Auditing
Our Code of Conduct applies to suppliers and their factories manufacturing for Primark. We are constantly working to improve our programme of auditing to help our suppliers comply with our Code of Conduct.
Our auditing priorities are driven by five main factors:
- The level of turnover with a supplier
- The proportion of a supplier’s production that is dedicated to our business
- Country of manufacture
- Production processes involved
- Any other information about a particular supplier or factory that identifies an area of risk
Our aim is to progressively audit and assess the lower tiers of our supply chain, which can include fabric mills, dye-houses, laundries, home-based workers, and suppliers of components such as buttons and zips. Workers further down the supply chain can be equally, or more vulnerable to poor working conditions.
Primark pays for the cost of all its audits as a way of avoiding any unnecessary commercial disadvantage to its suppliers or factories. It also enables us to select the best external partners, and to compare and test different methodologies and approaches.
Our audit partners
Audits are conducted by our own ethical trading teams based in the countries we source from and by our external partners.
Our external partners were selected on the basis of their local expertise, specialist skills, robust practices and innovative methodologies. We do not insist on a one-size-fits-all approach when it comes to auditing, as we recognise that culture and context play a significant role.
We work with a mix of small consultancies, commercial companies, non-governmental organisations and non-profit bodies, all of whom add value to our programme.
Our external partners include
- Engaged Partnerships for Change (Asia)
- Grant Thornton (India)
- The Institute of Contemporary Observation (China)
- Level Works (Asia)
- Nari Uddug Kendra (Centre for Women’s Initiatives), Bangladesh
- UL Responsible Sourcing (Worldwide)
- Consulting Service International (Asia)
- The Reassurance Network (UK and Europe)
- ILO Better Work / Better Factories
Auditing challenges
We asked two of Primark’s external auditors some key questions about the industry, and their views on the future of auditing.
Mitzi Zaruk (MZ) is the Managing Director and founder of Engaged Partnerships for Change
Lyndsay Cunliffe (LC) is an Ethical Auditor at The Reassurance Network
What makes a good auditor? What skills do they need?
MZ A “good” auditor embodies trust and is a credible messenger of needs, root causes and ultimately of goals. Ideally this role belongs to a worker or workers who are empowered, respected, knowledgeable and engaged. But the industry is still a long way from being directly engaged with workers as auditors.
In the interim, second and third party auditors can play a facilitating role to monitoring supply chain performance when they seek to engage in building relationships of trust throughout the value chain. The ability to dialogue is integral to auditing but this will not be possible without trust.
LC Auditors should be able to absorb visual, verbal and written information and convert it into a balanced workplace assessment which describes both good practices and non compliances found. It is important that the auditor is a good listener, observant, level headed and able to empathise and communicate in a simple and effective manner with employees at all levels. Whilst some technical skills can be learnt, e.g. how to check wage records, we look for people who have a built-in ability to communicate effectively, demonstrate good common-sense and, most of all, care about the work we do.
What’s the biggest challenge in auditing today?
MZ Credibility and purpose. Suppliers hurting from audit fatigue, brands not knowing what else to do but audit, stakeholders distrustful of audit results all still point to a failure of purpose and communication.
LC There are many immediate challenges for us; there are direct issues such as falsified paperwork, coaching of workers to say ‘the right thing’, and attempted bribery. However there are also more subtle challenges such as how to gain the confidence of factory managers who have little faith in the purpose of audits. There are still many differing audit standards that confuse suppliers and factories and it is often a challenge to explain which standards we are looking for and why. An internal challenge for us is the recruitment of competent auditors who can meet such challenging circumstances yet remain focused on the overall purpose of improving conditions of employment for workers worldwide. In the longer term the challenge will be to adapt and broaden our skills to meet the new demands that will be placed upon us as the scope and methodology of audits develop and widen.
How has the industry changed since you started auditing?
MZ On the whole, there is now greater awareness (or at least familiarity) of social and environmental issues and standards and social auditing itself as a process for assessing supply chain performance. Many have leveraged this awareness to improve performance; others, however, have used their awareness of auditing to circumvent transparency, which is at the core of a credible process of auditing. The focus of auditing, too, has changed and there is greater demand now for a deeper supply chain spread.
There is a more commonly held drive now to go beyond auditing, to move from checklists to goals and objectives for significant change and improvement.
What has yet to change, however, is the traditional view of audits that focus more on Code of Conduct compliance, rather than Code of Conduct promotion. As a result, supply chains race to pass a compliance scorecard - sometimes through unethical means and often with little regard to sustainable compliance - rather than recognise and utilise their social leadership potential.
LC I started auditing in 2000, when the whole idea of monitoring supply chain ethics was in its infancy; there was little training and guidance available, and we all had much to learn! Over time, natural progression has seen auditor training and qualification courses established, audit methodologies improved and standardised and I am now rarely asked by a factory manager ‘just what is all this ethical nonsense?’ instead the question is now, ‘you want to do another audit….again??’ There are now many audit providers worldwide, although it is still a niche environment to work in, but the community is growing, skills and knowledge are developing and I am no longer constantly asked ‘what is it you do?’, which is a relief!
What do you think the future of auditing could look like?
MZ Auditing will hopefully be impact-driven: a progressive process of monitoring not only supplier performance but also opportunities for supply chain engagement.
LC I hope the future will bring an audit style which is better designed to identify the root causes of poor working conditions, rather than dealing with the symptoms, and that such audits will then lead more directly to identifying the need for problem-solving programs for factories, such as how to improve productivity, or effective HR systems. Indeed we are already moving towards this. The ethical audit scope is already broadening into environmental and business-practice issues and I’m sure this will continue, but there is still the need to define in the industry what a ‘good audit’ is before we rush to conquer new ground.
However, I believe there is also a need in the industry in general, to really define what the ultimate goal of auditing is, what are we trying to do, and why? Then we can really answer “how”? Can we eventually do away with the need for auditing? Will we see empowered workers solving their own issues and working in a collaborative way with managers to secure the success of their company? I remain ever optimistic, but that’s the ethical auditor in me.