Primark’s Ethical Trade and Environmental Sustainability team has over 130 people in its 10 key sourcing markets. The team works across all aspects of human rights due diligence, from strategy and risk assessment to supporting suppliers and their factories in implementing its Supplier Code of Conduct.

Primark’s social audit and monitoring programme is one of the key elements of how human rights due diligence is implemented in its product supply chains. Through this programme, Primark conducted over 2,000 social audits over the last year. These audits are carried out by Primark’s own employees based in sourcing countries, in addition to carefully selected third parties. Primark carries the full cost of these audits, which includes rigorous checks for human rights issues based on first-hand assessment of the working environment, reviews of relevant documentation and confidential worker interviews. At the end of each audit, supplier factories are issued with a time bound corrective action plan that outlines any areas for improvement. Primark uses these audits in the approval process for all new tier one factories. Any potential new factories are audited and only if the outcome of the audit is satisfactory can any orders be placed.

Primark also implements additional due diligence activities where necessary. One example is its Structural Integrity Programme which was established in 2013 in Bangladesh to assess the safety of all supplier factory buildings against international standards. If areas are found to require improvement, it works with the suppliers and their factories, in collaboration with a team of structural and civil engineers from international engineering firms, to provide technical support and guidance. The Structural Integrity Programme has been expanded to Pakistan and Cambodia, with ad hoc support for other sourcing countries as required.

Primark believes it is important that organisations, workers and their representatives can raise grievances and alert the business to potential breaches of standards. Primark is committed to making effective and accessible grievance mechanisms available to all its colleagues and people in its supply chains. This includes:  

• having grievance mechanisms which allow for anonymous reporting; 
• expecting all Primark-approved factories to have effective grievance mechanisms available to their workers; 
• working with third parties, including Non-Governmental Organisations (NGOs), to support the implementation of industry-wide grievance mechanisms in our sourcing countries and support existing ones. An example is the Amader Kotha Helpline in Bangladesh, an external and independent grievance mechanism to provide workers with a confidential and accessible means to raise concerns and access remedy; and 
• developing a separate, widely available, Primark-funded grievance mechanism that will be accessible to all workers and relevant stakeholders in its supply chain, called Tell Us.

Primark also receives grievances through other channels, including the customer services section of its website, confidential worker interviews during social audits and workers having direct contact with Primark colleagues and its partner organisations. When issues or grievances are raised, Primark takes steps to investigate thoroughly while protecting the confidentiality of those raising the complaint, and anyone else who might be affected. Primark does not tolerate any retaliation against those who have raised a grievance and any affected stakeholders. 

More detail about Primark’s approach to human rights due diligence can be found in its Modern Slavery Statement, Supply Chain Human Rights Policy and Sustainability and Ethics Report.

Solutions and projects for systemic issues in factories

Where inherent risks and more systemic issues are identified, Primark works with suppliers and their factories, as well as partners and other brands, to address these through longer-term solutions and projects. The first of these projects began over a decade ago, and the portfolio of work continues to grow. Local teams play a key role in working closely with the supply chain and external experts to identify issues, find solutions and share learnings with others. Over the years, Primark has identified several thematic areas to support factory workers in its supply chain, some of which are included in the Primark Cares strategy and are aligned with the activities undertaken as part of Primark’s supply chain Human Rights Due Diligence. These include: 

• creating financial resilience;
• promoting equal opportunities for women; and
• improving health and wellbeing.

There are currently 36 external partners working across 21 projects to support workers in the garment industry in seven sourcing countries. 

For example, Primark recognises the specific challenges faced by vulnerable workers, including migrant workers, and has developed dedicated programmes to support these workers in India which is a key sourcing location for the business. One example is the My Life programme in India, which helps vulnerable migrant workers understand their rights, with a strong focus on women. Primark launched the programme in 2017, partnering with the international NGO Women Win. The programme has been running for over five years and has been adapted to fit local needs, including language requirements. An independent evaluation by 60 Decibels, an end-to-end impact measurement business, confirmed the positive impact of My Life on workers, especially migrant workers, who are some of the most vulnerable. Migrant workers often face challenges due to language barriers, cultural differences and limited access to resources. By equipping them with essential life skills, the initiative is helping to mitigate the risk of abuse and exploitation, helping them to overcome these challenges and build more resilient futures. 

Building on these successes, Primark is continuing to engage with stakeholders to expand the programme beyond factories.

Primark acting on living wages

Primark’s approach to pursuing a living wage for workers in its supply chain is focused on industry collaboration through its membership of ACT (Action, Collaboration, Transformation): transparency on wage data and continuous improvement of purchasing practices. Primark’s social audit programme also monitors supplier factories’ compliance with legal wage requirements.

By embedding responsible purchasing practices¹, Primark recognises that this will support better conditions to enable suppliers and their factories to pursue a living wage. For example, by identifying and ringfencing the labour cost of a product, Primark will aim to protect wages from price negotiations. 

The business has set up a working group, comprising some of its key suppliers and its in-house country teams, to develop a tool to identify labour costs. Primark has also provided training to 320 suppliers and 455 buying and merchandising colleagues on this costing method. Primark continues to train and upskill its product teams on the importance of implementing responsible purchasing practices. 

As reported last year, Primark began planning a pilot on wage data collection using the Fair Labor Association (FLA) Wage Tool to measure the gap between actual wages and living wages. Following consultations within the business and with the FLA, suppliers and factories in Cambodia, Bangladesh, India and Turkey were selected to ensure a broad and diverse pilot, considering workforce size, gender split and length of time working with Primark. 32 factories are now taking part in the data collection pilot. Information from the pilot will be used to compare actual wages paid against the Living Wage benchmark of the Global Living Wage Coalition.

Transparency and traceability

Supply chain traceability is complex and Primark continues to develop its approach. For the past six years, it has published a Global Sourcing Map, covering tier one factories that make its products², including worker numbers and gender at each site.

Primark’s partnership with TrusTrace, which started in 2022, enables Primark to gather data from across its product supply chain, from raw materials through to finished product. This programme is run by a dedicated Transparency and Traceability team operating within Primark’s Sourcing team. In 2023/24, Primark reached 100 suppliers and increased the number of raw materials mapped to the four main materials Primark uses: cotton, polyester, man-made cellulosic fibres (such as viscose) and nylon. Primark continues to train suppliers on its traceability expectations. 

Traceability is also embedded into the operations of the Primark Cotton Project.
 

^{1. ACT brands have committed to improving their purchasing practices globally in five areas where the biggest impact on wages and working conditions was identified. Read more here: https://actonlivingwages.com/what-we-do/act-and-purchasing-practices/.}

^{2. Tier one factories manufacturing finished goods. Tier two factories provide materials and services to tier one factories.}