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Responding department: Communication and institutional relations (also with input from Office of the General Counsel and Secretary of the Board, Corporate Social Responsbility)

Stock exchange symbol: (ITX:SM)

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

In its Annual Report and on its website, Inditex has made a public commitment to respect the UN Guiding Principles on Business and Human Rights that the Ruggie Framework develops. As a socially responsible company, Inditex has developed policies and procedures aimed at defending and promoting human rights both in its own operations and those of its stakeholders (Page 52 of the 2013 Annual Report - [link]). In order to reaffirm the values and principles that underpin Inditex’s activities and to adapt the system of risk control to the social and regulatory environment, in 2012 the Board of Directors approved, among other things, the new Code of Conduct and Responsible Practices (which replaces the Internal Code of Conduct and the Internal Guidelines for Responsible Practices) and the Whistle Blowing Channel Procedure. As set out in the first section of the Code, Inditex’s corporate culture is firmly rooted in the fulfilment of human and social rights and the effective integration into the company of all employees, with respect for their diversity. The Code of Conduct and Responsible Practices provides the action lines that must be followed by the Group in the performance of its professional duties. Its goal consists of exacting an ethical and responsible professional conduct from Inditex and its entire workforce in the conduct of their business anywhere in the world.

It is a basic element of its corporate culture, on which the training and personal and professional development of its employees is based. For such purposes, the principles and values that shall govern the relationship between the Group and its main stakeholders (employees, clients, shareholders, business partners, suppliers and the companies in which its business model is implemented) have been defined. (Pages 135 and 136 of the 2013 Annual Report and [link]). It should be noted that Appendix I of the Code of Conduct and Responsible Practices lists a series of codes, global commitments, agreements and conventions that Inditex has voluntarily signed up to; these form part of its internal regulations. Inditex is committed to promoting and fulfilling these regulations. For illustrative purposes only, the following are worthy of note: - UNI GLOBAL UNION ( Promotes respect and the promotion of fundamental rights and decent work in the sales and distribution network. - The United Nations Global Compact ( United Nations initiative promoting social dialogue between businesses and civil society. - Ethical Trading Initiative (ETI) ( Platform for dialogue to improve the working conditions of workers in the distribution sector in developing countries, including companies, international union organisations and non-governmental organisations. - International Framework Agreement and performance protocol with the International Textile, Garment and Leather Workers’ Federation (ITGLWF) ( For the promotion of fundamental human and social rights in Inditex’s production chain, including the definition of mechanisms of intervention and joint action in the production chain for the implementation of the Code of Conduct for Manufacturers and Suppliers - Better Work Programme of the ILO ( Platform to improve global compliance with labour standards and the competitiveness of supply chains. The Code of Conduct for Manufacturers and Suppliers is the basis on which Inditex’s activity and its relationship with all suppliers is articulated. It defines standards that must be met on issues of fundamental labour rights, health and safety of products, and environmental aspects. The Code, which was established in 2001 and updated in 2012, is applicable to all manufacturers and suppliers taking part in the purchasing, manufacturing and finishing processes of products sold by the Group and is based upon the general principles that define Inditex’s ethical behaviour, established in the Code of Conduct and Responsible Practices. The Code of Conduct for Manufacturers and Suppliers defines minimum standards of ethical and responsible behaviour that must be met by the manufacturers and suppliers of the products marketed by Inditex in the course of its business. In particular, as its conceptual framework, the Code has the OECD Guidelines, the Ethical Trading Initiative Base Code, the Global Compact Principles and, among others, the following ILO conventions: 1, 14, 26, 29, 79, 87, 98, 100,105, 111, 131, 135, 138, 142, 155, 164 and 182. The Code includes the following principles: No forced labour; No child labour; No discrimination; Respect for freedom of association and collective bargaining; No harsh or inhumane treatment; Health and safety in the workplace; Wages are paid; Working hours are not excessive; Regular employment; Traceability of production; Health and safety of products; Environmental awareness; Confidentiality of information; Code implementation; Committee of Ethics. (Pages 52 and 248 of the 2013 Annual Report and [link]).

How are human rights governed in your company?

Section 5.3 (a) iv) of Inditex’s Board of Directors’ Regulations stipulates that the Board of Directors shall, among other things, approve the general strategies and policies of the company with regard to Corporate Social Responsibility. Section 5.5 states that the Board of Directors shall ensure that the company discharges its ethical and social duties and its duty to act in good faith in its relations with its employees and with third parties, in accordance with the principles of Corporate Social Responsibility that the company has undertaken. In short, the articles referred to above underscore the company’s profound commitment to human rights –expressed as part of its Corporate Social Responsibility policy– as the important functions of determining the Corporate Social Responsibility policy and of monitoring compliance with it are assigned to the company’s highest governing body. Within the context of this Corporate Social Responsibility policy, it is Inditex’s aim to ensure a stable and sustainable supply chain, which includes respecting and protecting human rights. It is a shared responsibility in which Inditex’s extensive internal and external team of sustainability professionals, formed of more than 3,900 people, works closely with the company’s other departments to jointly address the common challenge of not only strengthening and ensuring a sustainable production chain, but also of having a positive impact on those communities in which it operates. Inditex has CSR teams that are responsible for overseeing compliance with the Code of Conduct for Manufacturers and Suppliers. These teams are located in the head office in Spain and in a further nine countries (Portugal, Morocco, Turkey, India, Bangladesh, Vietnam, China, Argentina and Brazil) ([link]).

How are human rights managed within your company?

Regarding the Code of Conduct and Responsible Practices, as an instrument that manifests Inditex’s commitment to respecting human rights, it should be borne in mind that a requirement for suppliers to comply with the applicable aspects of the aforementioned Code is included in a growing number of contracts. Inditex makes its employees aware of the Code of Conduct and Responsible Practices via face-to-face training. Online training is expected to be rolled out in the near future in order to reach the highest possible number of employees. Furthermore, it is also worth mentioning the Whistle Blowing Channel, as it is via this channel that compliance with human rights issues, among other things, is monitored, thus allowing the company to take measures to correct irregular actions when necessary. Additional details about Inditex’s Whistle Blowing Channel are given in section 7 below. Regarding the protection of human rights in the supply chain, Inditex has a compliance programme for monitoring compliance with its Code of Conduct for Manufacturers and Suppliers. Active engagement and cooperation with suppliers is the basis on which this programme is implemented. Within the compliance programme, which consists of various stages, Inditex performs social audits to check that suppliers are respecting the rights and standards set out in the Code of Conduct for Manufacturers and Suppliers. In 2013, more than 4,300 social audits were conducted on suppliers all over the world. Based on the results of the audit, the supplier is assigned a rating in accordance with its level of compliance with each section of the Code of Conduct for Manufacturers and Suppliers for its associated manufacturers. Moreover, social audits are always accompanied by proposals for resolving any breach detected, in the form of a corrective action plan. With the supplier’s commitment, Inditex’s CSR teams support suppliers interested in continuing to work for the Group with corrective action plans to remedy any of its breaches. Besides Inditex’s teams, other stakeholders also take part in these plans, such as factory managers, suppliers and local and international trade unions. Continuing training and awareness-raising is one of the cornerstones of human rights management in the production chain. The CSR teams in the various countries where Inditex produces goods are in constant communication with suppliers to let them know about the application of Inditex’s standards and to help them meet them. To strengthen these messages, individual sessions are usually held to address specific issues. In 2013, more than 500 sessions of this type were held. Also in the 2013 financial year, numerous training sessions and seminars were held with suppliers. In total, more than 1,100 suppliers attended at least one of the face-to-face sessions. Also in 2013, more than 240 employees based at the central offices received specific training in sustainability. (Pages 51 to 65 of the 2013 Annual Report and [link]).

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?

For Inditex, stakeholder dialogue is vital for finding out what issues they consider most relevant and, therefore, for guiding the Group's strategy and actions on human rights issues, among others. To meet their expectations, Inditex maintains a permanent dialogue to identify the issues that interest them or concern them most, establishing different channels of communication with clients, suppliers, shareholders, NGOs, trade unions and other relevant stakeholders. Inditex thus identifies the issues of greatest interest to those who, in one way or another, have a relationship with the company. It drafts a materiality or relevant issues matrix that serves to define the content of its Annual Report and to ensure that the strategy is aligned with the concerns and expectations of those with links to the company or affected by its activities. In the 2013 financial year, the Group took a further step in the production of the materiality matrix. The most relevant issues were defined by performing an analysis of its own value chain and of the internal and external aspects that affected it in some way. In addition, the population surveyed (both internal and external to company) was expanded, which enabled a more complete picture of the stakeholders’ opinions to be obtained. Furthermore, Inditex has a Social Council, which serves as an advisory body on Corporate Social Responsibility issues. It is formed of people or institutions that are external to or independent from the Group. Its function is to formalise and institutionalise dialogue with key players from the civil society in which Inditex implements its business model. (Pages 40 to 45 of the 2013 Annual Report and [link]). One of the aspects that stakeholders and the company consider most important is the protection of human rights and labour practices in the supply chain. Consequently, Inditex has created clusters of suppliers, which are defined as areas for cooperation formed of suppliers, manufacturers, trade unions, business associations and international buyers, among others, with the common aim of promoting a sustainable production environment in a geographical area strategic to the implementation of Inditex’s business model, within a framework of dialogue and participation based on compliance with fundamental labour rights. Inditex currently has 10 clusters of suppliers in the geographical areas where it has a larger and more significant presence: Spain, Portugal, Morocco, Turkey, India, Southeast Asia, Bangladesh, China, Brazil and Argentina ([link]).

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

  • Health (including environmental health, workplace health & safety)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Sexual harassment
  • Displacement and community relocation
  • Access to water
  • Freedom of association and trade union rights
  • Transparency in payments to governments / responsible tax practices
  • Women
  • Children (including child labour)

Actions on freedom of association and trade union rights

Based on the Framework Agreement signed in 2007 and renewed in 2014, Inditex and IndustriALL, in collaboration with the trade union movements of each country, develop and implement a variety of programmes designed to promote human and labour rights in the different geographical regions where Inditex manufactures its products ([link]).

Actions on women

Gender-based violence: in 2010 and 2013, Inditex signed up to two agreements with the Spanish Ministry of Health, Social Services and Equality, the aims of which are to raise awareness of gender-based violence and to promote the inclusion of victims in the labour market.

Actions on children (including child labour)

Inditex has zero tolerance for child labour, and is committed to not pursuing commercial relations with suppliers that employ any young workers in conditions that are potentially hazardous to them. Alongside this, Inditex supports the implementation of remediation plans that ensure the fundamental rights of children ([link]).

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

ntegrated Reporting Council and by AccountAbility. The 2013 Report responds to the Global Reporting Initiative G4 indicators and serves as a United Nations Global Compact Progress Report, in which Inditex has an advanced level. The Annual Report is externally verified in accordance with the ISO 19011 standard and with the principles established in the G4 Sustainability Reporting Guidelines of the GRI, the principles established in the International Reporting Framework and the AA1000 AccountAbility Principles Standard (AA1000APS) of 2008. The results of the verification of the last Annual Report published (for the 2013 financial year) demonstrate that the application level (Compliant - Exhaustive) for the GRI G4 Guidelines was appropriate. A selection of relevant indicators are also reviewed in accordance with the ISAE 3000 standard. (Pages 6, 7 and 277 to 294 of the 2013 Annual Report and [link]). In addition, Inditex’s corporate website ([link]) was updated in 2013 and contains details of, among other things, Inditex’s strategies and work on sustainability issues.

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?

Inditex publishes an Annual Report every year. The Annual Report contains the most significant social, financial and environmental indicators of the year, and enables stakeholders to assess the value creation and performance of the Group in the financial year in question. The Report is drafted on the basis of the principles established in the Global Reporting Initiative (GRI) and by the International IAs mentioned previously, Inditex has a Whistle Blowing Channel available to all Group employees, manufacturers, suppliers or third parties with a direct relationship and lawful business or professional interest, regardless of their level or geographical or functional location, and enabling them to report any breach of Inditex’s internal conduct and regulatory compliance policies committed by any Group employee, manufacturer, supplier or third party with whom the Group has a direct employment, business or professional relationship provided it affects Inditex or its Group. The active right to report breaches or submit communications via the Whistle Blowing Channel is thus conceived of in broad terms. This helps to draw the company’s attention to conduct that hypothetically or potentially could represent a violation of human rights. Any breach and any kind of malpractice can be reported, including of a financial and accounting nature. The Committee of Ethics is responsible for overseeing the Whistle Blowing Channel and enforcing the Whistle Blowing Channel Procedure. The Committee of Ethics reports and is accountable to the Audit and Control Committee, which in turn reports to the Board of Directors. This mediated reporting of the Committee of Ethics to the Board of Directors is further evidence of the company’s clear commitment to human rights because, as mentioned previously, the Board is Inditex’s highest governing body. The way in which this Channel operates is set out in the Whistle Blowing Channel Procedure approved by the Board of Directors on 17 July 2012, which is available on the corporate intranet. Reports of any breach or any queries regarding the interpretation or application of internal conduct and regulatory compliance policies may be sent to the company by post, for the attention of the Committee of Ethics (Avenida de la Diputación, Edificio INDITEX, 15142 Arteixo, A Coruña, Spain), by email ([email protected]), or by fax (+34 981186211). The confidentiality of such reports is ensured. Upon receipt of the report, the Committee of Ethics will first verify whether it falls within its remit. If so, it will refer the report to the relevant department so that it can make the appropriate enquiries. Otherwise, it will order its immediate closure. In light of the findings reached further to the enquiry, the relevant department or departments shall, having first heard the interested party, propose any of the following measures to the Committee of Ethics, which will have the final say: − Remedy of the breach, if appropriate. − Proposal of penalties or relevant measures. − Closure of the case, where no breach has been detected (Page 247 of the 2013 Annual Report and [link]).

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

Inditex collaborates with numerous organisations and institutions when developing its Corporate Social Responsibility policy. This dialogue and involvement has enabled Inditex to move in the right direction, sharing and applying the best sustainability practices found throughout in the world. Inditex forms part of the Working Group on Business and Human Rights within the Spanish Global Compact Network, the aim of which is to develop and promote good practices in the application of the Ruggie Framework. Inditex also takes part in the Ethical Trading Initiative, the Sustainable Apparel Coalition and the UN Global Compact, among others. In particular, Inditex is a member of the United Nations Global Compact Supply Chain Advisory Group, the aim of which is to share best practices on human rights and on the sustainable management of production chains. In addition, Inditex has a Framework Agreement with the international trade union federation IndustriALL, signed in 2007 and renewed in 2014. This Agreement was the first of its kind to encompass the entire production chain of a company in the sector, and its basic aim was to ensure compliance with international labour regulations stemming from Conventions of the ILO and the United Nations, as well as the OECD Guidelines. The Agreement underscores the vital role that trade union freedom and the right to collective bargaining must play in every country. Both organisations thus directly collaborate to ensure compliance with the Code of Conduct for Manufacturers and Suppliers of Inditex ([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.

  • In 2012, Corrective Action Plans and the Plan for the Prevention and Remediation of Work by Minors, both of which are part of the supply chain sustainability programmes, were amended in response to the Guiding Principles developed by the UN Framework to Protect, Respect and Remedy, which establishes that “ addressing adverse human rights impacts […] requires taking appropriate measures for their prevention, mitigation and, where appropriate, remediation.” Inditex's commitment to continuous improvement therefore places a priority on remediation plans within the company's CSR strategy. The remediation plans drawn up by Inditex thus have a dual function: on the one hand, to establish measures directed at mitigating and/or remedying any breaches of the Code of Conduct for Manufacturers and Suppliers detected when conducting social audits and, on the other hand, to prevent these from recurring in the future. (Pages 71 to 73 of the 2012 Annual Report and [link]).
  • For better protection of human rights, the Whistle Blowing Channel, which until 2012 was only available to employees, has since been opened up to suppliers, manufacturers and any third parties with a direct relationship and a lawful business or professional interest, regardless of their level or geographical location. (Pages 135 and 136 of the 2013 Annual Report).

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

The Inditex supply chain in 2013 was made up of more than 1,500 suppliers in 46 countries. The legislative, social and cultural differences in the various countries and regions sometimes make it difficult to implement the global human rights policy in the supply chain (as stated in the Code of Conduct for Manufacturers and Suppliers). To overcome this difficulty, Inditex works with local teams and acts jointly with trade unions, non-governmental organisations (NGOs), workers’ associations, governments, international clients and members of civil society to participate in dialogue meetings together with our suppliers and manufacturers, through clusters or dialogue platforms. (Pages 63 to 65 of the 2013 Annual Report and [link]).