Corporate Social Responsibility Report - New Look

1 downloads 129 Views 2MB Size Report
What Corporate Social Responsibility (CSR) means for us. 6. Putting workers' needs first. 7. Working with our ... supply
Cor porate Socia l Responsi bi l it y Repor t

2016

Contents CEO letter

4

Introduction to CSR

6

Who we are

6

What Corporate Social Responsibility (CSR) means for us

6

Putting workers’ needs first

7

Working with our suppliers

7

Delivering success through partnerships

10

Making CSR part of our culture

12

Our journey

14

Ethical sourcing

16

Our approach

18

Improving workers’ lives and livelihoods

21

Building strong and lasting relationships with suppliers

28

Encouraging a dialogue for change

32

Environment

36

Our approach

38

Inspiring environmental management in our supply chain

38

Extending our impacts further into the supply chain

39

Reducing the environmental impact of our operations and products

40

Animal welfare

42

Our approach

44

Use of animal products

44

Animal testing

45

Appendix

46

Letter from our CEO

Working ethically and sustainably is absolutely fundamental to our business, and we are committed to supporting the thousands of people in our supply chain who make the garments our customers love. The clothing industry has the potential to make a massive positive impact on social development. More than 30 million people make textiles and garments across the world; and in our top sourcing countries, such as Bangladesh, the fashion industry makes up a huge percentage of their GDP. The reach and footprint of the clothing industry gives us a fantastic opportunity – and I’m passionate about building an ethical value chain that our people and customers can be proud of. However the industry is not without its challenges, and we cannot afford to ignore these. The time to act is now. New Look’s projects over the years have led to some excellent and inspiring insights that we can use to scale up solutions across our supply chain. The industry is becoming more and more open to collaboration, and is seeking to develop common solutions. We have the opportunity to make the global garment industry a driver for inclusive, sustainable economic development – bringing benefits to everybody, whatever their background. Our strategy at New Look is to put workers at the centre of our agenda. We first listen to their needs and understand their challenges; and then work with suppliers, supporting them to become better businesses that offer more secure, sustainable jobs. It works the other way too - we can also learn a lot from our suppliers, such as understanding more about the specific local challenges they face and how they are tackled. Our relationship with suppliers is always an equal partnership – we work together closely, using their feedback to shape and influence our strategies. Collaboration with other industry organisations is also critical for delivering success at scale. As well as our suppliers, we partner with brands, non-governmental organisations (NGOs), government initiatives, and local expert organisations which support

4

and enhance our Corporate Social Responsibility (CSR) strategy. We know it will take time to achieve the results we’re looking for, and we’re committed to sustaining our efforts at all levels of the company. Our challenging targets help us continually strive for improvement. In all our efforts, we aim to work with an honest and authentic attitude. Our CSR team works closely with the people in our supply chain – buyers, suppliers and factories – to monitor progress, and to encourage learning from each other. By taking this approach, we can achieve great things. In 2015/16: • We’ve reached 100% of our factories with our third party audit programme and are actively engaging with our suppliers to improve working conditions in our supply base. • We’ve reached over 160 factories with our training in worker awareness and labour rights. • We’ve further expanded specialist projects on gender equality to 11 factories, including empowering homeworkers and millworkers in India, engaging in training for female supervisors in Bangladesh, and promoting health awareness in China and Vietnam. • We’ve become learning members of the Better Cotton Initiative to improve global cotton production. • We’ve delivered health and safety projects to nearly 200 factories around the world. • We’ve become members of ACT, an initiative between international brands and retailers, manufacturers and trade unions to address the issue of living wages in the textile and garment supply chain. Thanks for your interest in our CSR work. Please read this report and visit our website to find out more. Yours sincerely,

Anders Kristiansen CEO

5

Introduction to

CSR Who we are

New Look is an international multichannel retail brand, offering exciting, on-trend, value-fashion for women, men and teenage girls and is the UK’s No. 1 retailer for women under 35*. We have 850 stores, comprising 584 in the UK and a further 266 globally. We also have a fast-growing e-commerce offering, serving over 120 countries worldwide, supported by convenient delivery options. Our long term business strategy comprises of initiatives spanning Brand, Multichannel, International Expansion, Product Development and Menswear. Our ranges of apparel, footwear and accessories are designed with broad age appeal and global relevance. They are delivered by our great people in stores and support centres, who ensure we deliver great service - wherever, whenever and however customers choose to engage with us. What corporate social responsibility (CSR) means for us Our products reach our stores via a complex global supply chain. Hundreds of thousands of people are part of this process, and we take proactive steps in the way we do business to protect and empower them. We fundamentally believe that being a good * Based on Kantar Wroldpanel published data 24 weeks to 25 September 2016

6

corporate citizen is the right thing to do, and we are committed to creating a supply base we can be proud of. This is a view shared by everyone at New Look. To us, CSR is about improving the lives of workers throughout the supply chain while working in a way to protect the environment and promote animal welfare. At the moment, our CSR strategy focuses predominantly on our supply chain. We concentrate on the areas where we can deliver real improvements and that we know are most important to workers. Our CSR strategy is built on three pillars: • Ethical sourcing: we work closely with our suppliers and factories to make sure workers are treated fairly, provided with a healthy and safe working environment, and – most importantly – that their human rights are upheld. • Environment: we promote high environmental standards in our supply chain and aim to reduce the environmental impacts of our products. • Animal welfare: whenever animal-derived materials are used in our garments, our goal is to ensure suppliers respect animals and promote high welfare standards.

In order to create long-lasting positive change, we need to address the root causes of the challenges affecting global supply chains. This requires close collaborations with our suppliers and other stakeholders across the fashion industry. It means we often work on holistic projects that simultaneously tackle more than one of the three pillars of our CSR strategy. We make long-term commitments and set ambitious targets to encourage continuous progress and increase our impact for each pillar. Our CSR team uses regular impact assessments to collect results from projects around the world and identify areas for improvement. As a fashion retailer, it’s our mission to help every person to express their individuality, personality and unique style through fashion. Our clothes help customers feel confident, and if they want to learn more about our supply chain, we want them to feel confident in the way we do business too. In the past year, we responded to the many queries from our workers and customers regarding CSR, and engaged in many valuable dialogues with our broader stakeholders. Although we are always bold and optimistic about our work, we are also pragmatic and honest about potential challenges, whilst seeking to continuously learn and improve. Putting workers’ needs first It takes thousands of people around the world to make our products, and we have committed to put their needs firmly at the heart of our CSR work. Ethical sourcing is the broadest of our three CSR pillars, because workers have been our priority for many years. We want everyone in our supply chain to be treated fairly, safely and ethically regardless of their gender, sexuality, race, religion or age.

workers every year to understand their needs, and we regularly visit their factories to engage in project work and conduct audits to understand where improvements can be made. Working with our suppliers We work closely with suppliers to put our strategy into practice. More than 200 suppliers help us make the products that our customers love. This year we’ve sourced from nearly 800 factories in 30 countries, mainly from China, Bangladesh, Cambodia, Turkey and the UK. We develop close relationships with our key suppliers. In 2015/16, our top 20 suppliers accounted for 80% of production. We also work with smaller, specialised suppliers. Mapping our suppliers, their factories and their own suppliers helps us get a better understanding of our impacts throughout the value chain. This is an enormous task, with a second tier of fabric mills, dye plants and other workplaces adding to the complexity (see flowchart for more detail). By working together with our direct (Tier 1) suppliers to map Tier 2 suppliers and beyond, we can build a more complete picture of our value chain and identify where and how to make improvements. Suppliers must commit to our policies and standards before entering into partnership with New Look – see appendix. We aim to bring them with us on the journey to raise awareness and enhance their ability to deal with key issues. Continual dialogue is vital for effective collaboration, providing feedback on our efforts and enabling us to learn from others.

We know that people’s needs and concerns are continually evolving, and vary depending on their situation. That’s why we speak to thousands of 7

Supply chain mapping Buyer: New Look Agent: The supplier through which we work with the factory Tier 1:

Factories that produce, label and dispatch products

Tier 1+: Sites linked to the main ‘Tier 1’ factories that provide additional support to make products ready for dispatching (e.g. packaging, ironing, finishing) Tier 2:

Mills, tanneries, processing units or chemical facilities that provide the materials our Tier 1 sites need to manufacture products

Tier 3: Sites where raw materials (i.e. cotton or leather) undergo the first stage of processing outside their place of origin

Supplier Clothing

Footwear

Accessories

Home

Factories where products are manufactured

Tier 1 +

TIER 1+ 8

Beauty

Tier 1 main factory

T I ER 1

PRO D UC T

AGENT

BUYER

Tier 4: The original source of the product (i.e. farms or fields)

Sites providing additional support to the main Tier 1 factory

TI E R 2 TI E R 3

Yarn supplier

Slaughter house

T I ER 4

Animal derived source

Fabric mill, wet processing

Farm

Farm

Chemicals source

(tannery, processing unit)

Mineral sources

Product dependent

9

Delivering success through partnerships To live up to our global CSR goals and address the complex issues facing the fashion industry, it is vital that we partner with governments, the private sector, civil society, trade unions and other stakeholders. Our partners range from international organisations to local NGOs and onthe-ground specialists. Each group has something unique to offer, and a distinctive way of identifying and acting on

challenges. Many of our partners bring essential expert knowledge on specific issues affecting our industry which, combined with our own experience and leverage, can lead to a greater positive impact. It’s important for us that our projects have a longlasting and positive impact upon workers. Many of our collaborations aim to pave the way towards setting new industry standards that will make a true difference on the ground.

Our partners The Accord: An independent, legally binding agreement between brands and trade unions designed to work towards a safe and healthy Bangladeshi Ready-Made Garment Industry. See how the Accord is resulting in improvements in our supply chain on page 24. Action, Collaboration, Transformation (ACT): An initiative between international brands and retailers, manufacturers, and trade unions to address the issue of living wages in the textile and garment supply chain read more on page 22. Alliance HR: A human rights and human resources consultancy that provides collaborative, pre-competitive ethical trade and labour standards programmes. We work with Alliance HR to deliver the Fast Forward project in the UK – read more on page 30. Better Cotton Initiative: The Better Cotton Initiative (BCI) is a not-for-profit organisation stewarding the global standards for Better Cotton, and bringing together cotton’s complex supply chain, from the farmers to the retailers - read more on page 41 Business for Social Responsibility: A global non-profit network that works with businesses to develop sustainable business strategies, solutions and projects. We collaborate with BSR on its innovative HERhealth project – read more on page 26. Carnstone: An independent management consultancy specialising in CSR. We collaborate with Carnstone in environmental projects. Centre for Promotion of Quality of Life: This Vietnamese NGO aims to promote and enhance the quality of life of vulnerable people and communities through research, training and cost-effective programmes. We collaborate on the HERhealth project. Ethical Trading Initiative (ETI): A global alliance of companies, trade unions and NGOs that promotes respect for workers’ rights. The ETI Base Code forms the backbone of our Ethical Aims – see appendix. We work closely with ETI on projects to improve working conditions in the supply chain. Extensive Standards Technical Services (ESTS): Global third party professional audit firm specialising in onestop social responsibility solutions. We are working with ESTS to support capacity building programmes with our suppliers in China, including improving wages and working hours. Geosansar: A social initiative in India that provides financial services and education to workers in our supply chain. Read about our collaboration on page 23.

10

GIZ: The Deutsche Gesellschaft für Internationale Zusammenarbeit GmbH or GIZ in short, is a company that specializes in international development. We partner with GIZ on dialogue training for workers in Cambodia. INNO Community Development: We are working with INNO, a non-profit organisation that advocates for community development, on a project to implement worker committees and hotline remediation services in China. Integrating Human to Quality (IHQ): We are working in Cambodia to improve industrial relations, together with IHQ, a non-profit training organisation for businesses and NGOs. International Finance Corporation: A global financial institution that offers investment, advisory, and asset management services to encourage private sector development in developing countries. In Touch MSC Ltd.: Leading provider of whistleblowing programmes. We are working with this partner to implement the worker remediation hotline SpeakUp in the UK supply base. SpeakUp provides a safe and confidential way for workers to make reports about concerns they may have about wrongdoings in the workplace. MADE-BY: A not-for-profit consultancy that works with fashion and textile brands to improve environmental and social conditions across the industry. We collaborate with Made-By in the SCAP program. Nari Uddug Kendra (NUK): This NGO promotes gender equality, human rights and personal empowerment of women and girls. We are working with NUK on gender training in Bangladesh. Reed Consulting Bangladesh: A consultancy that supports various sectors in Bangladesh to be more responsible, sustainable and profitable. Sedex: A web-based database that enables suppliers to share information about the standards in their factories in a simple, efficient and cost-effective way. We use Sedex to promote visibility in our supply chain and require all New Look suppliers to upload factory information to the online platform. Self-Employed Women’s Association (SEWA): An Indian trade union that aims to support poor, selfemployed women workers to be self-reliant and help lift them out of poverty. Read about our collaboration on page 26. Solidaridad: This international civil society organisation brings together different stakeholders to create fair and sustainable supply chains from producer to consumer. Solidaridad is a key partner in our Better Mills Initiative project in China – see page 39. SUDOKKHO: In Bangla, ‘Sudokkho’ refers to a person who has received training, developed skills and earned a reputation for being competent and knowledgeable. Sudokkho supports private-sector led training for the poor, with a focus on training that effectively supports women and disadvantaged people into decent employment. SUSA – Sustainability Agents: This organisation provides training for improved implementation of social and labour standards at production sites, and we work with them to provide worker-management dialogue in Cambodia. Sustainable Clothing Action Plan (SCAP) 2020: New Look is a signatory to this commitment, made by organisations across the clothing sector, to work together to reduce the environmental footprint of clothing. The Waste and Resources Action Programme (WRAP): WRAP works with governments, businesses and communities to deliver practical solutions to improve resource efficiency with a mission to accelerate the move to a sustainable, resource efficient economy. WRAP leads the Sustainable Clothing Action Plan. World Academy of Research and Development (WARD): This organisation focuses on professional training and development to improve business profitability. We are currently working with WARD on how to address employee overtime in Bangladesh.

11

Making CSR part of our culture

We are instilling CSR in every part of our business and are proud of our team’s collaborative culture, encouraging all team members to challenge each other and bring their own strengths to any discussion. Our CSR team works closely with our buyers and suppliers to review purchasing practices and understand impacts on people in our supply chain. They regularly provide training when and where needed in order to maximise the impact we have in our supply chain.

and design teams who support our CSR objectives. In the past year, CSR Champions have focused on redefining our CSR strategy; increasing awareness of ethical sourcing among our suppliers and internal teams, and building momentum for CSR through behaviour change. We also encourage our people to volunteer their time to support good causes through the New Look Foundation.

Responsibility for other aspects of CSR lies with relevant departments across the business. We also have a team of CSR Champions – self-elected New Look staff members from buying, merchandising

12

13

Our journey 2001

2005

2009

2011

We developed our Ethical Aims, which set out our ethical trading policy and standards. They are based on the ETI Base Code and ILO conventions, covering core labour standard issues

Launched the Factory Improvement Project (FIP) and are the first company in to build improvements in productivity and HR together to increase wages in Bangladesh

Issued our homeworking policy, recognising homeworkers as full members of the workforce who should enjoy equal conditions to other employees

Began marketing clothing made by fairly paid homeworkers in India

2002

2006

2010

Participated in first project to reduce working hours through productivity gains in China

Our Ethical trade programme expanded to include all suppliers

Became one of 7 pioneering brands working to roll the Responsible and Accountable Garment Sector Challenge Fund (RAGS) Better for Business and Workers (BBW) across 73 factories employing over 100,000 workers

2003 Joined the Ethical Trading Initiative

2004 Ethical trade programme included top 10 suppliers, representing over 55% of New Look’s intake

14

2007 Increased wages of over 9,000 workers in Bangladesh and India, through the Factory Improvement Project

2008 Reached over 15,000 workers via The Factory Improvement Project

Were the first company to collaborate with Geosansar to roll out financial inclusion programme to workers in India

2013

Banned the use of Angora in our products to maintain animal welfare standards

Became a signatory member of the Accord on Fire and Building Safety in Bangladesh, set up to make a safer Bangladeshi garment industry

Partnered with other industry brands to codesigned and sign to the enabling principles of Action Collaboration Transformation (ACT)

Won ‘most stylish women’s high heels’ in the PETA Vegan Fashion Awards

2015

Banned sandblasting in all of our product lines due to the high risk to workers’ health and safety

Won the Source Award from the Ethical Fashion Forum, recognising our commitment to sustainability

Banned suppliers from sourcing Uzbek cotton due to the widespread use of forced and child labour in its production

Initiated the Fast Forward Programme in the UK

Partnered with other international brands, retailers, manufacturers and trade unions as part of the Action Collaboration Transformation (ACT) initiative

Started working with the Self-Employed Women’s Association (SEWA) of India, developing a commercial partnership through which workers receive training, support and better pay

2012 Received an Inspiring Good Governance Award at the TVE Corporate Responsibility Film Awards for our film about our work improving wages and conditions in garment factories in Bangladesh

2014 Kicked off our partnership with Business for Social Responsibility (BSR), to implement HERhealth in China and Vietnam aimed at improving women’s awareness of general and reproductive health and increasing access to health services.

Highly commended in Drapers Award for CSR

2016 Joined the Better Cotton Initiative as a ‘learning member’

15

Ethical sourcing 16

17

Ethical sourcing

Our Ethical Aims set out that: • Employment should be freely chosen • Freedom of association and the right to collective bargaining are respected • Working conditions are safe and hygienic • Child labour shall not be used • Living wages are paid • Working hours are not excessive • No discrimination is practiced • Regular employment is provided • No harsh or inhumane treatment is allowed If suppliers fail to comply with these standards, we will work with them to tackle issues and improve their performance. But in extreme cases, we may be forced to stop working with them. For full details on our Ethical Aims, see Appendix.

Everyone across our global supply chain has the right to work in safe and fair conditions, and we want New Look to have a positive impact on the lives of workers in our supply chain. We aim to put workers’ rights at the heart of our strategy by focusing on three key areas: • Improving workers’ lives and livelihoods • Building strong and lasting relationships with suppliers • Encouraging a dialogue for change between suppliers and their workers Our Ethical Sourcing strategy is underpinned by the United Nations Guiding Principles for Business and Human Rights (UNGP). These are the global standards for addressing and preventing human rights risks associated with business activity, based on the ‘protect, respect, remedy’ framework. According to the UNGP, while states have a duty to protect against human rights abuses by third parties (including business), corporations must respect human rights and act with due diligence to avoid infringing on the rights of others. Both governments and businesses must provide access to remedy, which could include compensation, rehabilitation, and the prevention of further risks. New Look has a role to play in upholding human rights, by ensuring workers in our supply chain are protected by the right policies and systems, and providing access to remedy in any cases of human rights risks. We have achieved a great deal since we began our journey towards ethical sourcing, from protecting the health and safety of workers promoting gender equality (see timeline on page 14). In 2015/16, we implemented 72 projects and activities across strategic countries including Bangladesh, Cambodia, China, India, Turkey, the United Kingdom and Vietnam. Many of them are described in this chapter.

18

Our approach In order to put our strategy into action and continue to make progress in Ethical Sourcing, it is vital to have a clear approach with well-defined aims, goals and policies. This section outlines the different key areas, projects and activities that form part of our Ethical Sourcing strategy, and highlights the way we work with different industry partners. Setting clear plans We have clear goals and robust implementation plans within each focus area, and we keep track of how we are doing by monitoring progress on a quarterly basis. Over the next five years, we aim to:

Working together to address challenges New Look has long believed in going beyond audits. Instead of a top-down approach, we aim to collaborate with suppliers to solve problems together. To address the root causes of a challenge we must do more than just monitoring and policing – remediation and collaboration are just as important as audits. As a first step to assessing the social and ethical status of our supply chain, we ask all suppliers to submit third party audits for the factories being used for New Look production. This informs how we work with suppliers in order to develop longterm remediation plans for factories.

• Gain a clearer picture of our supply chain, to reach more people • Improve workers’ lives and livelihoods by providing a decent living wage and creating better communication channels • Build even stronger links in our supply chain through our partnerships and programmes Our policies and requirements All suppliers, factories, agents and units must commit to, and demonstrate continued adherence to, our Ethical Aims, which set out our standards for fair and safe working conditions. The Aims align with the International Labour Organization’s conventions, and the Ethical Trade Initiative’s Base Code, to improve the labour standards of workers around the world. The Aims form part of our Supplier Authorisation and Ethical Policy, which suppliers must agree to before commencing business with New Look.

In order to promote transparency and reduce duplication effort in ethical trade auditing in the supply chain, our preferred audit format is SMETA (Sedex Members Ethical Trade Audit) as it aligns with our Ethical Aims, and helps us define the baseline for our suppliers. After an audit takes place, we work with our suppliers to establish the best way forward that helps them meet our ethical standards. For countries such as the UK or Bangladesh, we follow a more in-depth auditing process. In the UK, all our Tier 1 factories must be audited under the Fast Forward programme. By March 2017, all Tier 1+ sites will also be covered . In Bangladesh, we use the legally binding Bangladesh Accord on Fire and Building Safety (the Accord) to constantly work towards improving the conditions of our supply base in the country. As a global brand operating in different countries, we’re aware that audits only provide us with a snapshot in time of the status of the factories. This is why it is so important to go beyond audits, by working directly with suppliers, factories and key local partners on key long-term projects that support the workers in our factories (see our partner list on page 10). For our top 20 suppliers, we use an ethical scorecard and comprehensive KPIs to help them benchmark performance against our Ethical Aims. Suppliers are evaluated on their ethical performance alongside commercial KPIs. We have four levels of scoring that help identify opportunities to improve. To achieve the highest score, suppliers must be fully dedicated to ethical trading. This includes employing an ethical trade manager, possessing an ethical trade policy and implementing projects that positively affect workers. We commit to support suppliers advance through the levels, in order to improve their understanding of good working practices, and increase alignment with New Look’s ethical requirements.

Tier 1+ sites are those linked to the main ‘Tier 1’ factories that provide additional support to make products ready for dispatching (e.g. packaging, ironing, finishing).”

Modern slavery At New Look we believe in respecting and improving the lives of workers right across our global business and supply chains. As such, we operate a zero tolerance policy towards any form of modern slavery, forced/compulsory labour and human trafficking in our day to day operations and in our supply chains. We’re committed to preventing modern slavery and the work is already underway. Next year we will be required for the first time to make a statement under the Modern Slavery Act 2015 (the Act). We welcome the Act and its reporting obligations as a driver for transparency and consistency of approach to meet its objectives. At New Look, we fully understand that modern slavery is a global issue and that no economy, industry or sector is immune. We are committed to doing all we can to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We are a member of the Ethical Trading Initiative (ETI), an organisation which brings companies, trade unions and Non-Governmental Organisations (NGOs) together in a unique alliance to tackle ethical issues. New Look has adopted the ETI’s Base Code of Labour Practice which is based on the standards of the International Labour Organization (ILO) as the foundation of our Ethical Aims. Under those Aims, employment should be freely chosen, and forced, bonded or child labour cannot be used.

We have a number of teams working directly with suppliers, from first contact to dealing with their onboarding and measuring their ongoing performance. We clearly communicate our Ethical Aims from the outset. It is important to us that all suppliers understand what is expected of them, and all suppliers of products for resale are required to accept and sign up to our terms as set out in our Supplier Manual. We have been working for some time on collecting information about our suppliers. This ongoing comprehensive mapping of the size and shape of the New Look supply chain looks beyond the suppliers we contract directly with to better understand who is working in our supply chain and identify who may be at risk. We regularly review our monitoring arrangements and employ up to date techniques and resources to help us achieve this. We measure compliance with Ethical Aims through third party audits of our principal manufacturing sites. New Look acknowledges the need to drive initiatives beyond our principal manufacturing sites, looking deeper into the supply chain to identify areas of potential high risk presented by unauthorised subcontractors or the exploitation of a growing migrant workforce or other sectors of vulnerable labour. We continually strive to test our policies and processes to achieve this. Whilst we continue our work on product supply chains, we are increasingly focused on our wider business.

19

Improving workers’ lives and livelihoods We put workers’ needs at the centre of our ethical sourcing strategy. Despite doing our best to protect workers in our value chain, we know that many people employed in the garment industry face poor working conditions that affect their safety, health and quality of living. No matter which country, supplier or factory, our priority is to ensure that workers are treated fairly, safely and ethically. We drive continual improvements in all aspects of their working environment, from working conditions to relevant training on important issues such financial inclusion, gender equality or social dialogue. Every year we speak to thousands of workers around the world. Their stories, along with on-site audits, factory visits and our own project experience, create a picture of our supply chain and inform our strategy and the high standards we set for our suppliers. Better wages and working hours One of the first steps to improving the lives of workers is to provide fairer wages. We aim for workers to earn a ‘living wage’ – one that will be sufficient to cover their everyday needs – which may often be more than the minimum wage. In China, we conducted an in-depth analysis of average pay and hourly pay against the Asia Floor Wage (AFW), to establish a local benchmark and a long-term strategy. We’re now working with an external partner to improve management systems in four factories in China, with the goal of improving wages and working conditions.

20

We work with other brands, suppliers, manufacturers, business associations, trade unions, governments, nongovernmental organisations (NGOs) and local stakeholders to secure industry-wide agreements that can improve people’s livelihoods. We are part of Action Collaboration Transformation (ACT) (see case study on page 22), and, along with 13 other brands, we have worked with IndustriAll and Cambodian trade unions to advocate for a fair wage setting process that is continually reviewed to keep up with rising living costs. Many of the learnings that enabled programmes like ACT to be established came from our previous projects such as the Benefits for Business and Workers (BBW) project in India and Bangladesh, part of the Responsible and Accountable Garment Sector (RAGS) Challenge Fund established by the UK government. Supported by a coalition of brands and retailers, the project focused on enhancing the business practices of garment manufacturers as well as the day-to-day lives of their workers. The programme ran between 2010 and 2013 and achieved productivity gains in 73 factories, successfully improving workers’ take-home pay while reducing working hours. But we learned that the best way to achieve impact at scale is through industry collaboration, rather than individual retailers working on a factory level.

21

Commitment

Factories reached in 2015-16: 35

Commitment

Factories reached in 2015-16: 24

Deliver wage improvement projects through capacity building

Number of factories reached in the last 3 years: 171

Deliver financial inclusion projects

Number of factories reached between 2013 and 2016: 45

Case study

Case study

Collaborating to transform wages in the fashion industry

Supporting financial inclusion

In 2015, we joined forces with other international brands, retailers, manufacturers and trade unions to become part of Action Collaboration Transformation (ACT). ACT aims to improve wages in the industry by establishing industry collective bargaining in key garment and textile sourcing countries, supported by world class manufacturing standards and responsible purchasing practices.

Industry collective bargaining aims to improve wages for all workers, regardless of which brand, retailer or factory they work for. It enables all workers in the sector to negotiate wages under the same conditions, by bringing together national representatives from employer associations and trade unions to advocate legally binding, enforceable agreements.

India

ACT will develop mechanisms to link purchasing practices to the outcome of industry bargaining, supporting manufacturers to provide their workers with the wages and conditions that meet retailers’ requirements. At the same time, ACT will work with suppliers to develop and carry out best practices on manufacturing standards and systems.

As well as providing access to bank accounts at its 650 branches, Geosansar focuses on financial literacy education and training and provides additional services such as insurance, overdrafts and pensions.

We want all workers across our supply chain to earn enough to support themselves and their families. But we know that we cannot do this alone, since supply chains are complex and our factories will often provide garments to a number of brands and retailers.

Improving financial literacy Supporting workers through financial inclusion projects helps ensure they can safeguard and maximise their wages, and we are committed to playing a role in this area. Setting up a bank account can empower workers to have a secure place to store money, get access to insurance, send money to their families, and strengthen their financial history. It also increases transparency for workers’ wages overall, enabling New Look to establish systems to monitor and control the wage payment of factory workers. At New Look, we strongly advocate for improving wages across the industry, and we believe in locally implementing the wage management systems and training needed to help workers thrive with their personal finances. As part of our Financial Inclusion Programme, we established a pioneering partnership with Indian social enterprise, Geonsansar, and more recently with BRAC Bank in Bangladesh (see case study on page 23). Through the Fast Forward programme, we also work with Alliance HR in the UK to provide banking services and financial education to garment workers. Our financial education programmes help workers understand a variety of financial matters, such as how to open a savings account, take out a loan, or use a debit card.

22

Since 2010, we have partnered with Geosansar in India, a bank that provides financial products and services to low income employees. Only half of India’s population have a bank account, but we are part of a quiet yet powerful revolution to change this.

Working with Geosansar, we have trained more than 1,100 workers in six factories on banking and insurance since the start of Phase 2 of the programme in February 2014, and over 2,600 workers throughout the life of the project. More than 80% of the workers who received financial inclusion training subsequently opened a bank account. In the third phase of the project, we have expanded our reach beyond Tier 1 suppliers to fabric mills in order to understand workers’ challenges further down our supply chain. As well as the benefits to workers that come from financial empowerment, we are also seeing benefits to employers (i.e. our suppliers), such as improved worker productivity, lower absenteeism, and improved reputation as a socially responsible supplier.

Providing safe and healthy working conditions Good health and safety is a fundamental requirement of our Ethical Aims, and we always strive to improve the working conditions in the factories we source from. Globally, health and safety is a key issue affecting the garment industry and we recognise our responsibility to be part of the solution. We expect suppliers to provide a safe and hygienic working environment, take adequate steps to prevent accidents and injuries, and provide regular training on health and safety requirements for all workers.

I’ve been working with the factory for 4 months now. Before I used to send money to my family through sources that would charge me high commission. With the financial inclusion training, now I can transfer money to my family quickly with low commission. Babita, factory worker, India Bangladesh In Bangladesh, we worked with BRAC Bank to pilot a similar project in one factory, reaching 300 workers. After that, the factory rolled out the programme to its entire workforce and now 100% of workers - nearly 2,300 – have bank accounts.

After opening my bank account now I can deposit my money and it is totally a hasslefree process to collect my salary Sonia, Sewing Operator, Bangladesh

We know that factories sometimes struggle to provide adequate conditions for their workers, and we work closely with our suppliers to support improvements. The strong relationships we forge with key suppliers enable us to better support their programmes. Our audit programme covers 100% of our factories, with the intention of engaging suppliers more fully in health and safety as well as different aspects highlighted in our Ethical Aims.

23

Focusing on gender equality

Commitment

Factories reached in 2015-16: 333

Work with factories to provide healthy and safe working environments

Number of factories reached between 2013 and 2016: 542

Our commitment to workers’ rights extends to all workers, regardless of their age, gender or social status. Nearly 70% of workers in the garment industry are women*, yet female workers are often confined to certain types of roles, and have fewer opportunities for promotion than men. Promoting gender equality – where everyone is given the same opportunities, treatment and rewards regardless of their gender – is vital if we want to create fairness among workers. For us, gender equality means that women and men should be given the same means of benefiting from opportunities available and be treated with the same level of respect and dignity.

Gender is a sensitive issue in many of the countries we source from, as it is intrinsically linked to social, economic, historic and cultural factors. By recognising this and respecting local values, we can be better prepared to encourage gender equality and gender equity by, for example, facilitating conversations with suppliers to help factory managers understand conscious and subconscious bias.

Source: http://www.ilo.org/wcmsp5/groups/public/@ed_dialogue/@sector/documents/ publication/wcms_300463.pdf

*

Case study Supporting the Accord to improve health and safety in Bangladesh We are committed to improving the working conditions of garment workers globally, and work closely with our factories, suppliers and buying teams to create a positive impact. Much of our attention on improving health and safety is focused on Bangladesh, one of our key sourcing countries, where health and safety remains a big concern. New Look is a member and signatory to the Bangladesh Accord on Fire and Building Safety – an independent, legally binding 5-year agreement set up in 2013 between global brands and retailers and trade unions designed to build a safe and healthy Bangladeshi Ready Made Garment (RMG) Industry. The agreement consists of six key components: 1. A five year legally binding agreement between brands and trade unions to ensure a safe working environment in the Bangladeshi RMG industry. 2. An independent inspection program supported by brands in which workers and trade unions are involved. 3. Public disclosure of all factories, inspection reports and corrective action plans (CAP). 4. A commitment by signatory brands to ensure sufficient funds are available for remediation and to maintain sourcing relationships. 5. Democratically elected health and safety committees in all factories to identify and act on health and safety risks. 6. Worker empowerment through an extensive training program, complaints mechanism and right to refuse unsafe work. This agreement was the first of its kind where a multitude of apparel brands (over 200), trade unions and NGOs are collaborating and working collectively to improve the health and safety of the garment factory workers in the country.

Regarding Accord inspections, when health and safety issues are identified, we work with Accord specialists to support factories to address them – for example, by providing training and monitoring progress, or support them to implement solutions such as installing fire alarms or hydrants.

Commitment

Factories reached in 2015-16: 11

Empower women through specialist projects

Number of factories reached between 2013 and 2016: 45

We monitor factories on a weekly basis, and regularly conduct in-depth inspections to provide factories with the support they need. In 2015/16, all our factories in Bangladesh were inspected by the Accord. To ensure the remediation work is going on in a timely manner we work with other brands as well. Our factories have now completed 52% of the remediation work - compared to last year’s 13%- with one factory completing 100% of all initial findings. To escalate the remediation work, our internal teams set a path for suppliers and factories and review progress on a quarterly basis. In July 2015, New Look – along with Accord representatives delivered a training workshop to all our Bangladeshi suppliers and factories, sharing the key issues that our suppliers were facing as well as highlighting the importance of the Accord and how we can better work together to accelerate remediation work.

While I don’t necessarily understand the technical aspect of Accord, after it has come in place the workplace has become safer than it was. We didn’t use to have the fire drills or understood the importance of keeping the aisle clear. Now we have fire doors, regular training and fire drills with our fire marshal on fortnightly basis. Factory worker, Bangladesh

New Look’s Senior CSR Manager has also been a member of the Accord’s Worker Participation Committee, to help ensure factories have established training programmes, worker participation in health and safety committees, and avenues for workers to raise issues.

24

25

Case study Supporting women’s empowerment Gender training in Bangladesh

security, food security and social security.

Training and education is one of the best ways to tackle gender discrimination on the factory floor. In 2015, we launched a project with Bangladeshi NGO Nari Udyog Kendra (NUK) and the Social Compliance Initiative Bangladesh (SCIB) to train supervisors on the benefits of equality and gender empowerment in factories.

Initially we faced some challenges to align factory management practices and ways of working with those of an NGO. But by facilitating dialogue between the commercial team of our suppliers, factories and SEWA, we ensured a level playing field for all stakeholders, resulting in solutions that would benefit everyone. We were also able to include homeworkers in the sampling and production process. The project also benefits factories through greater transparency and control of their supply chains (at no extra cost), high quality work, and reputational benefits.

In 2015/16, we trained nearly 160 participants across two factories on leadership skills and issues relating to leadership, efficiency, gender, forced labour, discrimination, harassment and social dialogue. Our follow up sessions showed that after training, attitudes and relationships between workers and supervisors was much improved. Nearly 60% of supervisors reported they gained a better understanding of gender issues, and all participants committed to try to abolish discrimination against women. After this project, the number of female supervisors in the 2 factories increased by 73% - from 11 to 19. More broadly, supervisors gained a better understanding of social dialogue and how to tackle any problems that arose. Homeworking in India As a result of our mapping exercises, we are very aware of the fact that homeworking may appear, and for that reason we created a homeworking policy which complements our global Ethical Aims, defines what we consider as homeworking, sets our commitment towards homeworkers as well as highlights our expectations from suppliers. Our policy very much states the fact that homeworking may happen in our supply chain, hence we see homeworkers as full members of the workforce who should enjoy equal conditions to other employees. We are committed to responding positively to the issue of homeworking and to collaborate with our suppliers to improve the conditions experienced by workers towards the standards set out in the ETI Base Code. Some people – especially women – working in the clothing industry in India are home-based, because it allows them the flexibility to perform household and family duties while still earning an income. We are committed to supporting them as well as the workers in factories. Often, home-based workers do not benefit from the same protections as factory employees, with lack of training, little equipment, low pay, and health risks from poor working conditions. In 2010, we began working with the Self Employed Women’s Association (SEWA) in India to support home-based workers. The SEWA movement has expanded considerably over the past 40 years, and now has 1,700,000 members across 9 states. We set up an agreement between SEWA and five factories- to allow home-based workers to supply them directly – cutting out the middle man to improve the women’s income. Last year we did 5000 units over 2 embroidered garment styles. By working directly with SEWA we can ensure the women can be economically self-sufficient – leading to long-term income

26

HER project in China and Vietnam We want to support female workers to increase their awareness and empower them to discuss their health concerns in a safe environment in the workplace. In partnership with the nonprofit organisation Business for Social Responsibility (BSR), we implemented the HERhealth project in two factories in China and Vietnam since 2014. This is a project to improve women’s awareness of general and reproductive health, challenge harmful health taboos, promote preventative care, and increase access to health services.

ETI Nalam programme in India

Protecting Children’s rights

In India, we have started working with the Ethical Trading Initiative and other partner brands on the NALAM programme, a training programme on rights and responsibilities for young women workers in the mill sector in Tamil Nadu (India). This programme aims to contribute to the elimination of exploitative practices by implementing a replicable model that promotes ethical recruitment and retention of young women into the sector. We will provide an update on the progress in our next report as the programme is currently recruiting new mills.

Child labour is forbidden by law in most countries but sadly continues to exist. We know that child labour remains an issue in the textiles industry in some of the countries we source from and it is something we strongly oppose in our Ethical Aims. We work with suppliers to help ensure they have processes to conduct age verification training in order to detect child labour risks in the hiring processes. But if an underage worker is found working in one of our suppliers’ factories, we do not just walk away. Instead we require our suppliers to take them out of work, find them a school, pay their living expenses until graduation, and offer them a position once they are legally old enough to work. This is in line with ethical sourcing consultancy Impactt’s Operational Procedures for Remediation of Child Labour.

During the project we trained 29 women in China and 25 in Vietnam to be ‘Peer Health Educators’ (PHEs), responsible for educating their colleagues on key health issues such as nutrition, family planning and pre and post-natal care. Through the trained PHEs, it’s estimated that 900 women were reached in their factories. Peer to peer education encourages women to be more open and build trusting relationships with their coworkers. Women also take less time off work as they gain better control of their own health.

We now feel comfortable teaching and sharing health knowledge with the coworkers. Especially through peer health education group training, we know each other better. Peer Health Educator, Vietnam

The training on pre/post pregnancy care was very helpful for workers as the majority of workers are women. Now we get to speak with professional doctors about modern care techniques, whereas previously workers had a more traditional approach around it. Peer Health Educator – Vietnam

27

Building strong and lasting relationships with suppliers

Case study Improving suppliers’ business practices in China In 2015/16, following our past work in the area we began a project to support four factories in China to improve their business practices, particularly around wages, working hours, and communication between workers and management. China is one of the largest manufacturers of garment products in the world - and one of our top sourcing countries – yet many factories still face challenges in how they manage their operations, which in turn affects how well workers are paid and the hours they work. Together with ESTS , our aim was to build factories’ capacity and management skills, resulting in: • Reduced excessive overtime through productivity and worker management

We have worked with some of our suppliers for over 40 years. These long-lasting relationships have helped us build strong, transparent links based on mutual trust and openness. We aim to enable suppliers to put the systems and processes in place that will allow them to provide the best support to workers. Improving factory management and skills While we try to develop consistent solutions that can be scaled up across factories and suppliers, the reality is that all of our products require different styles of production. This means that every factory in every country is unique. By helping factories strengthen their management skills and systems, we can make our suppliers’ businesses more profitable and help workers at the same time. Over the years, this has come to include anything from setting up better record-keeping to improving communication between workers and managers. Our training programmes can equip workers to feel more empowered in the workplace– whether by improving their health and safety knowledge or helping them understand their labour rights, to also train factory managers and supervisors with the ability, knowledge and tools they need resolve key issues that may arise on the factory floor.

28

One of the most important things we can do is to support new workers when they join a factory. Since 2011, we have run a ‘buddy training scheme’ in India, training workers in how to formally induct new joiners in the factories. The scheme pairs each new employee with a buddy who helps them settle into their new role. Our methodology focused on training the HR team using real life examples for factory managers to implement new induction processes aiming to resolve more issues at floor level. The scheme has created a friendlier atmosphere in factories as workers are able to discuss concerns openly with their buddies and raise work-related issues to superiors. In 2015/16 we’ve trained 40 buddies in five factories. Thanks to this system, buddies discovered an issue of favouritism from supervisors that was happening on the factory floor. Unaware of this, the management of the factory saw it as an opportunity to take action and come up with a production bonus system to avoid favouritism going forward.

• Improved hourly earnings for production workers • Increased worker satisfaction leading to reduced employee turnover

• Enhanced workplace communication and better supervisory skills • Strengthened factory management to prevent labour violations such as child labour and discrimination We began by inspecting all factories for opportunities to improve, using the results to design targeted on-site training sessions. One factory employing nearly 150 people transformed into a more open environment where workers and managers could discuss their issues and anything arising on the factory floor. According to a survey carried out after the project, we found that 90% of workers were satisfied with working hours, 82% with their income and 88% of workers were satisfied with their relationship with colleagues. Further progress on our partnership with ESTS will be highlighted in next year’s report. For more on our work to improve wages, see page 21.

In 2015/16 we launched a partnership in Bangladesh to train workers to raise their levels of vocational skills, enabling them to be more productive at work. We will collect and report on the progress of this project in our next CSR report. In India, we run training sessions with factory supervisors to demonstrate how to get the most out of their workforce by communicating better and building stronger relationships.

29

Collaborating to improve industry standards The textiles and fashion industry in the UK employs around 100,000 people*. Over time it has grown into a complex network of small and large factories where subcontracting is often found, making it difficult for brands like New Look to monitor social and ethical standards in our UK supply base. Factories do not always keep accurate records of their costs and employees or who they subcontract to. This makes it hard for us to get a clear picture of our supply chain, and to understand if all suppliers are respecting labour standards.

Source: http://www.just-style.com/analysis/spotlight-onthe-reality-of-manufacturing-fashion-in-the-uk_id120876.aspx

Case study Fast Forward in the UK As part of our commitment to protect workers and enhance labour standards, in 2013, we established the Fast Forward initiative to improve compliance within the UK garment industry. This is an issue that no brand can tackle alone, with collective actions delivering much more positive results and collaboration being the way forward to achieve sustainable change in the industry. For this reason we opened our project model to other brands and has so far been joined by four other UK retailers. We work very closely with Alliance HR to transform the UK supply chain through this programme, whose objectives are to: • Improve labour standards compliance and enforce legal employment rights • Ensure wages are verifiable • Prevent exploitation and mistreatment of workers, particularly identifying instances of modern slavery • Provide access to remedy for vulnerable workers • Improve honesty and transparency in the UK supplier base • Check accuracy of suppliers’ tax payments Fast Forward is helping to build better business practices, such as efficient payroll processing and production costing; which, in turn, has helped raise wages and improve health and safety standards. We’ve held a total of 9 workshops in the UK, with 64 representatives of suppliers and factories attending the sessions. In the workshops, different aspects of the Fast Forward programme were explained in detail. An online resource library was created to provide factories with all the resources they need and support them in understanding all aspects of the programme. We’ve seen measurable improvements in all of our UK factories since we audited our supply base for the first time and the audits that have followed up later on. Initially more than a third of factories employed workers who lacked the proper documentation showing their right to work; this has now decreased to zero. The number of factories without a

30

satisfactory health and safety policy declined by 14%, and those where wages and working hours could not be verified dropped to a quarter that of the first audit. We’ve also seen an increase in wage payment through bank transfer, applying nearly to 90% of our supply base. Other achievements of the programme include the increase of factories’ health and safety policies aligned to New Look standards or grievance mechanisms such as whistleblowing posters being more readily-available to workers. We’ve also been working on the consolidation of our UK supply base, which has resulted in increased business to factories and more regular work. This has also had a positive effect on our sourcing strategy where we have a better monitor and control of our supply base.

NSL Ltd have partnered with New Look to help ensure that garment factories working on their behalf maintain full compliance with the United Kingdom’s immigration law. NSL have conducted a number of on-site audits and also raised awareness within factory management of their legal obligations. NSL continues to offer advice and support through its fully managed Right to Work Checking Service to ensure that all employees have the right to take up work in the United Kingdom. Kenneth Hanslip, NSL Ltd Technical Director, UK

I’ve learnt more about modern slavery. The resources from the Fast Forward website are useful. Factory manager, UK

Case study Supporting suppliers to help refugees in Turkey Our Ethical Aims highlight our approach towards nodiscrimination in the supply chain. This applies globally, to all workers, including in Turkey, which has absorbed nearly 2.5 million refugees since the Syrian civil war began five years ago. With this humanitarian crisis affecting a great proportion of the Syrian population, refugees are particularly vulnerable when it comes to discrimination against local workers, and may be treated unfairly.

• Refugees work only under voluntary working conditions

Work permits allow refugees to officially work in Turkey, but few receive these permits, forcing many to work informally and receive less pay than local workers. New Look is committed to ensuring that all refugees in our supply chain are employed on a formal basis, subject to the correct legal procedures and fair working conditions. Our refugee policy requires suppliers to ensure that:

• Refugees will be provided with at least the Gross National Minimum Wage, overtime premium, weekly rest day and a written confirmation of conditions of employment

• Workers with Syrian refugee status should not be expelled, and should be registered to obtain a valid work permit in accordance with local legislation • While the permit application is being processed, the refugee should be allowed to carry on working as normal and afforded treatment equal to other employees

We regularly audit our suppliers and, if we do find refugees working in our supply chain, we follow a remediation plan to help them obtain a valid work permit, fair conditions and equal rights.

31

Encouraging a dialogue for change Enabling honest, transparent dialogue between workers and management is absolutely fundamental to conducting business ethically. It is also an important way of bringing about real change to support workers, in accordance with the needs and priorities they have highlighted. Freedom of association and collective bargaining New Look recognises the fundamental importance of independent, democratic organisations of workers’ own choosing – commonly known as trade unions – to negotiate and achieve sustainable improvements for workers. Workers should be free to associate with trade unions and benefit from the resulting collective bargaining, because these are two essential elements of ethical, well-functioning industrial relations between workers and their employers. We encourage our suppliers to be as transparent as possible, with an open and positive attitude towards trade unions and collective bargaining.

In many countries, trade unions and workers’ basic rights to freedom of association (FOA) are not upheld and need to be better enforced. We advocate strongly for workers’ right to FOA, through our work with Action Collaboration Transformation (see page 22), the Accord (see page 24), and the Ethical Trade Initiative (see page 35). In Turkey, we worked with ethical trade specialists last year to support communication systems between workers and management. We trained over 40 managers and workers from 21 factories, and five factories implemented a full FOA process. We took the learnings from this project to other projects in Bangladesh, Cambodia, China and the UK.

Commitment Train workers on labour rights and worker awareness

Number of factories reached between 2013 and 2016: 286

Case study Improving industrial relations Cambodia We are working in Cambodia to tackle industrial relations challenges in the garment industry, promoting effective freedom of association and collective bargaining as a way to support workers to advocate for better working conditions. Our aim is to improve the capacity of management to prevent and resolve disputes more quickly at the factory level; and to promote sound industrial relations that support/enable collective bargaining. In 2015/16, we worked with six factories to improve industrial relations. We have mapped the current situation in these factories, and successfully trained management and worker representatives on developing their communication and negotiating skills. China Despite efforts in China to improve working conditions and protect workers’ rights, we continue to see challenges in many factories. Disputes between workers and management are growing over issues like under-paid or delayed wages and poor working conditions. We want to resolve these issues by promoting social dialogue and collective bargaining establishing positive industrial relations across our supply chain. We worked with the Ethical Trading Initiative (ETI) and other

32

Factories reached in 2015-16: 156

brands in China to develop a guide and toolkit for suppliers on promoting social dialogue collective and bargaining in supplier factories. By working with ETI we hope to establish consistent corporate policies to develop and promote social dialogue. UK Many factories in UK are very small and run by owners who are actively involved in day-to-day operations. In 2015/16, we wanted to formalise the way workers raise and resolve issues by supporting and implementing elected work committees in four factories. We have provided guidance on how to form workers’ committees and so far one factory has formed one and regularly uses it. Taking this approach empowers workers to raise issues without fear of reprisal. We continue to work with the other factories to promote worker committees.

Following this project, I am now aware of the worker committee in my place of work, and can approach them with any issues on the factory floor. Factory worker, UK

33

Case study Electing workers’ committees in Bangladesh We want to support workers to exercise their right to raise and resolve issues through social dialogue. Social dialogue is defined by the International Labour Office to include all types of negotiation, consultation or exchange of information between, or among, representatives of governments, employers and workers, on issues of common interest relating to economic and social policy. In factories that are not yet unionised, establishing democratically elected workers’ committees can be an important step in the right direction toward effective social dialogue. In this way, workers can choose who represents them in direct conversation with factory managers. Workers are often unaware of their rights and, without the organisation of workers’ committees, are not able to speak collectively to alert supervisors to their problems and concerns.

Giving workers a voice Giving workers easily accessible access to remedy is underpinned by the United Nations Guiding Principles on Business and Human Rights. We want to empower workers to speak up, have their voice heard and see their grievances and issues resolved. To help workers raise concerns, we have set up helplines in three of our strategic countries, Bangladesh, China and the UK. Through factory visits and worker interviews, our team also act as a contact point for workers to speak up in confidence if they need to. All the calls received are dealt with discretion and confidentiality and the worker’s identity is always protected.

In Bangladesh, we worked with the Ethical Trading Initiative (ETI) to establish elected workers’ committees in three factories. We are adopting the same methodology to implement committees in 6 other factories. Giving workers a voice in this way is crucial if we want to improve working conditions, achieve sustainable sourcing agreements and create stable economic growth. The project trained managers and workers on the importance of elected workers’ committees and the different roles and responsibilities of members. Workers have also gained a better understanding their rights and role within the workplace. We worked especially with elected female representatives on social dialogue and their role in workers’ committees. Women are often paid less than men, and may face gender-based discrimination. Thanks to the workers’ committees, women can now raise their specific concerns, and factory management is more likely to take action to resolve them. See page 25 for more about our work on gender equality.

We have also been setting up 24-hour hotlines in all our factories in the UK. Posters have been provided to raise awareness of the importance of speaking up, asking that workers make someone aware if they or their co-workers have been forced into work, haven’t been paid or are treated unfairly. Calls to the hotline are investigated and the necessary steps taken to remediate the issues raised.

In 2016, we started a partnership with NGO Inno Community Development to roll out a helpline to workers in 300 factories across China. An update on the progress and achievements of this partnership will be provided in next year’s report.

34

35

Environment 36

37

Environment

With internal guidance developed together with our Environment Standards, we expect suppliers to meet our minimum standards and prioritise action on their biggest issues, encouraging them to: • Have a written plan and targets for managing environmental impacts • Measure and track their impacts

Our vision is to transform fashion into a force for positive environmental change. To realise this vision, we are focusing on: • Inspiring environmental management in our supply chain • Reducing the environmental impact of our operations and products The apparel supply chain is complex, with many different suppliers responsible for spinning, weaving, dyeing and finishing fabric that is then used to make clothes. Each stage of production comes with its own environmental challenges, from the high volume of water needed to grow raw materials to the threat of pollution from chemicals used in the dyeing process. Such a complex supply chain makes it hard to address the environmental footprint of our products across their entire life cycle, so we’re starting with what we know – our supply base. Our priority is to inspire a proactive approach to environmental management across the factories and operations of our direct suppliers, with whom we have the closest relationships with and most influence over. As we develop our environmental programme further, we are expanding its scope to incorporate raw materials, aiming to find more sustainable alternatives to reduce the environmental impact of our operations.

Our approach We are committed to protecting the environment, conserving natural resources and conducting business in an environmentally responsible manner. In 2012, we became a signatory to the Sustainable Clothing Action Plan (SCAP), a joint industry commitment to a 15% reduction by 2020 in carbon emissions, water usage and landfill waste related to clothing. As a retailer, the biggest opportunity we have to minimise our environmental footprint lies in our supply chain – in the manufacturing of our products and the materials used to make them. We want to inspire our suppliers to conserve energy and resources, reduce their waste and emissions. We set clear environmental standards for our suppliers and we work closely with them to make targeted improvements. Inspiring environmental management in our supply chain We want to work with suppliers that share our vision and do business in a similar way. Our Supply Chain Environment Standards cover seven areas where our suppliers and factories can make improvements: energy, water, hazardous substances, raw materials, air emissions, wastewater and solid waste.

Our Environment Standards: Summary Read the full standards in the Appendix 1

38

Energy

Monitor and reduce energy use and related greenhouse gas emissions through energy efficiency measures, or use of renewable energy.

2

Water

Save water by taking steps like fixing leaks and reusing water where possible.

3

Hazardous substances

4

Raw materials

5

Air emissions

Monitor air quality and minimise harmful air emissions.

6

Wastewater

Treat all wastewater and make sure that all wastewater leaving the factory meets the highest standards.

7

Solid waste

Reduce, reuse and recycle waste.

Make sure that workers handle chemicals safely without contaminating the environment and use non-hazardous alternatives where possible. Ensure that all raw materials can be traced back to their source.

For suppliers in key sourcing countries, we offer an Environmental Scorecard that enables them to benchmark their performance on fuel, water, raw materials, chemicals and waste. They can use the scorecard to set targets, identify potential projects and solutions, and measure cost savings and other benefits. Our in-country CSR specialists are also on hand to engage in follow-up conversations with factory managers, and conduct site visits to support improvements.

• Set up appropriate governance structures

Extending our impacts further into the supply chain

• Take practical steps to reduce their environmental impact, using their own experience as well as our guidance on new techniques and ideas

We know that each tier of our supply chain faces its own unique environmental challenges. After mapping our supply chain, we are gaining a better understanding of this complexity, and now know that many challenges have their root causes beyond our factories – sometimes back to the mills or farms. But because these tiers are further removed from New Look’s direct operations, we often have less leverage and must work closely with partners in order to achieve positive impacts. Through partnerships and collaborations, we are going beyond the first tier of our supply chain to work with our indirect, second-tier suppliers, such as fabric mills and dye works (see case study).

We recognise that different parts of our supply chain face different environmental challenges. For example, some regions experience rising power costs and poor energy security, while water shortages are the main risk in other areas. We take a pragmatic approach, expecting and supporting factories to prioritise their biggest impacts first.

Case study Better Mills Initiative in China Helping the mills and factories to address environmental challenges is a win-win situation. It’s good for the environment, resulting in better conservation of energy and water, improved chemical management, and better pollution control. It’s good for suppliers, because it results in efficiencies and cost savings; and it’s good for us because it helps our products be more environmentally friendly. However, the challenge is too big for us to tackle alone. That’s why in 2014 we joined the Better Mills Initiative, a partnership set up in 2013 by the NGO Solidaridad and other fashion retailers to reduce the environmental footprint of textile processing in China. China is the world’s leading apparel manufacturer, but the average Chinese textile mill consumes three to five times more energy than those in more developed countries. Through a combination of training workshops and on-site technical support for participating mills, BMI introduces effective methods for improving environmental impacts. The overall aim of this work is to improve the sustainability performance of textile wet processing in the fashion supply chain in China. Beginning in 2014, we introduced BMI projects to two of our mills that specialise in bleaching, dying and printing textiles. New Look was responsible for facilitating contact with suitable mills, joint evaluations with Solidaridad, and analysis of areas for improvement. At the same time, Solidaridad provided the expertise for conducting training sessions, conducting baseline assessments, and hands-on technical support.

Participating mills learned that changes do not need to be expensive or difficult to be impactful. In fact, 70% of the improvement measures identified required less than 50,000 RMB. We saw significant results in less than 18 months; some highlights from the two mills are outlined below. Mill 1

Mill 2

• Introduced water reuse for washing and cooling, saving 15,000 tons of fresh water annually

• Installed new dyeing machines, resulting in annual water savings of 75,000 tons

• Reduced annual sulphuric acid consumption by 600 tons

• Optimised the wastewater treatment plant and added a water reuse system, saving 210,000 tons of water annually

• Strengthened the waste heat recovery system, saving 294 tons of steam and more than 100 tonnes of carbon dioxide • Reduced electricity consumption by more than 3,000 kWh by moving the compressor discharge port outside, so that less cooling was required

• Insulated steam pipes to reduce heat loss, resulting in a cooler workshop and lower cooling costs • Isolation of hazardous chemicals to improve health and safety and reduce chemical risk

We think the BMI programme is very helpful to us. We reviewed the baseline assessment report from Solidaridad and have made the improvement that is practical to the company. Vice General Manager of Mill 1

39

Reducing the environmental impact of our operations and products In 2012 we joined the Sustainable Clothing Action Plan (SCAP), an industry initiative to reduce the carbon, water and waste footprint of clothing supplied and received in the UK by 15% by 2020*. Together with the SCAP team, we have conducted baseline assessments of our environmental impacts, and found that the largest impacts are in the production and processing stages of many of the fibres we use. Polyester, cotton and cellulosic fibres account for over 80% of our global fibre mix. Although cotton accounts for a third of our fibre mix, it was responsible for nearly 80% of our total water impact in 2015. Using this initial analysis, we have identified a number of proposed key actions that will help us towards the SCAP targets, such as exploring more sustainable fibre alternatives and how we can incorporate them in our collections. We have also joined the Better Cotton Initiative to understand how best to minimise the environmental impacts of our cotton production (see case study).

Case study Working towards sourcing Better Cotton Cotton is a natural, renewable fibre and its production supports 250 million people’s livelihoods around the world. But the industry faces social and environmental challenges such as low incomes, hazardous working conditions and depletion of water supplies. Although cotton accounts for just a third of the fibres we use, it’s a major contributor of the overall environmental impact of our fibre mix. In February 2016, we became a learning member of the Better Cotton Initiative (BCI), a not-for-profit organisation that aims to make global cotton production better for workers and the environment. BCI trains farmers to grow crops to the Better Cotton Standard, using more sustainable farming practices that improve working conditions and incomes; promote more efficient water, fertiliser and pesticide use; and promote thriving ecosystems. In the first year as a learning member, we aim to learn more about BCI and how to work with our suppliers to procure Better Cotton. We have established a system that will enable us to track sustainable fibres in our supply chain and we are engaging in discussions with our key suppliers and buyers to understand the implications of buying Better Cotton and setting up feasible targets. By 2017, we aim to become a standard member of BCI and begin procuring Better Cotton. As a BCI Retailer and Brand Member, New Look will commit to improving cotton production through both our actions and our financial investment in the Better Cotton Initiative (in the form of membership fees). We look forward to the opportunity to share best practices, learn from peers and develop joint solutions to challenges in the industry.

* Compared to a baseline of 2014 for New Look

40

41

Animal welfare

42

43

Animal welfare Some of our products contain materials that come from animals, such as leather or feathers. As a responsible business and a good citizen, is vital that we protect the welfare of these animals.

• Freedom from hunger and thirst

Our commitment with our suppliers is that all animal derived products that are allowed to be used in our products must always be a by-product of the meat industry.

• Freedom to express normal behaviour

We are committed to animal husbandry that respects animals’ wellbeing at all times during the production of animalderived materials, and we work with suppliers to improve their standards of animal care. It is unacceptable to us that the manufacture of our products could cause any suffering for animals. That is why we also avoid purchasing products from suppliers that have conducted, commissioned or been party to animal testing.

We require that suppliers engage in a due diligence process to keep track of animal derived products and monitor that our standards are upheld. If a supplier does not uphold our welfare policy, we work with them to improve their standards and address any issues. But should suppliers fail to show any progress within an agreed timeframe, we cease working with them.

Our Animal Welfare and Animal Protection Policy (see Appendix) lists the materials that are prohibited in our products, because of a higher risk to animal welfare. These include animal fur, materials from endangered species, leather or skin products from exotic and wild-caught animals, Mongolian lamb fur, Karakul wool, Australian Merino wool and Angora hair. Our approach Transparency at all times, and close partnership with our suppliers, enables us to trace back to the source and ensure our animal welfare standards are understood and met throughout the supply chain. We only work with suppliers who have the same high animal welfare standards as we do. All suppliers must sign our Animal Welfare and Animal Protection Policy, which outlines our expectation that they only source animal-derived materials from farms with good animal husbandry. Animals should be managed and cared for in a way that guarantees them:

44

• Freedom from discomfort • Freedom from pain, injury or disease

• Freedom from fear and distress

As part of our due diligence process, in 2014/15, we began to map the tanneries used for leather products and the origin of the hides used to make our products. This information is now helping us establish the most effective ways to engage with suppliers further down the supply chain to improve standards for leather production – not only regarding animal welfare, but also for social and environmental issues such as health and safety or water pollution.

Animal testing We believe that animal testing for cosmetic purposes is unacceptable. Our Animal Testing Policy (see Appendix) outlines our commitment not to purchase ingredients, formulations or products that have been tested on animals, or knowingly purchase it from suppliers that carry out any form of animal testing, even if not in our own products.

Our CSR team works with other departments to conduct training and awareness sessions on animal welfare issues. This is particularly important for our buying and technologist teams, who are the main point of contact for suppliers to ensure our transparency requirements are met for animalderived products. Use of animal products The first step to achieving our objectives on animal welfare is to know exactly where our materials come from. We are mapping our supply chain to better understand every step of our products’ journey and identify where animals are involved. Suppliers must provide this information regularly and we use scientific species identification tests to validate that materials are from the animals stated. Regarding down feather, we actively seek industry-wide initiatives and collaboration to monitor and improve animal welfare standards and use our collective leverage to address issues found deep within the supply chain. In addition to being a by-product of the meat industry, we have clear policies in place stating that feather and down obtained from the live plucking of birds are not permitted in our products.

45

Appendix

46

47

Appendix

New Look Ethical Aims Based on the Ethical Trading Initiative Base Code

4.1. There shall be no new recruitment of child labour (under the age of 15).

1. Employment is freely chosen

4.2. Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child.

1.1. There is no forced, bonded or involuntary prison labour. New Look CSR Aims New Look’s CSR Aims represent the ethical and environmental standards used as a framework when conducting our business. Suppliers, agents, factories and units producing for New Look show commitment to work toward achieving these standards. If an employee feels they are unable to resolve an issue through existing procedures, they should be able to contact New Look’s CSR Department on ethical.support@ newlook.com. The provisions of this code constitute minimum and not maximum standards, and this code should not be used to prevent companies from exceeding these standards. Failure to meet our ethical aims may result in termination of the business relationship and the cancellation of all outstanding and future New Look orders at our discretion, without liability to New Look.

4. Child labour shall not be used

1.2. Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice. 2. Freedom of association and the right to collective bargaining are respected 2.1. Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. 2.2. The employer adopts an open attitude towards the activities of trade unions and their organisational activities. 2.3. Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace. 2.4. Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining. 3. Working conditions are safe and hygienic 3.1. A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment. 3.2. Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers. 3.3. Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. 3.4. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

4.3. Young persons (under the age of 18) shall not be employed at night or in hazardous conditions. 4.4. These policies and procedures shall conform to the provisions of the relevant ILO standards. 5. Living wages are paid 5.1. Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income. 5.2. All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid. 5.3. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded. 6. Working hours are not excessive 6.1. Working hours comply with national laws and benchmark industry standards, whichever affords greater protection. 6.2. In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7 day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate.

3.5. The company observing the code shall assign responsibility for health and safety to a senior management representative.

48

49

New Look Environment Standards 7. No discrimination is practised 7.1. There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation. 8. Regular employment is provided 8.1. To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice. 8.2. Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub- contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixedterm contracts of employment. 9. No harsh or inhumane treatment is allowed 9.1. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

Based on international industry standards, most are included in local law. The following standards constitute MINIMUM standards, not MAXIMUM standards, and should not be used to prevent companies from exceeding these standards. They are divided under seven distinct topic headings: energy, water, hazardous substances, raw materials, air emissions, wastewater, and solid waste. We expect all entities that take part in the manufacturing and finishing of New Look products to: • Have a written plan for managing environmental impacts, with targets • Measure and track their environmental impacts • Create organisational responsibility for environmental management • Take practical steps to reduce their environmental impacts 1. Energy 1.1. Continuously measure, record and track the amount of electricity, gas, and fuel used onsite, including for transportation, from all sources, including any on-site generation. 1.2. Set targets to energy consumption and start a programme to achieve the reduction. 1.3. Carry out projects to reduce the site’s consumption of energy. 2. Water 2.1. Continuously measure, record and track the amount of water used onsite, for both domestic and industrial processes, and from all sources – municipal mains, groundwater (boreholes and wells), and surface water (rivers, lakes). 2.2. Obtain permits and licenses required by local and national law and have test results on- site to demonstrate legal compliance. 2.3. Set targets to reduce water consumption and start a programme to achieve the reduction. 2.4. Carry out projects to reduce the site’s consumption of water. 3. Hazardous substances 3.1. Continuously measure, record and track use of hazardous substances. 3.2. Keep an inventory of hazardous substances used, handled, transported and stored onsite, including their quantities and where they have been bought from.

50

3.3. Make sure Material Safety Data Sheets (MSDSs) are available in the local language for all hazardous substances used onsite. 3.4. Ensure control measures are in place to prevent workers from being exposed to hazardous substances and to prevent them contaminating the environment. This should in include: training for workers who handle hazardous chemicals on how to do so safely; and clear labelling of all hazardous chemical containers and storage in secure areas with spill prevention/secondary containment vessels. Chemicals should never be poured directly into the ground or washed directly in surface water. 3.5. Communicate emergency procedures to workers and follow them in the event of a spill or release. 3.6. Make sure that all chemicals used in the manufacturing of New Look’s products comply with New Look’s Restricted Substances List. 3.7. Take steps to reduce the use of hazardous substances and replace them with safer alternatives. Where possible, use biodegradable chemicals if they meet the same technical performance requirements. 4. Raw materials 4.1 Trace raw materials and keep appropriate records to show this. For man-made materials this should be back to the final production process location, for natural raw materials (such as cotton) this should be back to the country in which they were harvested. 5. Air emissions 5.1 Continuously measure, record and track emissions generated by onsite combustion and conduct periodic air quality testing to capture air quality on the factory floor. 5.2 Minimise, and as appropriate, treat before release, all emissions to air that have potential to adversely affect human health and/or the environment. 5.3 Obtain permits and licenses required by local and national law and have test results on- site to demonstrate legal compliance. 5.4 Set targets to reduce emissions to air and start a programme to achieve the reduction. 5.5 Keep a list of all air emissions points within the factory and which substances are emitted at each point. 5.6 Install air extraction devices in areas of the factory where fumes or particulates (including dust) are generated and can be inhaled by workers.

51

6. Wastewater

7. Solid waste

6.2 Employ a trained individual, who understands the processing requirements and regulations for wastewater discharge, to operate any onsite ETP.

7.1 Continuously measure, record and track the types and amount of solid waste produced by the factory. This should be done for all solid waste streams including: fabric, paper, plastic, general (domestic) and sewage sludge if there is onsite wastewater treatment, and any hazardous wastes.

6.3 Measure, record and track wastewater volume and quality by collecting samples from the final discharge points.

7.2 Have systems in place to ensure the safe handling, movement, storage, recycling, reuse, or disposal of waste.

6.4 On a monthly basis (or as required by the law, whichever is greater) measure: Oxygen Demand (COD), Biological Oxygen Demand (BOD), pH, temperature, colour, Total Suspended Solids (TSS), and Total Dissolved Solids (TDS), and specific metals.

7.3 Set targets to reduce solid waste production and start a programme to achieve the reduction.

6.1 Treat all wastewater in a fully functioning effluent treatment plant (ETP) either on-site or in a shared ETP off-site before discharge.

6.5 Ensure that wastewater leaving the site meets the BSR Water Quality Guidelines which New Look supports and all applicable local and national laws. 6.6 Obtain permits and licenses required by local and national law and keep test results on file for at least 12 months to demonstrate compliance. 6.7 If discharging to a central ETP, have on file valid permits to do so, and test reports that show compliance with the central ETP’s requirements.

New Look Animal Welfare Policy* Animal Welfare and Animal Protection Policy We consider it unacceptable to harm animals in the process of manufacture of our products. All our suppliers must meet strict animal welfare requirements and ensure our animal welfare standards are maintained at all times. Our suppliers must only source animal derived material from farms with good animal husbandry . Good animal husbandry means animals have: • Freedom from hunger and thirst: by ready access to fresh water and a diet to maintain full health and vigour.

7.4 Make someone responsible for meeting these targets.

• Freedom from discomfort: by providing an appropriate environment including shelter and a comfortable resting area.

7.5 Consider reducing, re-using, and recycling for each waste stream.

• Freedom from pain, injury or disease: by prevention or rapid diagnosis and treatment.

7.6 Track the disposal route for each waste stream.

• Freedom to express normal behaviour: by providing sufficient space, proper facilities and company of the animal’s own kind.

7.7 Obtain permits and waste receipts required by local and national law and keep them on file to demonstrate legal compliance 7.8 Dispose of hazardous waste safely and legally using licensed waste contractors only.

• Freedom from fear and distress: by ensuring conditions and treatment which avoid mental suffering. We believe that using some animal materials is unacceptable in any measure, and as a result, we never use the following in our products: • Animal Fur: This includes both farmed fur (e.g. fox, mink, sable) and fur which may be a by-product of the meat industry (e.g. rabbit). • Endangered Species: This is defined as those species which appear on the CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora) or IUCN (International Union for Conservation of Nature) lists of endangered species. Information on these lists can be found at http://www. cites.org and http:// www.iucnredlist.org respectively. • Karakul: Or any leather or skin products that are the product of unnatural abortions. Sometimes called Astrakhan, Broadtail, Persian Lamb, Swakara or Krimmer. • Leather or skin products from exotic and wild caught animals: New Look does not accept the use of skins from wild- caught animals or real exotic animal skins, including but not limited to; reptile skins, snake, alligator, crocodile and lizard. New Look Retailers does not accept the use of these materials in any of its products. • Mongolian Lambs Fur: Due to the practices involved in the traditional methods of slaughter, we will not use this sheepskin variety. • Australian Merino Wool: Due to the widespread practice of mulesing sheep in Australia we will not use Merino wool sourced from Australia.

• Angora: Due to the reported plucking methods used by some angora suppliers, we do not accept any products containing angora. We sometimes use the below listed animal materials in our products under the following conditions. When we do, we only work with suppliers which provide us with information that enables us to trace their supply chain down to the farms. • Leather or Skin Products: All leather used for New Look Retailers Ltd must be a by-product of the meat industry. It can never be obtained from live skinning or live boiling, or from aborted, exotic, wild-caught or endangered animals, and must come from farms with good animal husbandry as per our definition. • Feather/down: New Look only accepts down, feathers and decoration feathers which are a by-product of the meat industry, excluding the production of foiegras, and must come from farms with good animal husbandry as per our definition. We do not accept feathers or down obtained from the live boiling; live plucking, endangered, exotic or wild-caught animals. All our down and feathers must be sterilised as per the EU standard EN 12935. • Wool, including mohair and alpaca: New Look only uses wool originating from farms with good animal husbandry as per our definition. We are strictly against the practice of mulesing and do not accept wool from farms that expose the animal to suffering as a result of this practice. • For materials made of animal hair New Look only accepts hair from living animals, including cow, buffalo, yak, horse, goat, pig and alpaca when this is sourced from farms with good animal husbandry as per our definition. No vulnerable or endangered species must be used. Animal Testing Policy We believe that animal testing for cosmetic purposes is not acceptable. We recognise that customer safety is of paramount importance but that this can be assured without the use of animal testing. However, we may occasionally use in our cosmetic products ingredients which are animal derivatives but which may be collected without harm to animals. • We will not conduct, commission, or be party to any animal testing of cosmetic products or ingredients. • We will not knowingly purchase ingredients, formulations or products from suppliers that have conducted, commissioned or been party to animal testing for cosmetics purposes on these products after the company’s fixed cut-off date. In order to verify supplier compliance with this policy, the company obtains written certificates of supplier assurance from each of their suppliers on an annual basis.

* New Look follows recommendations on animal welfare set out by the World Organisation by Animal Health (OIE) in their Animal Health Codes and the Farm Animal Welfare Committee (FAWC) and their Five Freedoms. http://www.defra.gov.uk/fawc/about/five-freedoms/, http://www.oie.int/eng/en_index.htm

52

53