Marshalls : Modern Slavery Risk Analysis 2021

End

Modern

Slavery

Marshalls plc

Modern Slavery Risk Analysis

2021

Introduction

Our response is multifaceted, and definitely not one size that fits all, but one which seeks to keep the 'human' in human rights

Elaine Mitchel-Hill

Business & Human Rights Director

June 2021

We've learned over time, as we've grappled with and immersed ourselves in the complexities of trying to understand what it is that we can and must do to prevent and eliminate modern slavery, that this is a fast-paced,shape-shifting and dynamic space.

Whilst we know that risk mitigation and compliance are important, it is also for us about developing an approach which puts the victim/survivor at the centre of our desire to identify instances and to respond compassionately and appropriately. It is one which seeks to positively impact the context in which it takes place; not just within our own suppliers, but within the sectors, regions and geographies.

Our response is shaping up to be multifaceted, and definitely not one-size-fits-all, but one which seeks to keep the 'human' in human rights. We've endeavoured to share here our risk analysis approach and processes, transparently share analysis regarding the countries we source from, our salient issues, and importantly our effectiveness in identifying and remediating modern slavery.

We have also shared information regarding the work that we have done over the last 18 months, and continue to do, with Traffik Analysis Hub and the development of its advanced supply chain risk mapping tool for the private sector.

All of this information should be read alongside our 2021 Modern Slavery Statement and our 2021 End Modern Slavery Report.

Modern slavery risk mapping

Marshalls has undertaken, for the fifth year running and will do so annually, extensive modern slavery risk mapping for all countries where it has business operations, sources goods or has supply chains.

Whilst we utilise this information as part of our due diligence process for new goods, materials or services, we also put this alongside internal data and information to help us to better understand modern slavery and human trafficking risks, direct our efforts and resources most effectively, develop engagement programmes with key suppliers in high risk environments and to make plans with our anti-slavery partners regarding remediation for victims. It helps us to clearly identify areas of risk, set clear priorities and to have effective dialogues with a range of key actors regarding the wider systemic change which is necessary.

Marshalls publishes this information to be transparent about the countries from which it sources and also so that it might be easily referenced by others to help identify modern slavery and human trafficking risks.

Photo (front cover)

Photo taken during worker interviews with the International Organisation for Migration (IOM) in Vietnam (credit: Elaine Mitchel-Hill,Business & Human Rights Director, 2019)

Photo (above)

Depicting an IOM representative talking to a supplier employee in Vietnam. (credit: Elaine Mitchel-Hill,Business & Human Rights Director, 2019)

Contents

Introduction

1. Risk Analysis Process
2. Country Risk Analysis by Country

1. Human Rights Due Diligence System
2. Focus on Traffik Analysis Hub
3. Effectiveness and Key Issues

Find out more about Marshalls at:

marshalls.co.uk/about-us

All of this activity is documented in detail in our 2021 End Modern Slavery Report. Download it at:

marshalls.co.uk/sustainability/ modern-slavery

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Modern Slavery Risk Analysis 2021

Risk Analysis Process

You can see our human rights due diligence system on page 7, but in its simplest linear form, this diagram shows the broad stages of our actions to help us understand where our risks may lie. We analyse using Verisk Maplecroft data; use Traffik Analysis Hub data to look at the context of new or existing suppliers, or our entire supply chain; we add to this our own analysis regarding the countries from which we source, the sectors and the commodities; undertake specific slavery and trafficking risk analysis using the Social Responsibility Alliance Slavery & Trafficking Risk Template; undertake ethical audits using the appropriate scope; consider children's rights using the Children's Rights & Business Principles Framework; increasingly use live monitoring in high risk supply chains; undertake specific assessment and bespoke programmes with UN agencies; and offer a whistleblowing hotline in high risk supply chains.

In reality, the process is often not linear. It is a 'live' process which provides constant feedback, and demands constant tending and action.

Marshalls' internal modern slavery scoring matrix consists of data regarding the risk of modern slavery in specific geographies, sectoral risk and product risk. Information is taken from the following sources:

The World Bank - Global Findex Database globalfindex.worldbank.org/

The World Bank - Governance Indicators info.worldbank.org/governance/wgi/index. aspx#reports

United Nations Development Programme: Human Development Reports - Inequality- adjusted Human Development Index hdr.undp.org/en/composite/IHDI

United Nations Development Programme: Human Development Reports - Gender Inequality Index hdr.undp.org/en/composite/GII

Children's Rights and Business Atlas childrensrightsatlas.org/atlas/index/unicef_ elimination_child_labour/2016/

Social Responsibility Alliance

socialresponsibilityalliance.org

Global Slavery Index -

Government Response Rankings

globalslaveryindex.org/findings/

Ratification of Fundamental ILO Conventions ilo.org/dyn/normlex/ en/f?p=NORMLEXPUB:10011:0::NO::P10011_ DISPLAY_BY,P10011_CONVENTION_TYPE_CODE:1,F

World Justice Project - Rule of Law Index data.worldjusticeproject.org/

International Trade Union Confederation - Global Rights Index survey.ituc-csi.org?lang=en

Trafficking In Persons Report

state.gov/trafficking-in-persons-report/

GLAA Labour Exploitation Sectoral Risk

gla.gov.uk/publications/labour-exploitation/

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Country Risk Analysis by Country

We analyse, produce and share transparently Modern Slavery Country Risk Profiles for all sourcing countries as part of our risk mapping and due diligence processes. These profiles map a number of modern slavery drivers: rule of law and resilience to corruption; labour rights; government efforts to combat human trafficking; gender equality; protection of children from exploitation; education, health and standard of living; and access to banking.

The risk profiles here and on the following pages feature suppliers with a minimum £10,000 annual spend. Global data sources can be found on page 2.

Top 5 Countries according to

Marshalls' Modern Slavery Risk

Mapping & Country Profiling

1. Egypt (risk score: 0.47)
2. Vietnam (risk score: 0.50)
3. China (risk score: 0.53)
4. India (risk score: 0.53)
5. Brazil (risk score: 0.57)

Risk score is rated 0-1. The higher the score the lower the risk.

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