Sustainable Sourcing Policy Sainsbury’s

CONFIDENTIAL

© Sainsbury’s Supermarkets Ltd. 2017

Reference Issue Number Owner: Authorised By: Date Page Number

SP003 8 Social Sustainability & Communities

Manager Technical Operations Group 1st April 2020 Page 1 of 15

Sustainable Sourcing Policy – Goods for Resale Sainsbury’s Brand

Introduction

Sainsbury’s Supermarkets is an international business. Our buyers search the world to find new sources of

supply to satisfy the needs of our UK customers. About half of our goods are sold under our own brand

name for which we lay down detailed technical specifications and monitor product quality and production

facilities.

Sainsbury’s is conscious of the responsibility we share with our suppliers for the welfare of workers who

produce the goods we sell (directly and indirectly, in their business operations and within their supply

chains). We seek to develop long-term partnerships with suppliers who share our values and who are

prepared to commit themselves to our Code of Conduct for Ethical Trade which is consistent with

internationally agreed conventions on workers’ rights and the Ethical Trading Initiative (ETI) Base Code

encompassing ILO Core Conventions for decent work. Applying the Code to local circumstances takes time

and requires sensitivity and understanding. Our desire is to see the Code adopted as a minimum standard

and to see suppliers’ performance improving continuously. Our Code also includes a declaration of our

intention to do business on fair terms, to operate transparently and to support suppliers to work beyond our

code. We believe that by adopting and communicating this Code we, in partnership with our suppliers, are

taking practical steps towards improving working conditions for the people who make and supply the

products we sell.

Sainsbury’s has also made commitments to uphold and respect human rights (our Human Rights policy is

located here) decent work and diversity and have signed up to the:

United Nations (UN) declaration of Human Rights

UN Guiding Principles on Business and Human Rights

UN Women’s Empowerment Principles that promote gender equality and women’s empowerment

We would encourage our suppliers to make similar commitments and implement and promote these within

their operations and supply chains. One key area is the provision of effective grievance mechanisms to

enable workers to raise grievances and access effective remedy free from retaliation. These mechanisms

should take account of vulnerable groups such as women, smallholders and worker representatives. We

would also encourage suppliers to publish data on the risks they identify, actions they take and key data

such as gender pay gaps in their operations and relative supply chains.

Scope

The requirements outlined in this document are in addition to all applicable UK, EU and international

legislation and industry best practice. Sainsbury’s suppliers must ensure that they meet all requirements

laid down in law at the point of manufacture and where they are finally sold to the customer. While the

requirements set out below are intended to help you supply products suitable for Sainsbury’s, they do not

absolve you of your responsibility to understand and comply with all the quality, legal and safety

requirements for your products and the people who support your business to make these products.

Who should implement this policy?

This supplier policy is intended for Sainsbury’s direct suppliers, agents, central technical resource and

virtual manufacturers who are responsible for ensuring compliance with Sainsbury’s Code of Conduct for

Ethical Trade.

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Sainsbury’s require a senior member of staff at our suppliers to be accountable for ensuring this policy is

implemented at their production sites and by their suppliers, this member of staff should be communicated

to the Ethical Trade Team (ETT). Sainsbury’s expect technical and human resource staff at direct suppliers

to take operational responsibility for implementing this policy and developing and implementing an ethical

trade strategy in their own operations and to cascade and improve these standards to their supply chain.

How to use it

This document is intended to support suppliers to effectively carry out their ethical trading responsibilities,

and meet Sainsbury’s ethical commitments. It builds on our Code of Conduct and outlines how suppliers

should implement our Code of Conduct.

Please get in touch with your Technologist and the Sainsbury’s Ethical Trade Team if you have any queries

about this document.

Categories this policy applies to:

Fresh Packaged Food:

Meat & Poultry

Fish Produce and Floral

Food Services

Meal Solutions

Canned & Packaged

Impulse Bakery Dairy Frozen

Non Food Grocery:

Baby and Beauty

Beers, Wines & Spirits

Household Pet care Pharmacy and Health

Amendment History

AMENDMENT

Issue Number Date Page or All Detail of Change

8 20th March 2020 All Inclusion of responsible recruitment and environmental clauses

Reference to revised human rights policies and changes throughout first part of document to reflect this

Revised document title

7 8th July 2019 Appendix B on non-conformance gradings removed as

now align with Sedex gradings. Appendix B changed to new mandatory questions for second-party visits from Sainsbury's colleagues.

Appendix C - guidance on third-party audits - updated

with approved audit bodies

Appendix F updated to new version of Guidance for the

Responsible Use of Labour Providers

Appendix J.1 updated to version 2.0 of FPC Guidance on

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provision of caravan accommodation for temporary workers in the UK

Appendix K added - our commitment to the Retailer

Protocol for Handling Reported Cases of Modern Slavery in the UK Supply Chain

Appendix L added - Modern Slavery Checklist – questions to ask to help identify victims of modern slavery

Supplier requirements box - clarifications added and

introduction of 'amber' rating for 1 or 2 major non-conformances. Expectation added to work towards compliance with Appendix F - Sainsbury’s Supply Chain Policy for the Responsible Use of Labour Providers.

Training support - Encourage sign up and use of

Responsible Recruitment Toolkit. Encourage use of free accommodation webinars on Sedex website

6 12 May 2017 All The policy has been condensed from 20 to 10 pages, with guidance documents moved to appendices. Requirements have been made clearer including the management of labour providers. Appendices have been updated including additional guidance on audit process in Appendix C and ethical trade strategies in Appendix E. Two new Appendices have been added for guidance on training and worker accommodation – I and J.

5.1 1 February 2017 Appendix B – pg24-32

Update to appendix B following changes made to Sedex, some of the issue titles and gradings have been updated.

5 14 July 2016 9,11,13,14,20,49 Replacement of INSPIRE with Evolve

4 7 April 2016 All More specific references to audit process and interaction with Sedex system

Suppliers to tell Sainsbury’s their ethical point of contact

Specific reference to checking for voluntary overtime and working hours during ethical visits

Five additional approved audit bodies

Appendix I added for guidance on responsible use of labour providers

Specific guidance on developing an ethical strategy

3 6 October 2014 3.1.6.1, 3.1.6.3 Appendix G & H

Updated clause based on the ETI Base code for working hours and Labour Provider Audit frequency added to state 6 monthly. Newly replaced and updated Appendices G&H.

2 24 April 2014 All Changes to policies and procedures. Updated content and format

1 June 2012 All Update of version 4 of HP008 and addition of supplier Guidance

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External Position Statement – Our Principles

At Sainsbury’s we expect strong social and environmental standards from suppliers, but we

recognise that many need practical help and support in implementing more sustainable practices.

Our challenge is to build supply chains that maximise the positive social and environmental impacts

whilst building resilience to the social and environmental challenges facing the industry, working

closely with farmers, producers and processors to champion and embed excellence in sustainability.

Commitment to Ethical Trade, Human and Gender Rights

Ethical trading is an important company objective. We are committed to providing sufficient

resources to ensure our commitments are fulfilled. We are founding members of the Ethical Trading

Initiative (ETI) and require all our suppliers to meet the Sainsbury’s Code of Conduct for Ethical

Trade which is based on the ETI Base Code for ethical sourcing. Our Code covers 12 key principles,

including safe and hygienic working conditions and payment of a fair wage. We would encourage

suppliers to also commit to:

United Nations (UN) declaration of Human Rights

UN Guiding Principles on Business and Human Rights

UN Women’s Empowerment Principles that promote gender equality and women’s

empowerment

This means taking a broader view and applying a gender lens to all elements of work and reporting

progress and ongoing challenges. Our commitment to ethical and responsible sourcing is ongoing

and we work with suppliers to ensure they continuously improve their performance in these areas.

We also recognise the need to communicate this commitment to key stakeholders including the

public, suppliers and the people who work in our supply chains.

Fair Terms of Trading We recognise the contribution that stable business relationships make to the observance of good labour practices and endeavour to establish long-term and productive relationships with our suppliers. We are committed to dealing openly and fairly with suppliers including smallholders, adhering to contract terms and avoiding the exertion of undue pressure. Building the Capacity of Ourselves and Others We are aware that both colleagues and our suppliers’ staff need to understand the importance of ethical trade and that they must be able to identify and resolve ethical issues. We are committed to providing guidance, training and support to suppliers where needed and to ensuring workers in our supply chain are aware of the provisions of the Base Code and our commitment to ethical trade. We view effective management systems as crucial for monitoring and tracking our own and suppliers’ issues. We view it as essential that workers have knowledge of their rights and are able to report any issues confidentially and without detriment to a designated person/committee. Monitoring our Supply Chains We recognise the importance of being aware of labour practices in our supply chains and the need to monitor, evaluate and act on information about our suppliers’, sites’ and growers’ performance. To do this, we use a range of tools including independent, third party audits of suppliers and sites, self-assessment questionnaires and confidential mechanisms for workers to highlight issues. We view access to grievance mechanism and facilitating effective worker and supplier communication as critical for identifying and resolving supply chain issues. Being Transparent We aim to be transparent with all our stakeholders on our ethical trade performance and would encourage our suppliers to do likewise. We appreciate that you might be worried about sharing issues with us; however it is better that we understand and work together to improve the situation.

Together, we aim to respond rapidly and fully to ethical issues in our supply chains.

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Table of Contents

Introduction ........................................................................................................................................... 1

Amendment History ............................................................................................................................... 2

External Position Statement – Our Principles .......................................................................................... 4

Sainsbury’s Code of Conduct for Ethical Trade ........................................................................................ 7

Supplier Requirements and Rating Definitions ...................................................................................... 10

Supplier Management of Third-Party Audit Process .............................................................................. 13

Red and Amber Rating Criteria for Overdue Non-Conformances in Third-Party Social Audits ................ 14

Forms ................................................................................................................................................... 14

Training Support .................................................................................................................................. 14

Modern Slavery ........................................................................................... Error! Bookmark not defined.

Triggers for Policy Review ..................................................................................................................... 15

Appendices as separate documents:

Appendix A – Glossary & Q&As

Appendix B – Mandatory Questions for Second-Party Visits

Appendix C – Third Party Audits

Appendix D – Second Party Ethical Visits

Appendix E – Ethical Trade Strategies

Appendix F – Sainsbury’s Supply Chain Policy for the Responsible Use of Labour Providers

Appendix G – Example of a Completed Appendix H for Exceptional Non-Conformances

Appendix H – Exceptional Non-Conformance Action Plan

Appendix I – Sainsbury's Supplier Ethical Trade Training Links

Appendix J.1 – Guidance on Worker Accommodation

Appendix J.2 – Worker Accommodation - Risk-Assessing Guidance

Appendix J.3 – Worker Accommodation Risk Assessment

Striving for Improvement

We recognise that many ethical trade issues can take time and effort to resolve. As a minimum, we require our suppliers to work towards compliance with our Code of Conduct or the local law – whichever provision affords the greater protection to workers. We expect suppliers to work to resolve issues identified in a timely manner and to engage workers’ organisations in identifying and resolving issues. In the longer-term, we will work with suppliers and workers to develop best practice on ethical trade and positive examples which secure workers’ rights alongside benefiting our suppliers’ businesses and our own. As a business, we take a collaborative and supportive approach when serious issues are raised, rather than cutting off the relationship. We seek to help suppliers on their ethical journeys and support them through meetings, capacity building and collaborative forums.

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Appendix K – Retailer Protocol for Handling Reported Cases of Modern Slavery in the UK

Supply Chain

Appendix L – Modern Slavery Checklist – questions to ask to help identify victims of modern

slavery

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Sainsbury’s Code of Conduct for Ethical Trade

Sainsbury’s Code of Conduct for Ethical Trade is based on the Ethical Trading Initiative (ETI) Base Code,

with an additional three clauses unique to Sainsbury’s. For more detailed information on the ETI Base Code

containing the clauses in full, see the ETI website: http://www.ethicaltrade.org/eti-base-code

Entitlement to work

Only workers with a legal right to work in the country should be

employed.

For both workers and agency workers, original

documents should be reviewed and then

returned to workers to verify right to work.

Labour agencies

Labour agencies should only support workers registered by them.

Relationships with labour agencies should be

covered by a Service Level Agreement which meets all national legal

requirements.

Labour agencies should be audited on a regular

basis to ensure compliance with national

requirements.

Protection of the

environmentSuppliers, sites and

growers shall carry out their activities in

accordance with national laws, regulations,

administrative practices and policies relating to the preservation of the

environment of the countries in which they operate as well as in

accordance with relevant international agreements,

principles, objectives, responsibilities and

standards with regard to the environment.

http://www.ethicaltrade.org/eti-base-code

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Management Criteria

Accountability: You should have a senior manager responsible for ensuring this policy is

implemented within the supplier businesses and their supply chain.

Modern Slavery

The Modern Slavery Act 2015 requires all companies with an annual turnover of £36 million or more to issue a statement each financial year about the steps taken to address modern slavery and human trafficking across their business and supply chains. Suppliers must comply fully with the provisions of the Act, if they apply to you. All suppliers should be prepared to provide Sainsbury’s with information on their actions, including risk assessment, mitigation and training, in order to enable us to prepare our annual Modern Slavery Statement. Through membership of the Consumer Goods Forum, Sainsbury’s has made a specific commitment to embed the Priority Industry Principles on Forced Labour in its own operations and value chains. These include:

Every worker should have freedom of movement

No worker should pay for a job

No worker should be indebted or coerced to work Although these principles are outlined in the above Code of Conduct, we have specific expectations around recruitment fees as follows:

Suppliers shall seek to ensure that when they recruit directly and/or engage labour recruitment agencies, recruitment and relevant travel fees1 are paid by the supplier or agency and will prohibit prospective workers from paying fees associated with the recruitment process. This means you must pay enough to worker/agents to cover cost of recruitment and relevant travel.

We recognise that it takes time to understand the definition of recruitment fees and to implement appropriate responses. We are working with suppliers across our business to understand the extent of recruitment fees in our supply chains and encourage suppliers to make use of the training resources to raise awareness and take preventative actions.

For guidance please refer to Training Support section below

Environmental Criteria

1. Protection of the Environment

12.1 Suppliers, sites and growers shall carry out their activities in accordance

with national laws, regulations, administrative practices and policies

relating to the preservation of the environment of the countries in which

they operate as well as in accordance with relevant international

agreements, principles, objectives, responsibilities and standards with

regard to the environment.

12.2 The supplier must identify significant environmental hotspots and

conduct impact assessments in the following areas

a) Material use (where produced for and supplied to Sainsbury’s)

b) Use of chemicals

c) Energy Management and GHG emissions

d) Water management

1 ILO definitions and those described in the Responsible Recruitment Toolkit

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e) Biodiversity

f) Waste prevention and disposal

g) Air emission

12.3 The supplier shall have environmental improvement plan with objectives

and targets documented.

12.4 The supplier must be able to demonstrate environmentally sound

manufacturing practices and measure emissions for water, air and land.

12.5 The supplier must be able to demonstrate that environmental

considerations are taken into account in the design of product or

services, by considering energy consumption, material use and end of

life disposal.

12.6 The supplier must ensure its employees, subcontractors and suppliers

comply with Sainsbury’s environmental requirements and all applicable

legal requirements.

12.7 The supplier must inform Sainsbury’s if a significant environmental

incident occurs at supplier’s premises and/or as a result of supplier’s

activities.

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SP003 7 Ethical Trade Manager – Food/ Drink/

Household/ Health & Beauty Technical Operations Group 8th July 2019 Page 10 of 15

Supplier Requirements and Rating Definitions

These requirements must be reviewed annually by suppliers. Compliant to Policy – all areas achieved Minor non-conformance (NC) - Absolute compliance to Sainsbury’s requirements has not been met, but on objective evidence, the conformity of the product is not in doubt and no safety, quality, legal or ethical risk is presented to Sainsbury’s brand or customers. Major NC - A substantial failure which requires prompt attention to prevent a safety, legality, quality or ethical issue from arising and / or raises doubt as to the conformity of product. Critical NC - Critical failure to comply with a safety, quality, legal or ethical requirement that puts either Sainsbury’s product, Sainsbury’s brand or a Sainsbury’s customer at risk.

For further guidance see

Appendix:

Rating based

on the

evidence

gathered to

demonstrate

compliance Critical Non-

Conformance (NC)

Major NC Minor NC Compliant to Policy

a. Communicate ETI Base Code to all workers.

b. Register all direct production sites on Sedex

Complete Sedex Self-Assessment Questionnaire (SAQ)

Link to relevant Sainsbury’s category on Sedex and grant access rights

Enter Sedex site reference number onto Evolve in the following format: ZS0000000

c. Update Sedex SAQ information at least annually

d. Ensure all production sites have a 2-pillar SMETA ethical audit (4-pillar is also accepted) according

to their risk rating carried out by a Sainsbury’s approved audit body and other Sainsbury’s requirements:

High risk: every 12 months Medium risk: every 24 months Low risk: at TM discretion New site: within 12 months prior to being registered on Evolve

To find out your risk rating, ask your Sainsbury’s technologist Suppliers must directly commission any audit. We also accept Social Accountability International (SA8000) and SIZA audits.

C

e. Close off non-conformances raised through ethical audits via Sedex within the appropriate

timeframes as specified on the audit Corrective Action Plan

Any overdue business critical, critical or 3 or more majors will lead to the site being red rated

1 or 2 major non-conformances will lead to the site being amber rated

Suppliers must notify Sainsbury’s within 24 hours of an audit revealing a business critical issue

C, G, H

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Suppliers must notify Sainsbury’s within 24 hours of any ethical trade related whistle-blower

Ensure all new supplier sites have any business critical, critical, or 3 or more major NCs closed off before production commences.

For certain non-conformances which cannot be resolved within the timeframes on the Corrective Action Plan, Sainsbury’s will consider a derogation – see Appendix H

f. Allocate sufficient resources to ensure all supplying sites and indirect suppliers comply with legal requirements and Sainsbury’s Code of Conduct for Ethical Trade. This includes farmers, growers, sub-contractors, agents, homeworkers and labour agencies. This supply chain due diligence can be managed via Sedex or other supply chain management platform or tool.

g. Develop an ethical trade strategy for own business and supply chain including all suppliers, contractors and labour providers

D, E, I

h. Labour Providers

Work towards compliance with Sainsbury’s Supply Chain Policy for the Responsible Use of Labour Providers, in Appendix F

Audit labour providers at least annually. o We recommend using an independent third-party to conduct this audit who is experienced in

carrying out assessments of labour providers, using an audit tool specifically designed for that purpose. Clearview certification of your labour provider at the sites that supply Sainsbury’s will also be accepted.

o This due diligence also applies to labour providers used by any third-party sites which you contract with (e.g. raw materials or packaging materials suppliers).

o Audits must include worker interviews and document checks.

Suppliers must be able to provide copies of labour provider audits on request to Sainsbury’s that

indicate all relevant legislation is complied with.

Where relevant, suppliers must register for the GLAA’s Active Check Service for every labour

provider covered by a GLAA licence. See

http://laws.gla.gov.uk/Default.aspx?Menu=Menu&Module=Main/ActiveCheckHome

All UK sites using agency labour are strongly encouraged to attend Stronger Together and all global

suppliers to attend Responsible Recruitment training (see Training Section below). We offer one

free place per supplier for Stronger Together and all suppliers have access to free training and the

self-assessment tool for the Responsible Recruitment Toolkit as Sainsbury’s is a Founding

F, I

http://laws.gla.gov.uk/Default.aspx?Menu=Menu&Module=Main/ActiveCheckHome

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Sponsor.

i. Any accommodation provided to workers must meet at least legal minimum requirements

For guidance on UK legal minimum and best practice, see Guidance on Provision of Caravan

Accommodation for Temporary Workers in the UK http://www.freshproduce.org.uk/services/fpc-

publications/ and Accommodation Webinars (see Training section below).

J

j. Suppliers should familiarise themselves with the mandatory questions that technologists will ask when

visiting their sites which includes conducting a gap analysis against our Code of Conduct for Ethical

Trade.

B

http://www.freshproduce.org.uk/services/fpc-publications/


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Supplier Management of Third-Party Audit Process

All new sites must have an in-date ethical audit before production commences. See Appendix C for guidance on third party

ethical audits.

ALL SUPPLIERS MUST:

Fully complete the Sedex Self- Assessment Questionnaire (SAQ)

Update SAQ at least annually

Enter Sedex site reference number (ZS code) onto

EVOLVE

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ME

DIU

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HIG

H

Independent 3rd party audit conducted every 24 months –

shared via Sedex

3rd party audit required upon request 2nd party audits recommended

Independent 3rd party audit conducted every 12 months –

shared via Sedex

STEP 1: Risk Assessment

& Sedex

STEP 2: Ethical

Audits

STEP 3: Audit & NC

Grading

STEP 4: Corrective

Actions

STEP 5:

Sign-Off

Minor

Major

Business

Critical

STEP 6: Human

Resources

Critical

ALL SUPPLIERS MUST:

Inform Sainsbury’s of any Business Critical (BC) issues raised by auditors within 24h

Close off all NCs in timeframe stipulated by the auditor

ALL SUPPLIERS MUST:

Ensure all completed actions are verified by desk top review or follow-up audit

Business Critical and Critical NCs must have follow up audit within 6 months

Ongoing compliance

and evidence of good people

management required

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Reference Issue Number Owner: Authorised By: Date Page Number:

SP003 7 Ethical Trade Manager – Food/

Drink/ Household/ Health & Beauty Technical

Operations Group 8th July 2019 Page 14 of 15

Red and Amber Rating Criteria for Overdue Non-Conformances in

Third-Party Social Audits

The severity of non-conformances resulting from a site’s third-party ethical audit will be graded automatically by Sainsbury’s. Overdue business critical, critical issues and ≥ 3 major issues will result in a Critical Red rating. 1 or 2 major overdue issues will result in an Amber rating. Overdue non-conformances are those that are not closed out within the timeframes specified in the audit report. Non-conformances must be closed off on Sedex, see Appendix C for further guidance.

Rating

Grading of OVERDUE non-conformances

Business Critical

Critical Major Minor

RED ≥ 1 ≥ 1 ≥ 3

AMBER ≤ 2

Forms

Appendix H- Template for recording action plan and progress for exceptional non-conformances Appendix J.1 pages 22-30 – Self-help checklist for provision of accommodation Appendix J.3 – Worker accommodation risk assessment

Training Support

We offer one free place per supplier on Stronger Together training and strongly encourage suppliers to attend these, if available in their country: https://www.stronger2gether.org/

We are Founding Sponsors of the Responsible Recruitment Toolkit to offer expert, pragmatic

support for our suppliers to achieve responsible recruitment: https://responsiblerecruitmenttoolkit.org/ As a Sainsbury’s supplier, you, your suppliers and labour providers can access:

Free access to guidance

Self-assessment reporting functionality at a discounted price

Free face-to-face and online workshops: register and call +44(0)1276 919090 for your free 1-day workshop or two places on ½ day workshops

Together with other retailers, we have supported the development and rollout of Worker Accommodation Webinars which are based on the FPC Guidance on Provision of Caravan Accommodation for Temporary Workers in the UK (http://www.freshproduce.org.uk/services/fpc-publications/) https://www.sedexglobal.com/worker-accommodation-webinars/

https://www.stronger2gether.org/

https://responsiblerecruitmenttoolkit.org/

https://clicktime.symantec.com/3V1qjPqJx7SUpy5UbBFqLDm6H2?u=https%3A%2F%2Fresponsiblerecruitmenttoolkit.org%2Fmembership-account%2Fmembership-checkout%2F%3Flevel%3D1

https://clicktime.symantec.com/3EhzpsdKtxfNp5YcQQPe7Wn6H2?u=https%3A%2F%2Fresponsiblerecruitmenttoolkit.org%2Fworkshops

https://clicktime.symantec.com/3EhzpsdKtxfNp5YcQQPe7Wn6H2?u=https%3A%2F%2Fresponsiblerecruitmenttoolkit.org%2Fworkshops



https://www.sedexglobal.com/worker-accommodation-webinars/

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Reference Issue Number Owner: Authorised By: Date Page Number:

SP003 7 Ethical Trade Manager – Food/

Drink/ Household/ Health & Beauty Technical

Operations Group 8th July 2019 Page 15 of 15

See Sainsbury’s Supplier Ethical Trade Trading Links (Appendix

I) available on Evolve, for a full list of available ethical trade courses.

We encourage you to use the Training Links for internal capability

building to help address specific areas you find challenging, or to

understand best practice in areas such as human resource

management, tackling labour exploitation and health and safety.

Triggers for Policy Review

Annual policy review

Performance against policy

Changes to Sainsbury’s policy and procedures

Changes to national and international legislation

Changes to the Ethical Trading Initiative (ETI) Base Code

Changes to SMETA protocol – Sedex Members Ethical Trade Audit

Changes to Sedex and/ or Sedex risk assessment process

Documents

Sustainable Sourcing Policy Sainsbury’s