bitc.org.uk/toolkit/mental-health-for-employers-toolkit/

• Emerging Leaders training. www.emerging-leaders.net

USEFUL LINKS AND RESOURCES FOR A GREAT PLACE TO WORK

• UK information on apprenticeships for employers and apprentices. https://www.gov.uk/topic/further-education-skills/apprenticeships

• CIPD Guide to employing young people for SMEs. https://www.cipd.co.uk/knowledge/work/youth/sme-guide

• Employability programmes in schools. https://www.igd.com/charitable-impact/feeding-britains-future

• Resources for teaching children about food and farming - Farming & Countryside Education (FACE). www.stem.org.uk/resources/collection/3832/farming-countryside-education - Food a Fact of Life. www.foodafactoflife.org.uk

USEFUL LINKS AND RESOURCES FOR YOUNG WORKERS

Modern Slavery

• M&S is a founding member of Stronger Together and recommends their training for all our suppliers. Stronger Together is a multi-stakeholder business-led initiative aiming to reduce modern slavery particularly forced labour, labour trafficking and other hidden third party exploitation of workers. They provide guidance, training, resources and a network for employers, labour providers, workers and their representatives to work together to reduce exploitation. They offer a range of in-depth, specialist training opportunities on tackling modern slavery including open workshops, e-learning modules and bespoke in-house training. They have active programmes in the UK, South Africa, USA and Spain. https://www.stronger2gether.org/

• M&S Modern Slavery Toolkit, includes a checklist of practical actions to take to tackle modern slavery in your business and in your supply chains. https://corporate.marksandspencer.com/documents/plan-a-our-approach/mns-modern-slavery-toolkit.pdf

• Guidance for identifying and addressing cases of forced labour by SEDEX (2017) - Guidance on Operational Practice and Indicators of Forced Labour. https://www.sedex.com/guidance-operational-practice-indicators-forced-labour/

• Modern Slavery Helpline. www.modernslaveryhelpline.org

• UK Government Guidance on Modern Slavery Statements. https://www.gov.uk/government/collections/modern-slavery

• ‘Making a plan for remediation. Tackling Modern Slavery in supply chains. A Guide 1.0.’ Produced by the Walk Free Foundation. https://humanrights.wbcsd.org/project/tackling-modern-slavery-in-supply-chains-a-guide-1-0/

In addition to the above, some of the resources mentioned in the Responsible Recruitment section will also be useful.

USEFUL LINKS AND RESOURCES FOR HUMAN RIGHTS

Report written by Hilary Murdoch for Marks and Spencer.

With thanks to:

MX Creative Ltd info@mxcreative.co.uk – Report Design

Jonathan Self https://www.jonathanself.co.uk – The majority of the photographs illustrating this document

(except within case studies and where otherwise stated)

Caroline Hughes

Bakkavor Boston, Flamingo Flowers Spalding, Samworth Brothers Saladworks and

Worldwide Fruit Spalding for hosting photography visits.

All suppliers who provided case studies, insights, and peer reviews of this document.

Published November 2020