The policy was developed with reference to the International Bill of Human Rights and follows the UN Guiding Principles on Business and Human Rights for the implementation of the UN’s “Protect, Respect and Remedy” framework.
In FY 2019/20, we reviewed and updated our Human Rights Policy to include greater detail on our human rights due diligence processes in relation to monitoring, reporting and assessment. In addition, we expressed our willingness to collaborate as part of multi-stakeholder initiatives to combat modern slavery risks where relevant to our business. In FY 2020/21 we reviewed our policy again and determined that no material changes were required.
To ensure ongoing global human rights risk identification we conduct a Human Rights Impact Assessment every two years to confirm potential areas of risk across our operations and extended supply chain, capture emerging risks in relation to new operations and projects, and review or develop mitigation plans as required. New operations and projects are also assessed for human rights risks and impacts when they are initiated as part of our ethical trading programme. We have completed four impact assessments since 2014, each process involving mapping our own operations and those of our extended supply chain, and assessing them in terms of their potential impact on human rights as set out in the Universal Declaration of Human Rights. Our latest assessment took place within FY 2020/21. The Human Rights Impact Assessment covers potential human rights risks including but not limited to; forced labour and human trafficking (for more details please see our Modern Slavery Statement), child labour, freedom of association, right to collective bargaining and right not to be discriminated against. The assessment takes into consideration key vulnerable groups that may be at risk including women, children, migrant workers and contracted labour. In FY 2020/21, our Human Rights Impact Assessment highlighted increased risk in relation to the COVID-19 pandemic, particularly in relation to workers’ health and wellbeing.
Our ethical trading programme is a key component of our human rights due diligence approach, which includes conducting ethical trade audits at supplier sites. Mitigation plans are developed based on an audit findings, as well as the broader risk profile of the supplier and sourcing location, which is evaluated as part of our Human Rights Impact Assessment. As of 31 March 2021, eight finished goods sites (including subcontractors and support facilities) had mitigation plans in place.
During ethical trade audits and as part of our broader Responsibility programme, we conduct interviews with relevant stakeholder groups to better understand their needs and perceptions, while gathering insights into the direct and indirect impacts of our business and developing focused mitigation plans where required. For example, we provide grievance mechanisms for our global employees, as well as confidential hotlines run by non-governmental organisations (NGOS) for workers in our supply chain. Currently, more than 16,000 workers across 34 factories are provided with improved access to remedy and confidential support, including advice and information on workers’ rights and wellbeing. The hotline is available in all the appropriate languages in the 31 factories. The effectiveness of these hotlines is regularly reviewed. During FY 2020/21, Burberry-sponsored hotlines received 529 calls and their resolutions have been monitored closely by our Responsibility team.. In cases where remedy is required, we ensure we work with local expert organisations to provide resolution. Over the last year, we have collaborated with Issara Institute to provide remedy to workers who experienced recruitment fees as part of a complex recruitment journey.
Burberry prohibits retaliation against anyone who raises a complaint. This includes stakeholders who raise human rights related concerns. We require our supply chain partners to follow the same approach.
Our global employees can be members of a trade union or benefit from collective bargaining agreements where available. During FY 2019/20, 12% of our global employees were covered by an independent trade union or collective bargaining agreement.
Responsibility for the Human Rights Policy lies with Burberry’s Chief Executive Officer, while day-to-day operational responsibility lies with our Chief People Officer and global HR team, who ensure that the policy is upheld in our direct operations. The Vice President of Corporate Responsibility reports to the Chief Executive Officer and is responsible for overseeing human rights in our supply chain. Each individual in our sourcing team has personal objectives related to ethical trading, which has been a key driver in embedding responsibility into our way of working.
Human rights risks are reported via the Burberry Ethics Committee, chaired by the General Counsel, and attended by the Company Secretary, Senior Vice President of Risk Management and Audit, Vice President of Corporate Responsibility and Director of Asset and Profit Protection. The Ethics Committee reports to the Risk Committee, which reports to the Audit Committee at Board level.
Annually, we disclose to a number of organisations such as NGOs and investor indices. We have included a number of reports below to demonstrate our transparency on this topic.