The California Transparency in Supply Chains Act of 2010
Disclosure by the Body Shop International plc and its affiliates

The Body Shop is passionate about the workers in its supply chain and one of our core corporate Values is to "Defend Human Rights." All direct suppliers to The Body Shop International plc (BSI), and its affiliates, are assessed against our Supplier Code of Conduct, according to the criteria set out by the Ethical Trading Initiative (ETI), which is an alliance of companies, trades unions and voluntary organisations. The Code is underpinned by international labor standard norms and covers issues such as forced labor, child labor, discrimination, working conditions, living wages, and freedom of association. Our approach is to positively engage with suppliers if we find issues, but failure to commit to working with our Code results in termination of the trading relationship.

The eradication of child labor and forced labor are critical elements of our Code of Conduct and we take the issue incredibly seriously. Our Ethical Trade program includes the following activities:

  • Supplier mapping, assessments and questionnaires: BSI performs an ongoing mapping and risk assessment of its direct product manufacturers. This process includes assessment of particular labor compliance risks, based on location and is then corroborated by detailed supplier questionnaires.

  • Supplier audits: Every direct product manufacturer to BSI is audited by an independent third-party, or by our own Ethical Trade team against the criteria set out in our Code of Conduct. This includes issues of child labor and forced labor. We may employ different audit approaches depending on the supplier, country or the nature of our business with them. For example, in higher risk countries we may chose to perform unannounced audits, or with factories where we have an ongoing relationship we may perform collaborative audits. BSI has a zero-tolerance approach to child and forced labor and it is deemed as a 'critical' non-compliance. This means that we would require a supplier to work immediately on remediating the issue, ideally involving local Non-Governmental Organizations (NGOs), trade unions or other worker representatives and, where appropriate, local government officials.

  • Internal accountability, procedures and training: BSI has implemented a number of internal systems and procedures to ensure the robustness of our Ethical Trade program. Our buyers are ultimately accountable and are unable to place a purchase order unless the supplier has successfully been through our Ethical Trade process. Our buyers are encouraged to take ownership of Ethical Trade issues and are responsible for working with suppliers to ensure compliance with our Code, with the help of our specialized Ethical Trade team. Key buying and quality staff undergo regularly Ethical Trade training, including around issues of child and forced labor. For example in 2010, key staff from our sourcing and quality teams were trained to the SA8000 standard. In 2010 we also delivered an Ethical Trade "roadshow" to around 150 key people in the business. In 2011 our Ethical Trade processes and procedures were independently verified by the Institute For Market Ecology (IMO).

  • Capacity building and moving beyond auditing: BSI has evolved its Ethical Trade program so that in some cases we work more closely with suppliers on particular issues to directly improve labor conditions. We now have a number of specialist NGO partners working with some of our suppliers on issues like health and safety, worker retention and worker engagement. We also run an ongoing program to help our direct suppliers cascade our standards down the supply chain - a key requirement of our Ethical Trade Program.


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