As a global corporate citizen Walgreens Boots Alliance (WBA) recognizes its responsibility to address and mitigate the risk of modern slavery and human trafficking in its operations and supply chains. This statement sets out our commitment to eradicating these abhorrent practices and describes the actions we have taken through the end of our fiscal year, August 31, 2019. This statement meets the requirements of the UK Modern Slavery Act 2015 and the California Transparency in Supply Chains Act of 2010.
Furthermore, through this statement, we confirm our commitments to the Consumer Goods Forum (CGF) resolution against forced labor and to the Employer Pays Principle, which state that every worker should have freedom of movement and that no worker should be indebted or coerced to work or pay for a job.
Structure, Business and Supply Chains
A description of WBA’s structure, values, Divisions and product brands can be found in our Annual Report and in our annual Corporate Social Responsibility (CSR) Report, both on our website. CSR is embedded in our drive to operate both a sustainable and profitable enterprise and is at the core of our everyday work. Our CSR Committee, chaired by Co-Chief Operating Officer Ornella Barra, reports to the WBA Board of Directors’ Nominating and Governance Committee. The CSR Committee meets regularly to review our CSR program, policy statements and progress toward achieving our 12 CSR commitments, including our commitment to drive responsible sourcing practices throughout our supply chain, protecting human rights and engaging with suppliers around ethical and environmental issues.
WBA’s permanent working group on modern slavery reports to the CSR Committee and is tasked with driving ongoing improvements and a consistent approach to the issue. The group is made up of representatives from across our businesses and led by a senior leader.
We recognize that business alone cannot eliminate modern slavery, a goal that can be achieved only through long-term partnership and collaboration between businesses, nonprofit groups and governments. We are proud of our membership in organizations such as CGF and the Palm Oil Transparency Coalition that work toward this common goal.
The WBA Code of Conduct and Business Ethics, available on the Governance section of our website, provides the foundational standards for all aspects of our business and applies to all of our employees and operations globally.
The Code makes this clear commitment: “(w)e will also strive to ensure that slavery and human trafficking is not taking place within any of our supply chain business partners and will not tolerate such activities either within the supply chain or within any part of WBA’s business.” The Code further sets forth the responsibility of every employee to help ensure all of WBA’s global activities meet our high standards for behavior and business ethics, and establishes accountability for compliance with law and policy.
These issues are also addressed in our worldwide set of vendor responsibility and sourcing standards, the WBA Ethical Trading Standards Policy, which states our opposition to the exploitation of workers through any form of forced or bonded labor, slavery, human trafficking or other labor practices that involve harsh or inhumane treatment.
With regard to our own labor practices, the Code of Conduct further sets forth our standards for a diverse workplace that provides a safe and healthy environment and that complies with or exceeds local law. The WBA Global Human Resources Policy requires an effective program be in place to help ensure compliance with labor laws involving migrant and foreign national workers. During fiscal 2019 our human resource policies were updated to address the reporting, investigation, and disposition of any potential modern slavery claims within our own business.
As we are a global Company with businesses in many countries, local policies provide additional guidance and detail on these issues. However, such policies may only enact standards that are equal to or stricter than those of WBA.
Regarding potential violations or concerns within our supply chains or our own workforce, our Code of Conduct provides confidential reporting helplines managed by external services that can be used to report any concerns. These contact points are available 24 hours a day, seven days a week and in a number of languages.
Supply Chain Due Diligence
As described above, WBA’s permanent working group on modern slavery considers more fully our Company’s risk of exposure to these practices and risk mitigation activities. Following a 2018 review of potential exposure to modern slavery, the group developed a continuing action plan targeting the highest risk operations through a phased approach.
WBA works with multiple service providers to facilitate risk and compliance due diligence reviews of business partners globally. These reviews may include active monitoring for adverse media regarding modern slavery and other issues.
During fiscal 2019 we partnered with an external provider to review our assessment of ethical standards compliance within our Goods Not For Resale (GNFR) supply chain, starting in our Retail Pharmacy USA Division. GNFR refers to products or services purchased to support business operations. As part of this review we focused on assessing new suppliers prior to onboarding and actively monitored them for a minimum of one year. The top 300 suppliers, which represent the bulk of the Division’s annual GNFR spend, will be continuously monitored on an ongoing basis. This GNFR supply chain review is expanding to the UK with plans for evaluating further rollout across other non-U.S. WBA businesses in the future.
Our commitment to eliminating modern slavery starts with focusing intensely on our owned brands supply chain where we believe we can have the greatest impact. This includes maintaining and continually assessing and enhancing our well-established program of supplier assessment, which is delivered through our own ethical trading auditors or a small number of pre-approved third-party assessment bodies. Our ethical trading experts across the globe meet on a regular basis to ensure the program remains effective and drives best practice across our supply chain.
The assessment program, developed over 10 years, helps ensure our owned brand suppliers are fully aware of our standards and expectations. This is achieved through supplier manuals, contracts, technical agreements and mandatory ethical compliance assessments. Suppliers must further agree to provide evidence of their related compliance programs, which should also include a process for assessing the ethical standards of their own supply chains. Analysis of our assessment program shows levels of compliance with our ethical trading standards are significantly higher for existing sites than for new sites. This reflects increasing understanding and commitment from our supply chain to maintaining our standards.
Assessment results are shared monthly with the WBA senior management team. We also have in place a formal escalation process whereby any zero tolerance modern slavery issues or other serious violations of our standards that we become aware of are reported to the senior management team within 24 hours, along with the results of any investigations.
In fiscal year 2019, we conducted more than 1,200 ethical compliance assessments on new and existing suppliers for our Walgreens and Boots UK owned brands. Our assessment ratings are defined by the severity and/or number of incidents of noncompliance identified during the assessment process, these are currently defined as:
- Satisfactory and Needs Improvement: Meets our ethical trading standards expectations but could require differing levels of remedial corrective actions
- Critical: Falls below the expectations of our ethical trading standards and requires immediate remedial action to address the critical incidents of noncompliance to enable new or ongoing business relationships
- Zero Tolerance: Issues identified that are not accepted or tolerated by our businesses and are related to incidents of the following but not limited to:
- Child Labor
- Convict/Indentured/Forced Labor
- Corporal Punishment
- Slavery and Human Trafficking
- Acts of Bribery
The following table provides a breakdown of assessments and outcomes during fiscal year 2019.
|Fiscal Year 2019||Fiscal Year 2019 %|
Our policy in cases of zero tolerance violations is to terminate the business relationship with the site where the violation occurred and to suspend the supplier and its other sites pending a full investigation of the supplier and its supply chain. If the supplier is directly implicated in the zero tolerance violation, or if further violations are found, the business relationship with the supplier will be terminated. For suppliers where we identify critical noncompliance issues, corrective and remedial action plans are developed and implemented. In the small number of cases where suppliers are unwilling to work with us to achieve compliance within an agreed time frame, we maintain the right to end the business relationship and cancel outstanding purchase orders. However, simple termination of a contract relationship may not always be the most appropriate response. We recognize that in the event of noncompliance, withdrawal of our business may cause severe hardship to those employed and we will therefore attempt to work with our vendors through a remediation program to achieve ongoing compliance.
We want to work with suppliers who are open and transparent, so in order to reinforce this commitment, we request that our owned brand suppliers agree to our right of unannounced assessments at any time that they are operating.
Training and Awareness
During fiscal 2019 we developed a Company-wide training initiative to continue to drive ethical sourcing practices across our supply chain, protect human rights and support diverse suppliers. This training initiative is being implemented in fiscal 2020 and expanded to include select WBA employees globally in human resources, international retail and owned brands, including management. This builds on previous training modules focused on employees and management involved in and responsible for sourcing, supply chain and retail operations, which will be relaunched to existing and newly hired employees.
In our Retail Pharmacy USA Division, relevant employees are required to complete annually an online training course that fulfills the requirements of the California Transparency in Supply Chains Act of 2010.
We continue to conduct regular conferences where we discuss our ethical standards as part of an ongoing engagement with our suppliers. During fiscal 2019 a supplier conference was held in Asia, attended by over 100 suppliers. We also provide a supplier manual that explains our Code of Conduct and Business Ethics, assessment requirements, capacity building and continuous improvement programs.
Effectiveness and Performance Indicators/Monitoring
We recognize that the risks from modern slavery change, and as such our approach to preventing modern slavery is expected to be reviewed annually by the WBA permanent working group on modern slavery. This approach will monitor and review:
- Effectiveness of risk assessment processes
- Staff training programs
- Assessment programs (where applicable); and
- Reporting and escalation processes.
This statement is made pursuant to the relevant legal requirements of the United States (including the individual states therein) and the United Kingdom, and covers the UK subsidiaries listed here.
Co-Chief Operating Officer Walgreens Boots Alliance, Inc.
Chairman of the Corporate Social Responsibility Committee
(updated January 2020)