Ethical Trade Strategy

Primark is determined that our focus on providing value & quality for customers should not be at the expense of the people in our supply chain. The conditions and treatment experienced by people throughout our supply chains are critically important to Primark. These minimum standards are outlined in our Code of Conduct which all suppliers are expected to comply with as a condition of supplying Primark

Our products are sourced from many countries with diverse cultures and economies. After several years of investigation and exploration, in 2006 we joined the Ethical Trading Initiative. Our Ethical Trade Strategy was reviewed and developed in early 2007. This aims to provide a transparent and structured approach to ensuring Ethical Trade within the business, and for those interested external parties.

Current Position

Primark has initiated risk assessments of the supply base and as a result has implemented an extensive audit programme, using the expertise of specialist and independent audit companies

Although not a requirement of Primark's first year of ETI membership, an Annual Report has been submitted to the ETI, which details our progress and commits to our strategic approach going forward.

In addition, our team has been strengthened by the addition of two experienced Ethical Trading Managers, who will be based within region, in India and China. They will be crucial to the implementation of any remediation programmes agreed with the suppliers , and in supporting suppliers where required.

The Ethical Trade Strategy 2007- 2010

In line with the ETI, Primark's focus is on achieving continuous and sustained workplace improvements throughout our supply chain. We recognise that,where breaches are pinpointed some suppliers may be unable to meet all the terms contained within Primark's Code of Conduct with in a short timescale. However we commit to working with and continuing to support our suppliers to achieve positive progress within reasonable timeframes agreed. Our strategy currently has three phases; each phase will reflect the progress of the previous year.

We are currently active in Phase 2

Phase 1, 2007

Procedures

• Risk assessment process
• Finalise audit procedure
• Establish reporting structure and process

Supply Base

• Supply chain mapping
• Risks assess.

• Carried out third party audits

• Remediation

Stakeholder Partnership

• Complete ETI Annual Report
• Identify fellow members with similar principles and structure to develop collaborative opportunities and benefit from shared learning.
• Develop partnerships with NGO and Trade Union within region.

Training and Awareness Raising

• Include material on Ethical Trade in new employee induction process.
• Strengthen/update in-house awareness raising
• Extend awareness raising and specific training to suppliers
• Develop links with universities and fashion colleges to raise awareness of ethical trade issues.

Phase 2, 2008

Procedures

• Review the activities in Phase 1 and summarise lessons learnt and reflect positively in Phase 2 implementation.

Supply Base

• Supply chain mapping (continued and extended through supply chain)
• Risks assess.

• Carried out third party audits (ongoing)
• Remediation (ongoing)
• Recruitment of regional ET Managers in India/ Bangladesh and China
• Ethical Trade Responsible Manager in each Primark top 250 suppliers
• Verification

Stakeholder Partnership

• Complete ETI Annual Report
• Identify fellow members with similar principles and structure to develop collaborative opportunities and benefit from shared learning.
• Participate in ETI pilot groups in UK and in China, India and Bangladesh
• Develop partnerships with NGO and Trade Union within region ( to address specific issues identified by phase 1 audits).

Training and Awareness Raising

• Include in new employee induction process
• Refresh in house awareness raising
• Extend awareness raising to suppliers
• Develop links with NGO's and other in country resources, within the sourcing countries.
• Develop collaborative approaches with other Retailers where appropriate

Phase 3 –To be published when finalised