1 The boohoo group plc Report to the Board: September 2021 The Rt. Hon. Sir Brian Leveson 1. This is my fourth report to the Board of boohoo group plc (‘boohoo’ or ‘the Group’) and marks the approach to the anniversary of the publication of the Levitt Review (‘the Review’). I continue to applaud the enthusiasm that all at boohoo have demonstrated for the Agenda for Change Programme (‘A4C’) and chart the very real progress that has been made in relation both to the recommendations set out in the Review and also the wider ethical programme upon which the Group has embarked. It marks the movement of A4C into business as usual which is not, of course, the beginning of the end of the process, but merely the end of the beginning. 2. My oversight has continued to be greatly assisted by the role of KPMG who have been involved in advising, but predominantly overseeing, the governance of A4C and assisting boohoo. I have also valued input from Tim Godwin (the former Deputy Commissioner of the Metropolitan Police) who has gone beyond the open source and analytic investigation of the supply chain to consider the underlying challenges faced particularly in Leicester both as a result of cultural background and the dynamics of the relationships of those who work in the garment industry. 3. To such extent as boohoo can seek to address and resolve these issues (aimed at assisting the workforce of their suppliers), they are making very real effort to do as much as possible. In some cases, it is clear that this work is beyond what could be considered as reasonably to have been expected of them: a number of proposals and actions go beyond that which were recommended in the Review. In the ultimate, however, the challenge in relation to the development and enforcement of ethical trading is not one that boohoo faces or can face alone and changes to the way in which the regulatory regime is enforced will be essential. I do not seek to minimise the responsibility of the Group or the impact that boohoo can have but it is abundantly clear that the issues are far wider than any one retailer. So as not to divert attention from the work that boohoo has done and is doing and in the same way that I addressed the legal and regulatory regime as it operates in England and Wales in an Annex to my March report, this wider issue is addressed in a further Annex titled ‘Beyond boohoo’. 4. The main focus of the Review was an investigation of the way in which those employed by or working for businesses in the Leicester supply chain (whether contracted directly to boohoo or subcontracted to suppliers) were treated in relation to remuneration and working conditions along with the responsibility of boohoo to those workers. The response to the Review was clear: while other business entities decided that they would no longer source garments from Leicester, boohoo made the decision to stay and seek to demonstrate a real desire to assist the workforce by ensuring that appropriate working practices were put into place and enforced. Controlling their suppliers meant that sub-contractors were excluded from the supply chain and the present list of suppliers continues to be adjusted by removing suppliers when irremediable breaches of the code of conduct are exposed (although suppliers who are able and willing to correct less serious failings will be assisted to do so). At the same time, new suppliers have been on-boarded and boohoo has
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The boohoo group plc
Report to the Board: September 2021 The Rt. Hon. Sir Brian Leveson
1. This is my fourth report to the Board of boohoo group plc (‘boohoo’ or ‘the Group’) and
marks the approach to the anniversary of the publication of the Levitt Review (‘the
Review’). I continue to applaud the enthusiasm that all at boohoo have demonstrated for
the Agenda for Change Programme (‘A4C’) and chart the very real progress that has been
made in relation both to the recommendations set out in the Review and also the wider
ethical programme upon which the Group has embarked. It marks the movement of A4C
into business as usual which is not, of course, the beginning of the end of the process, but
merely the end of the beginning.
2. My oversight has continued to be greatly assisted by the role of KPMG who have been
involved in advising, but predominantly overseeing, the governance of A4C and assisting
boohoo. I have also valued input from Tim Godwin (the former Deputy Commissioner of
the Metropolitan Police) who has gone beyond the open source and analytic investigation
of the supply chain to consider the underlying challenges faced particularly in Leicester
both as a result of cultural background and the dynamics of the relationships of those who
work in the garment industry.
3. To such extent as boohoo can seek to address and resolve these issues (aimed at
assisting the workforce of their suppliers), they are making very real effort to do as much
as possible. In some cases, it is clear that this work is beyond what could be considered
as reasonably to have been expected of them: a number of proposals and actions go
beyond that which were recommended in the Review. In the ultimate, however, the
challenge in relation to the development and enforcement of ethical trading is not one that
boohoo faces or can face alone and changes to the way in which the regulatory regime is
enforced will be essential. I do not seek to minimise the responsibility of the Group or the
impact that boohoo can have but it is abundantly clear that the issues are far wider than
any one retailer. So as not to divert attention from the work that boohoo has done and is
doing and in the same way that I addressed the legal and regulatory regime as it operates
in England and Wales in an Annex to my March report, this wider issue is addressed in a
further Annex titled ‘Beyond boohoo’.
4. The main focus of the Review was an investigation of the way in which those employed by
or working for businesses in the Leicester supply chain (whether contracted directly to
boohoo or subcontracted to suppliers) were treated in relation to remuneration and working
conditions along with the responsibility of boohoo to those workers. The response to the
Review was clear: while other business entities decided that they would no longer source
garments from Leicester, boohoo made the decision to stay and seek to demonstrate a
real desire to assist the workforce by ensuring that appropriate working practices were put
into place and enforced. Controlling their suppliers meant that sub-contractors were
excluded from the supply chain and the present list of suppliers continues to be adjusted
by removing suppliers when irremediable breaches of the code of conduct are exposed
(although suppliers who are able and willing to correct less serious failings will be assisted
to do so). At the same time, new suppliers have been on-boarded and boohoo has
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committed to manufacturing in Leicester; to that end, it is building a factory at Thurmaston
Lane which the Group intends will be open later this year.
5. The Review made recommendations which extended beyond the enforcement of
employment rights into many other aspects of ethical governance and supply and boohoo
developed its change programme with all parts of its business in mind. These include:
a. Governance;
b. The development of a robust Code of Conduct and contractual obligations for
businesses wishing to supply boohoo1;
c. Onboarding of existing and future suppliers both in the UK and the rest of the world;
d. The provision of support and assistance to suppliers in relation to compliance with
legal, regulatory and code of conduct requirements;
e. Ethical and sustainable product compliance;
f. Training of those involved in buying and merchandising;
g. Internal and external audit: coping with compliance failures;
h. The development of manufacturing at Thurmaston Lane, Leicester;
i. Outreach including the launch of the Garment and Textile Workers’ Trust.
6. The recommendations of the Review were accepted by the Board of boohoo in their
entirety. A number have been subject to adaptation so as to fit with the way in which
boohoo does business although these modifications have not affected the thrust of the
recommendation; they alter only the mechanism of achieving the aim. Each one has been
considered and approved both by KPMG and the Board.
7. By way of summary, there were 17 recommendations set out in the Executive Summary
at Chapter 2 of the Review, along with 7 subsidiary recommendations (or suggestions) not
included in the Executive Summary. The Group sub-divided these recommendations into
34 actions (the performance of which have subsequently been mapped back to the
articulation in the Review). A number were ‘one-off’ but others require continuous review
to ensure that they are enduring and become ‘business as usual’. After providing evidence
to KPMG for confirmation, and subject to the monitoring of continued performance of those
requiring it, boohoo assesses that 26 have been completed and that those remaining are
in progress: it is anticipated that after the Board meeting on 17 September, five more will
be closed leaving only four as outstanding. KPMG will need to verify the completion of
seven of these actions (for example, the publication of the list of suppliers for the rest of
the world at the end of this month which I understand to be on track) and, subject to their
review in October 2021, agree with the conclusion that only four will remain. I am also
satisfied that this is a fair reflection of the state of the A4C programme but entirely endorse
the view that monitoring for a number will be necessary to ensure that the programme has
become embedded as business as usual; that is equally so in relation to the assurance
map and the internal audit regime which must also be part of business as usual. All the
interaction that I have had with boohoo suggests that this is, indeed, the determined
approach of the senior management (and, indeed, those involved in delivering the
business).
11 The Code of Conduct (dated 19 May 2020) can be accessed on the website of boohoo plc at https://www.boohooplc.com/sites/boohoo-corp/files/all-documents/boohoo-code-of-conduct-1.pdf
8. An illustration of the extent to which boohoo has taken on the responsibilities set out in the
Review can be obtained from an examination of the number of senior managers who have
responsibility for aspects of the A4C programme (a number of whom have been
transferred from other duties or appointed to the Group specifically for that purpose).
Under the Group Director of Responsible Sourcing and Product Operations, they include:
a. A Group Head of Sourcing and a global sourcing team (including staff in Italy, Paris,
China and Turkey;
b. A Group Head of Sustainability (including staff concerned with performance
management, carbon, supply chain and waste, product sustainability, packaging
and labelling);
c. A Group Head of Product Operations;
d. A Group Head of Product Compliance (with a team dealing with quality control and
including the ability to conduct laboratory analysis);
e. A Group Head of Quality Assurance supported by a substantial technical team
dealing with each of the business entities;
f. An Ethical Compliance team (headed by the Group Director) and including audit
capability;
g. A General Manager for the factory at Thurmaston Lane (now in the process of
recruiting staff with a view to opening the factory later in the year).
In addition, corporate governance and communications (involving public affairs and
internal communication) have been given enhanced attention; furthermore, internal audit
operates as a check on the business generally.
9. My role has not been limited to that of silent observer (and reporter) of the extent to which
the recommendations of the Review have been implemented. I have attended (albeit
virtually) many meetings covering different aspects of the business and I have continued
to provide challenge not only to the substance of the proposals aimed at maximising the
prospects of successfully implementing the A4C but also to ensuring that the steps which
are taken to ensure legal and ethical compliance can be evidenced and that processes
are in place to deal with any issue that might arise. The critical importance of both process
and evidence can be exemplified in this way. If (as has happened) there is an allegation
that a company in boohoo’s supply chain is not complying with the requirements of the law
or boohoo’s code of conduct, three things need to be capable of being demonstrated.
First, boohoo must be able to show that it undertook a robust process before including the
supplier within its supply chain in the first place. Secondly, boohoo must be able to
demonstrate that it has done all that could reasonably be expected of it to support the
supplier and ensure that it is capable of and complying with the ethical requirements placed
upon it: this includes, for example, being able to demonstrate that the contract for supply
of garments could be completed in an ethical manner and that the checks in place are
sufficient. Finally, boohoo must have a fit-for-purpose process to investigate any allegation
(whether by a whistle-blower using a hot-line or otherwise) so that appropriate steps can
be taken fairly either to remove the supplier from the supply chain or, (for breaches that
do not offend its zero tolerance policies, are not repeated or are otherwise irremediable),
the supplier is provided with appropriate support to correct its failings.
10. Following my earlier reports, rather than analyse the recommendations item by item
(although this is entirely possible), this report deals with the present position in the UK
supply chain, the publication of the supplier list for the rest of the world and many of the
other developments that have taken place over recent months. It will also highlight the
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building of the new factory at Thurmaston Lane; the training opportunities for workers that
are being encouraged within the supply chain; and the grant of charitable status for the
Garment and Textile Workers’ Trust along with illustrations of how the trust is seeking to
assist the ethical development of the industry in Leicester.
Executive Summary
11. There remains no doubt about the determination of all at boohoo (from the Chief Executive
and throughout the management chain and those involved in delivering the business) to
deliver the Agenda for Change. The enthusiasm for the programme has been evident both
at meetings and through their willingness to provide detail and explanation in any area that
I have probed.
12. Following the Review published a year ago, boohoo sub-divided the 17 recommendations
and 7 subsidiary recommendation into 34 actions which it committed to delivering through
its A4C programme. The programme covers the entirety of boohoo’s business (including
areas not covered by the Review) and is intended to address the issues of labour abuse
in the supply chain, sustainability and the other identified challenges including the
weaknesses in corporate governance. After the Board meeting this week and subject to
verification of seven by KPMG next month, boohoo anticipates that only four (all in
progress) will remain outstanding.
13. Although the work undertaken by boohoo to date has been considerable, neither that effort
nor the ultimate completion of A4C will mark the end of the journey. Rather, it will represent
the end of the beginning. As the Group readily recognises and is prepared for, it will be
critical to continue to maintain effective and efficient systems to ensure ethical compliance
across its business practices; these systems must be baked into the way of working and
become business as usual. In relation to the supply chain, this will involve monitoring not
only through audit (which is not the complete answer, simply providing a snap-shot of
compliance at the time) but by regular visits, ensuring access to whistle-blowing hotlines
and engagement with the supplier. The wider picture is analysed in the Annex ‘Beyond
boohoo’.
14. Since the publication of the UK supply chain, boohoo has continued to monitor its suppliers
and has responded to information as it has come to light, removing suppliers from the
supply chain if evidence of egregious breaches of its code of conduct becomes available.
At the same time, it is taking a number of steps to ensure that workers employed by its
approved suppliers are aware of and can exercise their rights. These include working with
community outreach and supporting a training programme pilot aimed at providing workers
with externally accredited training.
15. This month also sees the publication of boohoo’s supply chain outside the UK. The
preparation of this list has involved mapping and auditing a substantial number of factories
in 29 countries outside the UK: 125 auditors from Bureau Veritas have been involved in
the audit programme. The result is that every factory declared within the boohoo supply
chain is now mapped to a supplier.
16. Other recent developments include planning permission for the factory at Thurmaston
Lane with progress on construction sufficiently advanced that the first recruitment fair for
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staff has taken place: it is intended to start work in November. In addition, the Garment
and Textile Workers Trust is now formally constituted by the Charities Commission. It will
be a grant awarding body complementing existing charity, community and NGO initiatives
but, in addition, the Trustees are working with specialist academics from Nottingham
Universities Rights Lab to undertake research better to understand the socio-economic
issues in the city to inform both its purpose and scope.
17. In my report of 23 March, I referred to the need for boohoo to visualise where it saw itself
in two or five years and, by 9 June, I spoke of the development by the Group (approved
by the Board) of the ‘End State Design’ with Key Performance Indicators to spell out the
individual steps to achieve those goals. When fully developed, these will bring together
all aspects of business change. In the meantime, boohoo has also accelerated the
development of its purchasing practices and published a new set of Responsible
Purchasing Practices. These have been created in collaboration with product teams from
across the business and over the coming months there is a comprehensive plan to deliver
the training to every individual across the group who part to play in the design,
development and sourcing of products. Second, after the planned opening of Thurmaston
Lane, every garment quoted for boohoo brands will be broken down into cost components,
thereby giving buyers a better understanding in this area. Third, boohoo has also
developed a sustainability plan with elements concerned with fabric, packaging and overall
carbon emissions.
18. The Group has articulated its aspirations. Its commitment is clear and boohoo is
progressing at a commendable pace on the road to delivery. The challenge will be to
complete the journey and then to sustain and enlarge the transformation to its business.
The Supply Chain
The United Kingdom
19. The effect of the A4C has been to increase the capability and capacity of the ethical supply
team, to undertake unannounced visits (checking time sheets, pay slips, HR onboarding
processes, health and safety and establishing whistle-blowing hotlines). Staff have been
interviewed away from managers and a forensic intelligence gathering exercise has been
undertaken on directors and those with significant control in the supply chain (who, in
addition, have been interviewed). Essentially, the ethical compliance and quality control
teams have aimed at doing all that is possible both to ensure compliance and to provide
support and assistance in relation to quality levels and good works of working (including
the management of sharps in accordance with the Group’s metal policy). Engagement
with the team demonstrates that there is a real desire to support the UK workforce where
that is possible and assist businesses to correct the less egregious breaches of policy,
that is to say that do not offend those for which there is ‘zero tolerance’. Where possible,
the aim is and has been to help rather than simply to exclude.
20. It is reported by those concerned with compliance that they have seen many improvements
and that, generally, there is a real sense of unity with improved communication and
commitment. The on-boarding process and the supplier hub will identify and keep track
on the location of premises which, in accordance with the contract, are required to permit
access for the purposes of inspection and also to comply with other conditions of the code
of conduct including the provision of publicity for the whistle-blower hotline. Checking at
6
premises which might previously have supplied boohoo but no longer do so (to ensure that
there is no unauthorised sub-contracting) is more difficult because those who run these
businesses no longer provide access to boohoo. Having said that, the order app allows
boohoo to link a factory to a supplier and, by extension, when boohoo disengages with a
supplier, a boohoo buyer can no longer place orders with that supplier or that factory.
21. That is not to suggest that boohoo consider that the issues of ethical supply are all
resolved. Without somebody prepared to complain, audit is not necessarily able to identify
transgressions but there have been whistle-blowers. Each report is fully investigated and
then referred to the Supply Chain Compliance Committee or, first, its sub-committee, the
Supplier Due Diligence Financial Review Forum. The upshot is that businesses which
were originally approved in the supply chain have now been removed although, as time
passes, other businesses which have demonstrated willingness and ability to comply with
the code of conduct (and have passed the checks which I have previously outlined) have
been approved.
22. The difficulties should not be underestimated and there is a real challenge obtaining the
information (or the thread to pull to obtain the information) in the first place. There are
many reasons which may, at least in part, be cultural for this reluctance even on the part
of those who have every right to work in the UK. One example suffices. There has been
recent credible evidence (which was identified in a news report but also came to boohoo
through another reporting mechanism that is open to a whistle-blower) that, at a subsidiary
factory which was part of a business contracted directly with boohoo, although the
paperwork in those factory premises supported payment to workers of at least the
minimum wage, part of those wages then had to be refunded to the on-site manager. The
owner of the business was appalled at the allegation having prided himself on the full
compliance of his business and had clearly over-relied on the manager. When confronted,
the manager called for help from a friend (nothing to do with the business) who quickly
attended. The manager was sacked and the owner made it clear that he would reimburse
wages that were paid over to the manager. Thereafter, the other workers asserted that
they had not been required to repay wages and the entire workforce left in support of the
manager. That stance remained the following day when the workforce declined to return
without the manager.
23. Steps were taken by the supplier to remediate the position of any worker who established
the requirement to hand cash back. In fact, with the assistance of a community worker, the
requirement to repay was subsequently evidenced and that worker (now employed by the
same supplier at different premises) was reimbursed for the payments made to the
manager over a period of some months. All the remaining workers, however, resigned and
have since commenced work at premises not approved by boohoo and thus not within its
remit for further investigation. The supplier has taken what has happened very much to
heart and the owner has embarked on his own change programme (evidenced through
material supplied to boohoo) so as to ensure that issues such as this can be and are
captured; he is sponsoring public training on modern day slavery.
24. The Group is engaging with a nominated charity and community centre to engage workers
in relation to their rights and remediation generally is being pursued through an involved
NGO. In appropriate circumstances, where it is appropriate, remediation is a worthwhile
approach allowing workers to retain employment which is both ethically based and safe.
What this example has done, however, is that it has led to further analysis of suppliers with
multiple sites where business owners may have over-relied on a manager to deal ethically
7
and fairly with the workforce. Cultural and community links are clearly of the highest
importance and have to be engaged to ensure that issues such as this can be resolved.
25. It is clear that challenges remain for the internal compliance team and for the ethical
auditors Fast Forward (referred to in my last report). In relation to individual suppliers,
however, boohoo is going beyond audit, the enforcement of the code of conduct and the
provision of whistle-blowing hotlines but is seeking to address the skills of the workers.
Although it will be necessary to wait to see how these develop, a number of new
programmes have either commenced or are being planned.
26. First, boohoo has become involved with external accredited training provision. It has
engaged with KTL training which specialises in training of garment workers with
accreditation provided by NVQ. This has started with a pilot involving five suppliers who
each have up to 6 workers on the programme with trainers visiting the supplier’s premises
each week, working with each trainee for an hour leaving them with homework. An NVQ
Manufacturing Textile Products Level 2 qualification is available after 6 weeks. The
response has been enthusiastic and, after this pilot, will be extended to new workers and
new suppliers. The programme is free of charge to the suppliers.
27. Second, albeit in the future, with the provision of a new manufacturing site at Thurmaston
Lane (intended to be a centre of excellence in garment manufacture), it is intended to
encourage suppliers to visit and attend benchmarking days to learn ways of setting up,
managing and improving the efficiency of their operation, with weekly training sessions
and sharing of best practice. It is also hoped to make use of the apprenticeship levy to
which boohoo is required to contribute by supporting apprenticeships in the workforce of
suppliers.
28. Similarly in the future, boohoo are learning from de Montfort University (‘DMU’) and
Leicester Education Business Co Ltd (‘LEBC’) how the new factory at Thurmaston Lane
can support their aims not only by improving the reputation of garment manufacturing in
the UK but also by providing first hand experience of working in a garment manufacturing
business. It is intended that DMU students can visit and also receive talks on the operation
of a commercial fashion business including buying, designing, merchandising and product
specialism. At the same time, with training providers such as LEBC, it is hoped to extend
this reach into colleges and secondary schools.
29. I appreciate that a number of these proposals (going beyond the specific
recommendations in the Review) have, as yet, to move from the discussion and planning
phase into effective operations but it is important to identify what is visualised not least so
that, as time passes, the extent to which plans move into enduring business as usual can
be tested. The transparency which the Group has shown both in the publication of the
Review and in the publication of these reports carries with it a responsibility to continue
the work that has been proposed. In this regard, as in many others, the proof of the
pudding will be in the eating.
The Rest of the World 30. The task of auditing factories that supply boohoo from outside the United Kingdom has
complexities which did not have to be addressed for those in the UK. First, importers who
provide to the Group may well not manufacture but will obtain product from third party
suppliers whom they will not necessarily have been willing to identify for fear of cut out of
8
the chain with the Group going directly to the manufacturer. Second, working conditions
in other countries are undeniably different to those required in the UK and ethical auditors
cannot adopt a ‘one size fits all’ to the work they undertake: financial due diligence and
analytics possible in this country have not been possible in other parts of the world not
least because of the different approach to corporate liability and reporting. In that regard,
although there are in-country staff in some countries and support by way of open source
investigation and analysis has been provided from the UK (where possible), the on-site
audit work has been undertaken by Bureau Veritas who are well placed to undertake the
work, involved in 140 countries through a network of over 1,500 offices and laboratories
and a workforce in excess of 78,000. As the approved list will attest, this has involved
factories in 29 countries outside the UK with 125 auditors from Bureau Veritas involved in
the audit programme or validating other reputable ethical audits.
31. It is important to appreciate that a number of suppliers source garments from declared
factories. Those suppliers who are based in the UK have been through the same financial
due diligence process as was used to assess the UK suppliers. In relation to factories
outside the UK, each has been visited by Bureau Veritas for audit or has provided third
party evidence of an ethical audit from a recognised auditor which, in either case, can be
matched to the boohoo code of conduct and audit requirements. The result is that the list
to be published at the end of September will be of factories but, as with the UK, these
factories (and the suppliers which contract with them) will remain under review. Those
factories that reveal the egregious ‘non-negotiable’ breaches of boohoo’s code of conduct
or standards set by the International Labour Organisation or the Ethical Trading Initiative
will not be approved but it has been made clear that, although suppliers will be supported,
other breaches will be the subject of further audit with the ultimate conclusion that lack of
sustained and appropriate improvement will mean that suppliers will no longer be able to
remain on the approved list. The Supply Chain Compliance Committee and (in relation to
possible financial irregularities), the Supplier Due Diligence Financial Review Forum has
reviewed global audits by grading and has reached decisions based on the evidence.
32. Given the number involved, it has not been possible for KPMG to be present at these
meetings and to consider the issue of robust and fair process at the time. The firm has,
however, been regularly appraised of the process being followed and, throughout, has had
the opportunity to challenge its application and status. After publication of the list, for the
purpose of being able to report this recommendation as closed, KPMG will be able to
review in retrospect how it has operated. There is nothing to suggest that this will not be
achieved.
33. As suppliers are approved and ‘mapped’ their factories are added to the order app to
increase the visibility of the commitment of each factory. As with the UK, this will allow
boohoo to check up on capacity at those factories which are in the supply chain and will
permit buyers to ensure that capacity at any factory is not exceeded. Also in line with the
UK, this is merely the start of the process and there will be a continued focus on audit and
consolidation; once more, the challenge will be to ensure the approach to suppliers in the
rest of the world is also enduring.
Onboarding New Suppliers or new Factories for existing Suppliers 34. As for the future, one of the ways of ensuring that all who supply textiles can comply with
the code of conduct is to onboard only those businesses which demonstrate that they can
do so. The process is for the details of potential factories to be submitted to boohoo’s
9
Sourcing and Compliance team (soon to be through the supplier hub) and to upload
certified audit documentation which can be reviewed both by the team and by Bureau
Veritas. If an approved certified audit from one of a number of nominated auditors is
available, it will be converted into a boohoo report and be graded based on the boohoo
code of conduct and the International Labour Organisation/Ethical Trading Initiative base
code. If not, the factory will be requested to book an appropriate audit to be completed so
that it provides a graded report. It has to be recognised that few audits will be completely
clear of critical, high or medium rated issues of non-compliance with the high standards
required (green requiring re-audit after 12 months) so, assuming that the factory is
considered capable of remediation (if not, access for the factory will simply be denied), an
improvement plan will be devised and agreed with a further audit after 60, 90 or 180 days
determined by the number and nature of the requirements needing to be addressed.
35. The supplier hub is due to ‘go-live’ in the near future for all new suppliers and new factories
for established suppliers. To that end, on-boarding processes and training have been
completed with all buying teams across all brands. Requirements include social and
ethical compliance criteria created for buyers. Supplier score cards have been created
and rolled out. The scorecards identify production capacity, history of acceptance quality