Modern Slavery Act transparency statement 2019/20 - B&Q

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Modern Slavery Act transparency statement 2019/20 - B&Q
Modern
Slavery Act
transparency statement
2019/20
2   Kingfisher Modern Slavery Act transparency statement 2019/20

    At Kingfisher, we respect
                                                                   This statement has been published in
                                                                   accordance with the UK Modern Slavery               Company overview
                                                                   Act, which requires businesses to disclose

    human rights and do                                            the steps they are taking to tackle slavery,
                                                                   servitude, forced labour and human trafficking
                                                                   (together known as modern slavery).
                                                                                                                       Kingfisher plc is a home improvement
                                                                                                                       company with over 1,350 stores in nine
                                                                                                                       countries across Europe.

    not tolerate any form of                                       It sets out the steps taken by Kingfisher plc and
                                                                   its UK operating companies, to prevent modern
                                                                                                                       We employ 77,000 people and
                                                                                                                       nearly six million customers shop in our

    modern slavery. However,                                       slavery in its own business and supply chain for
                                                                   the financial year ending 31 January 2020.
                                                                                                                       stores and through our websites and
                                                                                                                       apps every week.

    we recognise that no                                           Our statement covers the six areas outlined
                                                                   in the legislation and takes into account good
                                                                                                                       At Kingfisher, our purpose is to make home
                                                                                                                       improvement accessible to everyone.

    supply chain is without
                                                                   practice, including Home Office guidance.

                                                                                                                       77,000
    risk of modern slavery                                           Responding to COVID-19

                                                                     The impact of the COVID-19 pandemic
                                                                                                                       Colleagues

    and it is our responsibility                                     did not directly affect the contents of
                                                                     this statement which covers the time              1,350+
                                                                     period 1 February 2019 – 31 January               Stores
    to ensure we understand                                          2020. However, the pandemic presents

                                                                                                                       9
                                                                     a huge challenge to society, to business

    these risks and work
                                                                     and to all our colleagues, customers and
                                                                     suppliers, and will have a dramatic impact
                                                                     on demand and our supply chains.                  Countries

    in partnership with our                                          At the time of publication, we don’t yet
                                                                     know the full scale of this impact, but           6 million
    suppliers to identify and                                        we remain committed to supporting our
                                                                     communities, including our suppliers, and
                                                                     governments to manage the COVID-19
                                                                                                                       Customers every week

    mitigate them.                                                   pandemic, and to ensuring the ongoing
                                                                     health and safety of all our colleagues           £11.5 bn
                                                                     and customers.                                    Total sales
3   Kingfisher Modern Slavery Act transparency statement 2019/20

    Our stores
                                                                                                          Our business
                                                                                                          structure
                                                                                                          and strategy
                                                                                                          Kingfisher is a multiformat retailer.
                                                                                                          Our retail businesses occupy
                                                                                                          number one or two positions
                                                                                                          in our core home improvement
                                                                                      Russia              markets of the UK, France and
                                                                                      18
                                                                                                          Poland with over 90% brand
                                                                                                          awareness.

                                                                   Russia                                 Over the last four years, Kingfisher has
                                                                                                          leveraged its collective buying and sourcing
                                                                                                          scale and developed our own exclusive brands
                                                                                                          to differentiate us from our competitors and
                                          UK &
                                          Ireland                  Poland                                 drive sales and gross margin growth.
                                          982 1                    80
                                                                                                          To serve customers effectively today, we
                                                                                                          need to be digital and service orientated, while
                                                                                                          leveraging our strong store assets. Under our
                                                                                                          new strategic plan, Powered by Kingfisher, we will
                                                                                                          utilise our core strengths and commercial assets,
                                                                                                          and ‘power’ our distinct retail formats in order
                                                                                                          to address the significant growth opportunities
                                                    France                  Romania                       that exist within the home improvement market,
                                                    221 2                   35                            returning the business to growth.

        Portugal
        3

                     Spain                                                                     Turkey 3
                     28                                                                        92

                                                                                                          1. B&Q UK & Ireland 296, Screwfix UK & Ireland 686.
                                                                                                          2. Castorama 100, Brico Dépôt 121.
                                                                                                          3. Turkey joint venture not consolidated.
4   Kingfisher Modern Slavery Act transparency statement 2019/20

    Our supply                                                     Goods for resale – supplier
                                                                   production sites by continent (%)
    chain

    The products we sell are currently
    sourced globally from around
    3,250 suppliers that are listed on
    our system in 61 countries and
    there are around 2,970 known
    production sites that supply us
    with finished goods.

    The map shows the percentage of production                                                                             Eastern
    sites by continent based on data disclosed to                                                                          Europe region

    us by suppliers via Sedex (the online supplier                                                     Western             19.85%
                                                                               Americas region         Europe region                                    Asia Pacific
    data exchange).                                                            1.38%                   35.99%                                           region
                                                                                                                                   Middle East region   37.27%
    There are many more indirect suppliers in our                                                                                  1.82%
    extended supply chain, including suppliers of
    raw materials and component parts used in
    the products we sell and buy. Read more in
    ‘Assessing risks among materials suppliers’.                                                                       Africa region
                                                                                                                       0.17%
    We also source goods and services not for
    resale (GNFR) with our 1,000 top suppliers
    accounting for around 85% of GNFR spend.
5   Kingfisher Modern Slavery Act transparency statement 2019/20

    Our target

    We aim to support human rights
    in our supply chain and have one
                                                                   We support a number of external initiatives that
                                                                   aim to protect and promote human rights. We are
                                                                   committed to playing our part in working towards
                                                                                                                          We are committed
    target relevant to our work in this
    area (see table).
                                                                   the United Nations Sustainable Development
                                                                   Goals (SDGs) and are a signatory to ‘Better
                                                                   Retail, Better World’, the British Retail Consortium
                                                                                                                          to playing our part
                                                                   (BRC) commitments on the goals. We are also a
                                                                   member of the UN Global Compact and report             in working towards
                                                                   progress against its 10 principles annually in our
                                                                   Responsible Business Report.
                                                                                                                          the United Nations
                                                                                                                          Sustainable Development
                                                                   We believe it is important to report openly on
                                                                   our approach and progress. Our Modern Slavery
                                                                   Act Transparency Statement was ranked 16th in

                                                                                                                          Goals and are a signatory
                                                                   the 2019 Global Governance FTSE 100 League
                                                                   Table compiled by the non‑profit Development
                                                                   International.

                                                                                                                          to ‘Better Retail, Better
                                                                                                                          World’, the British Retail
       Target                             Progress in 2019/20

       Ensure all suppliers               904, or 68%, of our high-risk production sites have had an
       meet our ethical                   ethical audit in the past two years. 62% of our suppliers
       and environmental
       standards by 2020.
                                          are currently registered on Sedex, the online supplier data
                                          exchange (www.sedexglobal.com).                                                 Consortium commitments
       To monitor progress,
       we require high-risk
                                          Unfortunately, this means that we are currently not on track
                                          to meet our target. We are, however, continuing to focus our
                                                                                                                          on the goals.
       production sites of                efforts on auditing high-risk production sites, and we will
       finished goods for resale          review our approach in 2020/21.
       to have an ethical audit
       by 2020. We assess                 230 GNFR suppliers completed an EcoVadis assessment.
       our suppliers of GNFR              These suppliers represent 42% of our spend with our top
       using the EcoVadis                 1,000 GNFR suppliers.
       assessment.
                                          See ‘Due diligence processes’ for further details.
6   Kingfisher Modern Slavery Act transparency statement 2019/20

    Company policies

    Our policy framework addresses
    human rights and modern slavery                                1. Code of Conduct                   2. Human Rights Policy            3. Supply Chain Workplace          4. Ethical Sourcing Policy
                                                                                                                                          Standards
    and is supported by training. Our                              Our Code of Conduct helps            Sets out our commitment to                                           Our Ethical Sourcing and
    key policies and standards include:                            to promote a culture where           respect human rights, in line     Our Supply Chain Workplace         Supplier Workplace Ethical
                                                                   transparency, honesty and            with international agreements     Standards explain the ethical      and Environmental Assurance
                                                                   fairness are the norm. It sets       and guidelines including:         standards we require from          (SWEEA) Policy sets out our
                                                                   out our personal and shared          the United Nations Guiding        suppliers. These are aligned       approach to ethical audits.
                                                                   responsibilities for meeting high    Principles on Business and        with the Code used by Sedex        The policy requires all high-risk
                                                                   ethical standards. It states that    Human Rights; the International   in the Sedex Members Ethical       production sites of finished
                                                                   all employees have a duty to         Bill of Human Rights (which       Trade Audit (SMETA). This          goods for resale to have an
                                                                   report any potential breaches        includes the Universal            includes the Ethical Trading       ethical audit by 2020.
                                                                   of the Code. The Code includes       Declaration of Human Rights);     Initiative (ETI) Base Code and
                                                                   a section on modern slavery and      the UN Global Compact;            additional elements agreed
                                                                   states our commitment to human       the International Labour          by the Sedex Stakeholder
                                                                   rights and ethical sourcing.         Organisation’s Declaration on     Forum. They prohibit slavery
                                                                                                        Fundamental Principles and        and child labour and set out our
                                                                   Our Code forms part of the           Rights at Work; the Children’s    expectations in areas such as
                                                                   contractual terms and conditions     Rights and Business Principles    health and safety, working hours
                                                                   for all employees and is             and UN conventions on the         and wages, and freedom of
                                                                   integrated into training (see page   elimination of discrimination.    association.
                                                                   15). Our compliance network,         It sets out our commitment
                                                                   including a compliance officer in    to implement due diligence        Our ethical audits check
                                                                   each operating company, helps        procedures to avoid infringing    supplier compliance with
                                                                   us implement our Code.               on the rights of others (see      our Supply Chain Workplace
                                                                                                        ‘Due diligence processes’).       Standards (see ‘Due diligence
                                                                   Our internal audit function                                            processes’).
                                                                   monitors compliance among
                                                                   businesses to the Code
                                                                   requirements, using a risk-based
                                                                   approach to plan their work. The
                                                                   Audit Committee of the Board
                                                                   of Directors receives regular
                                                                   updates on the outcomes from
                                                                   our internal audits.
7   Kingfisher Modern Slavery Act transparency statement 2019/20

    We review our policies annually and update
    them where necessary. During 2020, our
                                                                     a contract to supply goods for resale.
                                                                   — Our Vendor Manual for our goods for resale
                                                                                                                       All reports to the hotline are reviewed and,
                                                                                                                       where necessary, investigated with the outcome      Our Factory
    policies relating to human rights and modern
    slavery will be reviewed by Slave Free Alliance,
                                                                     summarises the key requirements of our
                                                                     policies and ethical audit requirements. It is
                                                                                                                       reported to the Audit Committee of the Board
                                                                                                                       of Directors.                                       Handbook
    a social enterprise and membership initiative
    launched by anti-slavery charity, Hope for
                                                                     usually shared with vendors when we request
                                                                     a quotation.                                      Many employees, including those in our quality,     provides details
    Justice, see page 8. Our policies have been                    — Our Factory Handbook for China, which             buying and logistics teams, will visit supplier
    approved by members of our Group Executive.                      provides details of our Supply Chain              factories in the course of their work. We want      of our Supply
    You can read our policies at www.kingfisher.                     Workplace Standards and shows how these           them to support our efforts to improve supply
    com/sustainabilitypolicies                                       should be applied in the factory reflecting       chain standards by reporting any unsafe or          Chain Workplace
                                                                     local circumstances and regulatory                unethical practices they encounter during
    More information on our governance and
    control framework is in our Annual Report and
                                                                     requirements, is available in English and
                                                                     Chinese and on our website. Over 300
                                                                                                                       these visits. We launched ‘CSR Watch’, an online
                                                                                                                       reporting tool to make it easy to report such
                                                                                                                                                                           Standards and
    Accounts, available at www.kingfisher.com/
    investors/company-reports
                                                                     printed copies of the Handbook have been
                                                                     distributed to suppliers in the Far East. We
                                                                                                                       issues, for our employees in China and the Far
                                                                                                                       East. All reports are investigated by our ethical
                                                                                                                                                                           shows how these
                                                                     will publish Factory Handbooks for suppliers
                                                                     in Vietnam and India during 2020 which also
                                                                                                                       sourcing team. We have provided training to
                                                                                                                       help our teams use the tool and understand
                                                                                                                                                                           should be applied
    Embedding our policies into
    procurement
                                                                     summarise key aspects of local labour law.
                                                                     See www.kingfisher.com/en/sustainability/
                                                                                                                       the types of issues they might encounter.
                                                                                                                                                                           in the factory,
    We embed the requirements of our policies,
                                                                     supplier-resources
                                                                   — Training for our colleagues (see page 15)
                                                                                                                       There were no reports relating to modern
                                                                                                                       slavery made via our whistleblowing line or
                                                                                                                                                                           reflecting local
    Code of Conduct and Supply Chain Workplace
    Standards into our procurement processes in a
                                                                     and suppliers (see page 11).                      other reporting channels in the 2019/20
                                                                                                                       financial year.
                                                                                                                                                                           circumstances
    number of ways:
                                                                   Whistleblowing                                      We require suppliers to maintain a means by         and regulatory
    — Potential new suppliers are informed during
      the tender process of our Code of Conduct,                   — Our whistleblowing policy and procedures
                                                                                                                       which workers can openly communicate and
                                                                                                                       share grievances with management, without           requirements.
      policies and ethical audit requirements,                       enable staff and suppliers to report any          fear of reprisal, intimidation or harassment.
      so they can take these into account when                       concerns, including about modern slavery          This requirement is included in our Supply
      quoting to provide products or services.                       and any other human rights violations.            Chain Workplace Standards and our ethical
    — Supplier contracts include clauses on                                                                            audits check that suppliers have grievance
      compliance with our Code of Conduct,                         Our independent and confidential                    mechanisms in place (see ‘Due diligence
      policies and standards. Our buying offices                   whistleblowing hotline is available to all          processes’).
      review compliance with our ethical audit                     employees (intouchfeedback.co.uk/kingfisher)
      requirements before any vendor is offered                    and suppliers (intouchfeedback.co.uk/kfsupplier).
8   Kingfisher Modern Slavery Act transparency statement 2019/20

    Risk assessment

    We have an extensive global                                                 — Ethical risk matrix: Our ethical risk matrix                           Our salient human rights issues
                                                                                  uses data from Maplecroft to help identify                                                                                  Partnering with Slave Free Alliance
    supply chain so we need to take
                                                                                  the high-risk product areas and countries                              We aim to identify and manage ‘salient’ human
    a risk-based approach, focusing                                               in our goods for resale (GFR) supply chain.                            rights issues.                                       We know modern slavery is not an issue
    on the highest-risk countries and                                             We are currently focused on risks in our                                                                                    that any business can tackle alone, given
    sectors for modern slavery and                                                direct supply chain, particularly labour risks                         During 2020, we are working with a consulting        the complexity of the issues involved,
    human rights issues. We assess                                                among suppliers of finished GFR. We are also                           partner to identify our salient human rights         including aspects of organised crime.
                                                                                  developing approaches to reducing risks                                issues as defined by the UN Guiding Principles       Collaboration with others in the retail
    risk on an ongoing basis using:                                                                                                                                                                           sector and beyond is therefore key to
                                                                                  in the wider supply chain including among                              Reporting Framework. These are the human
                                                                                  raw materials suppliers, see ‘Assessing risks                          rights at risk of the most severe negative           raising awareness, sharing information
                                                                                  among materials suppliers’.                                            impact through our activities. We are also           on risks as well as good practice.
                                                                                — Sedex: We also use Sedex to help us                                    undertaking a review of our high-risk sectors.
                                                                                  assess risks in our GFR supply chain. Sedex                            We will report on this in our statement next year.   To help strengthen our capabilities, we
                                                                                  provides two indications of risk for each                                                                                   have launched a new partnership with
                                                                                  production site – an inherent risk (based on                                                                                Slave Free Alliance, a social enterprise
                                                                                  sector and country) and a self-assessment                                                                                   developed by anti-slavery charity Hope
                                                                                  risk (based on a site’s response to the Sedex                                                                               for Justice. The Alliance works with
                                                                                  risk assessment questionnaire).                                                                                             victims, law enforcement agencies and
                                                                                                                                                                                                              businesses to help bring about a slavery
                                                                                We aim for all suppliers of GFR to be using the                                                                               -free supply chain.
                                                                                Sedex platform by the end of 2020. We are
                                                                                not currently on track to meet our target, see                                                                                During 2020, Slave Free Alliance will
                                                                                page 5 for more detail. Around 2,000 suppliers,                                                                               review our policies and implementation
                                                                                incorporating 2,973 factory sites, have now                                                                                   procedures and make recommendations
                                                                                joined the Sedex platform. This equates to                                                                                    for improvement. They will review our
                                                                                around 62% of suppliers of GFR1.                                                                                              risk assessment process for the UK, and
                                                                                                                                                                                                              also deliver training to our colleagues.
                                                                                We use the results of our risk assessment with                                                                                Our work with Slave Free Alliance is one
                                                                                Stop the Traffik, an organisation dedicated                                                                                   of the steps we’re taking in response
                                                                                to preventing modern slavery and human                                                                                        to modern slavery identified in our UK
                                                                                trafficking, to help us prioritise risk areas in our                                                                          supply chain. See ‘Responding to modern
                                                                                GNFR supply chain.                                                                                                            slavery in the UK’.

    1. This is the percentage of suppliers that had joined the Sedex platform by the end of the Kingfisher financial year (31 January 2020). In order
       to fully onboard suppliers onto Sedex, Kingfisher also requires that suppliers disclose and link Kingfisher to all production sites of finished
       goods for resale (including direct and indirect sites) and work is in progress to achieve this.
9   Kingfisher Modern Slavery Act transparency statement 2019/20

    Goods and services not for resale                                      audited one of our contractors in the UK and
                                                                           found it to meet high standards with a low risk                  We are working
    We are working with EcoVadis, a sustainability
    ratings platform, to help us assess and
                                                                           for human rights. We have a plan in place to
                                                                           undertake further audits with other suppliers.                   with EcoVadis,
    manage risk in our GNFR supply chain. Any
    new suppliers are required to complete the                                                                                              a sustainability
    EcoVadis questionnaire covering four themes                            Assessing risks among materials
    – labour and human rights, environment, ethics,                        suppliers                                                        ratings platform, to
    and sustainable procurement. Their responses
    are reviewed by EcoVadis and a rating                                  In some cases, we can help to influence                          help us assess and
    provided highlighting strengths, weaknesses                            standards in our extended supply chain,
    and risk areas. We have added the EcoVadis
    assessment as a requirement in our tender
                                                                           including among raw material suppliers.                          manage risk in our
    process for new suppliers and set a minimum
    score threshold which must be achieved within
                                                                           For example, we require the wood and paper
                                                                           used in our products to be responsibly
                                                                                                                                            goods and services
    a year of the assessment.                                              sourced, meaning it is certified to schemes
                                                                           such as FSC and PEFC or is certified recycled.
                                                                                                                                            not for resale
    We aim for our top 1,000 suppliers that
    account for around 85% of our GNFR spend to
                                                                           These certification schemes ensure wood is
                                                                           from well-managed forests. Both schemes
                                                                                                                                            supply chain.
    complete the EcoVadis assessment by the end                            are also in the process of developing new
    of 2021. 230 suppliers have done so to date1.                          requirements to increase protection for
    The response rate among existing suppliers                             workers’ rights including strengthening their
    was lower than anticipated and we are looking                          criteria relating to health, safety and labour
    at how we can increase this.                                           issues in the supply chain. More information is
                                                                           included in our reporting, see www.kingfisher.
    Our contracts with new GNFR suppliers in                               com/en/sustainability/about-our-reporting
    high-risk categories now include a ‘right to
    audit’ clause. We have asked some of our                               We use the results of a materiality assessment
    suppliers to undergo a third-party ethical audit                       from 2017, which considered 25 raw materials
    to help us better understand risks in our GNFR                         present in our products, to help focus our work
    supply chain. Our findings show that the level                         on raw materials. This assessed their level
    of risk can vary significantly from supplier to                        of risk for human rights and environmental
    supplier and that not all suppliers in high-risk                       practices. We will update the assessment
    categories will present a high risk. For example,                      during 2020 following our review of our salient
    facilities management have been identified as                          human rights issues.
    a potential high-risk area. However, we have

    1. EcoVadis assessments are completed at a parent company level. Where we work with multiple subsidiaries of the same parent company,
       we therefore use the same EcoVadis assessment. This means one assessment may cover more than one of our top 1,000 suppliers.
10   Kingfisher Modern Slavery Act transparency statement 2019/20

     Due diligence processes
     for modern slavery

     Our due diligence on modern                                    Governance of modern slavery risks
                                                                                                                        Responding to modern slavery in the UK
     slavery issues includes ethical
                                                                    Our Modern Slavery Working Group meets
     risk assessment, ethical audits,                               three times a year and brings together              During 2019, we became aware that a labour    Following this incident, we have begun our
     supplier engagement, training and                              senior managers and ethical sourcing                provider used by one of our suppliers         partnership with the Slave Free Alliance
     broader collaboration, including                               representatives from our group functions            had been trafficking people in the West       to strengthen our due diligence in the UK
     with others in our sector and                                  including procurement (both for GFR and             Midlands area of the UK since 2015. The       (see page 8). We are also sponsoring the
                                                                    GNFR), logistics, property, human resources,        labour provider also worked for suppliers     Responsible Recruitment Toolkit from
     expert partners.                                                                                                   to several other major UK retailers. The      allianceHR, a specialist trade organisation.
                                                                    community, sustainability and legal and
                                                                    compliance. The Working Group coordinates           landmark case, known as Operation Fort,       This provides a package of free training
                                                                    implementation of our business-wide                 resulted in arrests and jail sentences for    and support to help suppliers and their
                                                                    modern slavery action plan covering due             members of the people trafficking gang.       labour providers to embed responsible
                                                                    diligence, ethical audit, supplier and colleague                                                  recruitment practices. It provides good
                                                                    engagement, and training, policy, and reporting.    We were alerted by our supplier in June       practice guidance based on global
                                                                                                                        2019 and immediately set up a steering        standards and includes a self-assessment
                                                                    In 2019, we further strengthened governance         group to coordinate our response. We          process to help suppliers monitor and
                                                                    of modern slavery risks by establishing our         carried out audits at the production sites    improve progress among their labour
                                                                    Modern Slavery Steering Committee made up           of the supplier concerned; conducted a full   providers.
                                                                    of senior directors from risk, corporate affairs    investigation; and collaborated with expert
                                                                    and procurement of GFR. The Committee was           organisations and other retailers to inform   The Toolkit will initially be made available
                                                                    formed after the high-profile Operation Fort        our response. The police investigation        to our suppliers of finished goods in the
                                                                    case in the UK (see ‘Responding to modern           established that our supplier was not         UK, with a view to rolling this out to other
                                                                    slavery in the UK’), to oversee the Modern          complicit in the human rights abuses and      sourcing regions, as well as GNFR suppliers,
                                                                    Slavery Working Group’s response to this issue      that the labour provider used had been        at a later date. We also developed a protocol
                                                                    and support required process improvements,          infiltrated by a criminal gang.               for handling incidents of modern slavery,
                                                                    such as strengthening our due diligence                                                           to help us coordinate future responses
                                                                    process for labour providers in our GFR supply      Following this case, we have reviewed our     effectively and consistently.
                                                                    chain; further training for colleagues; and our     approach to labour providers in our supply
                                                                    partnership with the Slave Free Alliance which      chain. Labour providers can help suppliers    We met with the UK’s Independent Anti
                                                                    supports businesses to tackle modern slavery,       to plan and react efficiently to seasonal     -Slavery Commissioner during 2020 to
                                                                    but also supports victims to rebuild their lives.   demand and production peaks and flows.        discuss our response to this case.
                                                                                                                        However, poor recruitment, supply and
                                                                    The Committee will now report to our                management practices by labour providers
                                                                    new Responsible Business Committee, a               can leave their workers vulnerable to
                                                                    sub-committee of our Board of Directors,            human rights violations.
                                                                    established in early 2020.
11   Kingfisher Modern Slavery Act transparency statement 2019/20

     Supplier ethical audits                                        We require suppliers to act swiftly to address
                                                                    non-conformances and to ensure the welfare        Top five non-conformances by category
     Our most significant human rights and                          of workers. We monitor the effectiveness of
     modern slavery risks are in our supply chain.                  our audit programme by grading suppliers          The majority of non-conformances relate to       The number of non-conformances in
     We continue to roll out our programme of                       and tracking the number and type of non-          health and safety, which include fire safety     the table are from ethical audits carried
     ethical audits for high-risk production sites                  conformances that are found and remedied          issues such as provision of fire extinguishers   out in the past two years (2018/19 and
     of finished GFR (see the ‘Risk assessment’                     (see ‘Effectiveness of measures: supplier audit   and number of fire exits. Other common non-      2019/20). The data covers production
     section for details of how we identify risk).                  results’). 941 production sites have had an       conformances include working hours, wages        sites registered so far on Sedex.
     Each production site identified as high-risk is                ethical audit in the past two years. We aim for   and benefits, and environmental factors.
     required to have a SMETA or equivalent at least                all high-risk production sites of finished GFR
     once every two years.                                          to be audited by 2020 and we are currently at     Non-conformances                                               Number of non-conformances
                                                                    68% (904 sites).
     The audit reviews suppliers’ performance and                                                                     Health, safety and hygiene                                                               6,192
     identifies any instances of non-conformance                    We carry out spot checks on our suppliers and
                                                                                                                      Working hours                                                                            1,624
     with our standards relating to labour standards                carry out regular follow-up audits to ensure
     and human rights, health and safety, business                  improvement within our suppliers’ factory base.   Wages and benefits                                                                       1,358
     ethics and environmental performance. Non-                                                                       Environment                                                                                  749
     conformances are prioritised according to the
     Sedex classifications of minor, major, critical,               Supplier training                                 Management systems                                                                           658
     and business critical. Any instances of modern                                                                   All other non-conformance categories                                                         744
     slavery or child labour would be classified as                 We are collaborating with suppliers to help
     business critical – the most serious breach of                 build their knowledge and understanding of
     our standards.                                                 human rights issues and how to address them.
                                                                    Examples are included in the section
     We set up a new tracker in 2019, to improve                    ‘In practice: supplier engagement’.
     how we monitor suppliers identified as
     having business critical non-conformances.                     In the UK, suppliers of finished goods and
     Any factories with business critical non-                      their labour providers will be able to use
     compliances are recorded as ‘open’ until we                    the Responsible Recruitment Toolkit, see
     have third-party confirmation (via an ethical                  ‘Responding to modern slavery in the UK’.
     audit) that these issues have been resolved,
     and can be marked as ‘closed’. At the end of                   We have held two training sessions for GNFR
     January 2020, we had three factories classified                suppliers to raise awareness about the EcoVadis
     as ‘open’.                                                     platform and answer supplier questions.
12   Kingfisher Modern Slavery Act transparency statement 2019/20

                                                                                                                                                                     External initiatives and partnerships
        In practice: supplier engagement examples
                                                                                                                                                                     We participate in several partnerships aimed
        Excessive overtime                                          Embedding our standards among                    Protecting migrant workers                      at improving standards across the retail sector.
                                                                    sub‑contractors                                                                                  For example:
        Excessive overtime remains a challenge                                                                       Migrant workers are often vulnerable to
        in China and is detrimental to the health                   Our tools and hardware suppliers often           exploitation. In Malaysia, for example, many    — We are a member of an EDRA (the European
        and wellbeing of factory workers. We’re                     work with a large number of manufacturing        migrants end up in bonded labour, working         DIY Retail Association) Working Group, which
        exploring how we can engage suppliers                       sub-contractors. We want to make sure that       for months or even years to pay back debts        aims to develop a collaborative approach
        to address excessive overtime and raise                     these sub-contractors meet our responsible       to recruitment agents.                            to responsible sourcing within the home
        awareness of the business benefits of doing                 sourcing standards.                                                                                improvement sector.
        so, including improved productivity and                                                                      During 2020, we will be working with the        — We are members of the British Retail
        reduced staff turnover.                                     We are running a pilot project with our tools    UN’s International Organisation for Migration     Consortium (BRC) Working Group on
                                                                    and hardware suppliers in China to develop       on a project to help improve working              Ethical Labour and Responsible Sourcing
        During 2019, we worked with one of our                      our approach in this area. Suppliers have been   conditions and protect the human rights           and we are signatories to Better Retail,
        garden furniture suppliers in China. An expert              required to disclose the sub-contractors they    of migrant workers in the Far East. This will     Better World, a collaboration led by the BRC
        consultancy benchmarked the factory’s                       work with and how they select, manage, audit     include training suppliers on responsible         aimed at supporting the UN SDGs in areas
        current position, conducting site visits and                and review sub-contractors. Where we find        recruitment and use of recruitment agents.        including modern slavery and decent work.
        interviews with management and workers.                     that suppliers do not have a robust approach     We will also be training our teams to engage    — We helped establish the Indirect
        This found that working hours are not                       to responsible sourcing, we are working          suppliers on responsible recruitment.             Procurement Human Rights Forum to
        currently accurately recorded and that many                 with them to address this and put in place an                                                      promote collaboration with other businesses
        workers are working excessive hours with                    action plan to meet our standards.                                                                 and Sedex on ways to understand and
        too few rest days. The study also identified a                                                                                                                 address risks associated with GNFR. For
        number of process improvements that could                                                                                                                      example, it has developed a set of standards
        be implemented to improve efficiency in                                                                                                                        for labour providers. We are one of 10 core
        production, enabling the factory to increase                                                                                                                   members who meet on a quarterly basis.
        output and quality while reducing working                                                                                                                    — We have launched a partnership with Slave
        hours, without reducing compensation levels                                                                                                                    Free Alliance, a social enterprise developed
        for workers.                                                                                                                                                   by anti-slavery charity Hope for Justice.
                                                                                                                                                                       During 2020, Slave Free Alliance will review
        During 2019, we held two training sessions                                                                                                                     our policies, implementation procedures
        with factory managers and supervisors                                                                                                                          and risk assessment process for the UK, and
        covering process improvements, worker                                                                                                                          deliver training to our colleagues.
        incentives and attendance management, and
        helped the factory develop an action plan.
13   Kingfisher Modern Slavery Act transparency statement 2019/20

     Effectiveness
     of measures

     We aim to drive up ethical                                     was discontinued for business reasons.
     standards in our supply chain                                  One factory has submitted a corrective
                                                                    action, which is pending a follow-up audit.
                                                                                                                          37
     through our supplier engagement                                The remaining two factories are pending
                                                                                                                          production sites did not meet our minimum standards
     and ethical audits (see ‘Due                                                                                         (i.e. they achieved a business critical grade) of these:
                                                                    investigation and will require follow-up audits to
     diligence processes’).                                         ensure any business critical non-compliances
                                                                    are resolved.                                         33                                        1                                         3
                                                                                                                          production sites                          production site was                       production sites
     Performance indicators                                         During 2019/20, ethical audits identified             resolved the                              discontinued for                          submitted corrective
                                                                    35 non‑conformances under the heading                 non-conformance                           business reasons                          actions and are pending
     We monitor supplier progress and the                           ‘employment is freely chosen’. These included                                                                                             auditor approval
     effectiveness of our ethical audit programme                   one case of employers illegally withholding
     for production sites supplying GFR using a                     worker passports, see ‘In practice: audit
     number of indicators. These include:                           examples’.
                                                                                                                         Supplier production sites – GFR
     — percentage of suppliers and production sites                                                                      by audit grade %                                                   5.8%
       on the Sedex platform (currently 62%)                                                                                                                                                Grade 1
                                                                    Audit grades – goods for resale                                                                         0.4%
     — percentage of sites according to audit                                                                                                                    Business critical                      4.2%
       grades (see pie chart)                                       We allocate grades based on the results of the                                                                                      Grade 2
     — number of sites that failed to comply with                   most recent ethical audit that has been carried                                                                                                               2.8%
       our minimum standards and the number of                      out in the past two years.                                                                                                                                    Grade 3
       these which have been remedied (see ‘Audit
       results’ below)                                              We use the Sedex audit grade classifications
     — top non-conformances identified by                           to develop our own internal grading. The
       category (see table).                                        grades are based on the number of non-
                                                                    conformances identified during the audit, see
                                                                    pie chart:
     Audit results: business critical grades
                                                                    — grade 1 (no non-conformances);
     During 1st February 2019 – 31st January 2020,                  — grade 2 (some observations);
     our buying offices identified 37 production                    — grade 3 (minor non-conformances);
     sites of finished GFR that did not comply with                 — grade 4 (1-3 major non-conformances);                        56.0%                                                                                          30.8%
                                                                                                                                  Grade 5                                                                                         Grade 4
     our minimum standards (i.e. they achieved a                    — grade 5 (4 or more major non-conformances
     business critical grade).                                        or 1-3 critical non-conformances); and
                                                                    — business critical (business critical
     We were able to work with 33 of these sites to                   non‑conformances or 4 or more critical
     resolve the non-conformances. One factory                        non-conformances).                                 The chart shows the audit grades for the production sites that have had an audit in the past two years. It includes the
                                                                                                                         results from the latest full audit at each site. It therefore does not reflect any corrective actions taken or results from
                                                                                                                         follow up audits.
14   Kingfisher Modern Slavery Act transparency statement 2019/20

     A minor non-conformance represents an                                   and work with suppliers to improve factory
     occasional or isolated incident, which represents                       performance grades over time.                                     In practice: addressing business critical issues
     low risk to workers. A major non‑conformance
     represents, for example, a material breach of                                                                                             Withholding passports                           Child labour
     local law which represents a danger to workers,                         EcoVadis scores – GNFR
     whereas a business critical failing represents the                                                                                        During 2019, we identified two cases of         Auditors identified two cases of child labour
     highest level of breach and requires immediate                          230 GNFR suppliers completed an EcoVadis                          employers withholding the passports of          in an electronics factory in China. The
     action. It includes non‑conformances which                              assessment. These suppliers represent                             migrant workers. The production sites were      children were removed from the factory and
     present imminent risk to workers’ safety or                             42% of our spend with our top 1,000 GNFR                          located in Malaysia and Taiwan. We worked       we implemented our standard operating
     constitute a significant breach of workers’                             suppliers. The suppliers achieved an average                      with these suppliers to ensure that clear       procedure. This included: contacting the
     human rights.                                                           score of 55 out of 100. A score of 55 equated                     processes are in place to safeguard worker      parents of the children to make sure they
                                                                             to a silver rating1.                                              rights, and regular re-audits are in place to   were involved in the remediation plan;
     Over time, we aim for our suppliers to improve                                                                                            continually monitor their performance.          medical checks to confirm the children
     performance and require suppliers with low                                                                                                                                                had not been injured while working at the
     grades (5 and business critical) to have an                                                                                               In Malaysia, it was identified during an        factory; and helping the children to return to
     annual re-audit. Other suppliers are re-audited                                                                                           audit visit that a glove-making factory         education. The factory assisted one of the
     within two years.                                                                                                                         was holding passports for safekeeping           children to find a place at a technical school
                                                                                                                                               with a signed consent letter from workers.      and is in the process of securing a place
     We follow-up with suppliers to ensure the most                                                                                            Following our discussions with the factory,     for the second child. We worked with the
     serious issues are remediated. As a last resort,                                                                                          they returned passports to workers. This        factory to improve its human resources and
     we cease to trade with factories if they don’t                                                                                            was verified through a follow-up audit which    recruitment processes to ensure underage
     work with us to address business critical issues.                                                                                         included worker interviews and the factory      workers are not hired in future. Visits by our
                                                                                                                                               received a grade 5.                             responsible sourcing team and a follow-up
     The chart shows the audit grades for the                                                                                                                                                  audit confirmed no further cases.
     production sites that have had an audit in the                                                                                            In Taiwan, passports were held by a labour
     past two years. It includes the results from the                                                                                          provider. These were returned to workers        Another factory, also in China, was found
     latest full audit at each site.                                                                                                           and this was verified through an audit and      to be using an underage worker (aged 15)
                                                                                                                                               worker interviews. A follow-up audit found      on a temporary contract during the school
     It therefore does not reflect any corrective                                                                                              the factory had addressed all business          holidays. The child was removed from the
     actions taken or results from follow-up audits.                                                                                           critical issues and received a grade 4.         factory and received medical checks. The
                                                                                                                                                                                               child returned to her hometown to continue
     We work with sites graded as business critical                                                                                                                                            with her schooling. A follow-up audit
     to resolve the issues (see ‘Audit results’).                                                                                                                                              confirmed that the factory has strengthened
     During 2020, we plan to review how we monitor                                                                                                                                             its HR procedures for hiring temporary staff.

     1. The EcoVadis overall score (0-100) reflects the quality of the company’s CSR management system at the time of the assessment. The
        EcoVadis CSR recognition levels are based upon the percentile ranking of your company’s EcoVadis score. Silver represents the top
        25% of companies. EcoVadis updated their scoring system in January 2020 and this means our results from 2019/20 will not be directly
        comparable with those in 2020/21.
15   Kingfisher Modern Slavery Act transparency statement 2019/20

     Employee                                                       Future plans                                      Transparency                                 Entities covered
     training and                                                                                                     Statement                                    by this statement
     awareness                                                                                                        approval
     Employees complete an                                          Through our Modern Slavery                        This Transparency Statement was              This statement covers Kingfisher plc and all
                                                                                                                      approved in May 2020 by the Boards of        its subsidiary undertakings. This includes the
     e-learning module on modern                                    Working Group, we will continue
                                                                                                                      Directors of Kingfisher plc, B&Q Limited,    following UK subsidiaries with a turnover of
     slavery as part of our Code of                                 to identify risks and implement                   B&Q Properties Limited, Kingfisher           £36 million or above:
     Conduct training. Over 40,000                                  due diligence to help tackle                      Information Technology Services (UK)
     employees completed this                                       modern slavery. Over the next two                 Limited, Kingfisher International Products   — B&Q Limited
     training in 2019/20.                                           years, our key priorities are to:                 Limited, and Screwfix Direct Limited.        — B&Q Properties Limited
                                                                                                                                                                   — Kingfisher International Products Limited
                                                                    — on board all suppliers and production sites     It is signed by the Kingfisher Chief         — Kingfisher Information Technology Services
     Training our buying teams                                        of finished GFR on to the Sedex platform;       Executive Officer who is also a member         (UK) Limited
                                                                    — roll out ethical audits to all our high-risk    of the Board of Directors.                   — Screwfix Direct Limited
     We run regular training sessions to build                        production sites of finished GFR;
     awareness of modern slavery and ethical                        — strengthen our UK due diligence processes,      Thierry Garnier
     sourcing risks among key employees,                              including training for colleagues, through      Chief Executive Officer
     including those responsible for overseeing                       our partnership with Slave Free Alliance;
     our modern slavery due diligence and buyers                    — roll out training and tools on modern slavery
     of products and services.                                        to our colleagues in our sourcing regions;
                                                                    — roll out the Responsible Recruitment
     Our buying offices carry out training for                        Toolkit to suppliers in the UK with a
     appropriate employees on ethical sourcing,                       view to rolling this out to other sourcing
     which includes modern slavery. In 2019,                          regions, as well as GNFR suppliers, at a
     buyers and quality assurers in our Middle                        later date;
     East and Romanian buying offices were                          — conduct a review of our salient human
     trained on responsible sourcing and our audit                    rights issues and high-risk sectors;
     programme and learnt how to identify good                      — continue to roll out EcoVadis assessments
     and poor practices during factory visits.                        to GNFR suppliers and support low-scoring
                                                                      suppliers to improve;
     We will be conducting training during 2020                     — establish a new Responsible Sourcing
     through our partnership with Slave Free Alliance.                Steering Group made up of senior
                                                                      directors to provide strategic oversight of
                                                                      all issues relating to responsible sourcing
     GNFR training                                                    across the business.

     We held four training sessions for our GNFR
     buyers to introduce them to the EcoVadis
     platform so they can encourage their suppliers
     to participate. The sessions were attended by
     90% of our GNFR buyers.
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