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Responding department: Corporate Responsibility

Stock exchange symbol: (ABF:LN)

Does your company have a publicly available commitment to respect human rights?

We have an ABF commitment to Human Rights in our 2014 CR Update which can be found online at: [link] and in our 2014 Annual Report which can be found here: [link]

We also have standalone policies that relate to our human rights impact:

• Anti-Bribery and Corruption Policy

• Anti-Fraud Policy

• Environment Policy

• Health and Safety Policy

• Payment Policy

• Supplier Code of Conduct

• Taxation Principles

• Whistle blowing Policy These can all be found online using this link: [link]

How are human rights governed in your company?

Human Rights sit within our Corporate Responsibility (CR) governance framework, See diagram, from page 10 of the 2013 CR Report for structure: [link]

As the diagram shows, the Director of Legal Services and Company Secretary has overall responsibility for all CR issues and reports to the Chief Executive. Our decentralised business model empowers the boards and management of our businesses to identify, evaluate and manage the risks they face on a timely basis and with the local knowledge that is required. Key risks and internal control procedures are reviewed at group level by the board. The CR leaders’ group meets regularly to monitor CR performance and ensure that best practice is shared effectively and communications are running smoothly. Within individual businesses, accountability for CR sits with the chief executive and a CR manager. Each chief executive is required to sign and submit an annual questionnaire which assesses all types CR issues. These formal processes complement the regular CR group meetings which help maintain best practice sharing across the group.

How are human rights managed within your company?

Illovo are distinctly aware of the diverse cultures and the differences in laws, norms and traditions that the business needs to acknowledge and respect. It therefore supports and respects the protection of internationally proclaimed human rights and will not tolerate discrimination of any kind, nor any form of forced or child labour. In the year ahead, educational programmes and awareness initiatives will be implemented with grower associations and other suppliers, to inculcate a culture in our supply chain that promotes human rights and is committed to abolishing child and forced labour and other human rights violations. During 2014 no incidents of discrimination, limitation or violation of employees’ rights to exercise freedom of association and collective bargaining, or of forced, compulsory or child labour, were reported by any Illovo employees or any other persons. There were also no violations of the rights of indigenous people, and none of the operations were identified as posing any significant risks in this regard.

Similarly, Twinings Ovaltine wants to ensure that the people working for its suppliers and in its own sites are treated fairly and are working in safe and healthy conditions, and further down in the supply chain, that its raw materials are grown sustainably. Twinings Ovaltine has committed to support and respect human rights and to work collaboratively with stakeholders to drive progress throughout the industry.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Our efforts to encourage ethical business within Associated British Foods have benefited greatly from engagement with our stakeholders. These relationships are valuable to us and help to ensure the long-term sustainability of our different businesses. We have identified and engage with a number of stakeholder groups at a group and business level, such as communities, industry bodies and employees. For more information, see page 11 of the 2013 CR Report. One example to draw upon would be the work of Illovo where our engagement with local communities and other vulnerable stakeholders is guided by the principle of free, prior and informed consent in relation to all matters where new projects may impact on them. Our procedures involve environmental and social impact assessments, ongoing stakeholder engagement and risk and impact monitoring, while ongoing consultation processes involve mechanisms to address grievances.

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Health (including environmental health, workplace health & safety)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Sexual harassment
  • Access to water
  • Freedom of association and trade union rights
  • Women
  • Children (including child labour)
  • Indigenous peoples

Actions on workplace diversity / non-discrimination

Workplace diversity / non-discrimination Twining’s Thailand:

An audit found that the site were specifying age, gender and sometimes weight and height during their recruitment process. Following the inspection, the site was advised on why physical specification could be considered discriminatory, but could also prevent some good candidates from applying for the roles. Since the training, the site has amended their recruitment policies and current adverts to reflect competencies, skills and training needed to do the role, rather than physical attributes. This has enabled women to start applying and being considered for new factory roles.

Actions on access to water

Water use and availability:

As a group we have committed to building long-term partnerships to address significant water issues at a local level. We continue to develop our measurement of water use, with particular focus on water quality and access in water stressed areas. In Africa, where water quality is an increasingly serious issue, Illovo has been conducting water footprint assessments across all sites, using the findings to develop local risk-based water strategies and exploring collaborations with communities, suppliers, customers and NGOs on water issues.

Actions on women

Women Twining’s and Primark:

Starting in 2015, HER Project provides general and reproductive health education to female workers in global supply chains. Improved health awareness/knowledge: Personal/feminine hygiene, nutrition, family planning, sexually transmitted infections, and pre- and post-natal care, Greater self-esteem and feeling of being valued, Productivity gains via reduced absenteeism and turnover, Better Worker-Manager relations.

Actions on children (including child labour)

Child Labour Twining’s- Cote d’Ivoire:

Project to raise awareness on child labour, improve education infrastructures and provide new income generating activities for families.

  • 6 classrooms constructed and 27% increase in school attendance
  • Children protection committee set up
  • 1,600 people attended the awareness session on child labour
  • Community Service Provider Groups have been set up to carry work usually conducted by children
  • Women groups have received seeds, as well as training on basic business skills and good agricultural practices.

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

ABF’s public commitment to human rights is reported in our Annual Report and Accounts as well as our Corporate Responsibility report. See link here: [link]

By the end of 2015 we will have also developed a publically available stand-alone Human Rights policy that will be held at Plc level and implemented throughout the businesses.

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

In the unlikely event that an incident or suspected incident of human rights abuse is brought to our attention (through our own internal systems or third-party communication), Associated British Foods plc is committed to undertaking a comprehensive investigation to identify the root cause. This may involve the co-operation of third-parties (for example NGOs, trade unions and local charities). We will then ensure that the appropriate remediation takes place not only to correct the issue uncovered, but also to mitigate the risk of recurrence, taking into consideration local and national law where such an incident occurs in our supply chain.

Associated British Foods encourages an open culture in all its dealings between employees and people with whom it comes in contact. Effective and honest communication is essential if malpractice and wrongdoing is to be effectively dealt with. Our whistleblowing procedure provides guidelines for individuals who feel they need to raise certain issues to ABF or their own employing subsidiary, in confidence, and is designed to protect those raising a genuine concern from any detriment, in line with the Public Interest Disclosure Act 1998 or other jurisdictional legislation. For our full Whistleblowing policy please see:  [link]

An example of this can be seen through Primark’s leadership as one of the first to respond to the tragedy of Rana Plaza in April 2013. Due to our effective processes and transparency in our supply chain, we were able to alleviate the immediate suffering of the victims of the Rana Plaza building collapse. This included short-term financial aid and long-term financial compensation packages for the employees who worked in its supplier factory. To see more about our response to the Rana Plaza collapse, see page 52 of our 2013 CR Report or go onto the Primark Website: [link]

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

ABF commits to ensure compliance with the UN Declaration on Human Rights in the management of all our businesses. In addition, Primark was awarded the classification as a leader by the Ethical Trade Initiative (ETI) and we have a comprehensive group wide Supplier Code of Conduct which sets out our expectations of standards and is based on the International Labour Organization (ILO) conventions. Other examples of multi-stakeholder activity can be seen through our promoting the empowerment of women. This has been a particular focus for Illovo which has recently committed to developing a more strategic approach to gender issues through identifying social investment programmes focusing on women’s empowerment and investing in training and mentoring of women in the value chain, and building partnerships with local organisations: [link]

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

Before the Ruggie Framework was formalized into the internationally agreed UN Guiding Principles on Business and Human Rights in 2011, ABF were already publically reported the following on human rights: “Managers must take account of the core International Labour Organization (ILO) labour conventions and strive to observe the UN Universal Declaration of Human Rights, by respecting the dignity and human rights of our employees and in particular as stated below:

– Universal respect for an observance of human rights and fundamental freedoms for all without discrimination as to race, sex, language or religion.

– We remunerate fairly with respect to skills, performance, our peers and local conditions.” [link]

Since then, the statement has developed into a Plc commitment on Human Rights and will be formalized into policy in 2015.

The Guiding Principles have formed a vital part of our ability to engage with human rights and understand fully the role we, as a multinational business, play in the upholding and respecting of human rights. Therefore, since 2011, where we had an acknowledgement of human rights at Plc level and some good work in the businesses, we are now creating a policy at group level, which will be created in alignment with the UNGPs and we feel this is an area of real progression. As a diverse and decentralised business, we have a range of businesses doing a range of great work in this area.

Primark shows progress ‘on the ground’ since 2011 and can be evidenced by a robust Code of Conduct, which sets out the core principles that suppliers and factories must follow to ensure products are made in good working conditions, and that the people making them are treated decently and paid a fair wage. It is based upon the Ethical Trading Initiative Base Code, which is itself founded on the conventions of the International Labour Organisation and is an internationally recognised code of labour practice: [link].

Primark state that “Our Code of Conduct sets out the principles we expect suppliers to meet to ensure our products are made in good working conditions, and the people making them are treated decently and paid a fair wage. It is available in 29 local languages. In countries such as Bangladesh where many people cannot read or write, it can be difficult for workers to understand formal, written Codes of Conduct. Working with local charities and designers, we asked workers to design posters of our Code of Conduct. The newly designed posters feature cartoon style pictures that can easily be understood by all workers.”

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

As the UN Guiding Principles are only a few years old, it seems that businesses are coming to understand the implementation process of such principles. We have committed to formalize its respecting of human rights through the creation of a policy and are working in collaboration with third party organizations to ensure that this commitment aligns with the UNGPs and existing policies and practices that support our human rights responsibilities.