Robust Risk Identification and Monitoring
Many of our sourcing regions are vulnerable to climate change, economic inequality and potential human rights risks.
These can include gender-based violence and harassment, forced or child labour, poor access to sanitation and inadequate grievance mechanisms.
We expect suppliers to respect human rights and uphold core labour principles, as set out in our Supplier Code of Conduct and Human Rights Policy. To monitor the standards in our supply chain, our in-country teams carry out two key programmes: TCNA for tea and herbs and FMIP for our Tier 1 suppliers.
Twinings Community Needs Assessments
It’s important that people working for our suppliers can talk to us about their work and quality of life so that we can help ensure their rights are respected.
As well as purchasing tea only from Rainforest Alliance-certified gardens, we go beyond solely relying on third-party certification by monitoring standards in our tea and herb supply chains through our proprietorial Twinings Community Needs Assessments (TCNAs).
Through this programme, launched in 2016, our on-the-ground team of 13 people based in our key sourcing countries focus on listening directly to workers, farmers and their communities.
We encourage them to speak freely, without fear of retaliation, about challenges they face, particularly related to gender, working conditions, grievance mechanisms, children’s rights, housing, health, sanitation and wages.
The feedback helps us implement tailored corrective action plans so that we can track progress on improvements.
TCNAs usually last three to five days, and every tea estate and garden is visited at least once a year. Due to the complexity of our herb supply chain – with up to 12 sourcing countries per ingredient per supplier – it is unrealistic for us to visit every potential supplier and sourcing community. For that reason, we will be rolling out assessments based on a risk-based approach in FY25/26.
Factory Monitoring Improvement Programme
Our Factory Monitoring Improvement Programme (FMIP) helps us assess and manage human rights and worker safety across our Tier 1 suppliers and factories.
Each site is assessed and rated high, medium or low risk. Low- and medium-risk sites undergo sample spot checks, while all high-risk sites, defined as those with significant potential for human rights or labour issues, as well as being significant suppliers to our business, require an audit.
Audits are carried out by independent experts and consider criteria including health and safety, grievance and remedy mechanisms, migrant workers and recruitment, subcontractors and indirect worker management. As a member of Sedex (Supplier Ethical Data Exchange), we use its platform to inform the assessment process.
Based on audit findings and remediation requirements, we rate sites to determine the frequency of future audits:
- Red rating – re-audited following the completion of time-bound remediation plan
- Amber rating – audited every two years
- Green rating – audited every three years
Where non-compliances are identified, suppliers are required to take action to resolve the issues within a specified time frame.
Addressing forced and child labour
We recognise the growing risk of forced and child labour in tea gardens and estates, particularly as they become more reliant on migrant workers due to economic shifts.
The presence of forced or child labour in any form is unacceptable. It stands in direct opposition to our values and is a breach of our policies, including our Code of Conduct.
What we’re doing:
- Using our TCNAs and FMIP to help us identify potential human rights risks.
- Developing dedicated child and forced labour procedures, alongside a clear human rights impact procedure, to guide us, and in turn our suppliers, in identifying, preventing and helping to eliminate all forms of exploitation.
- Working with external human rights experts to increase our understanding of root causes, strengthen risk assessments and co-develop remediation plans with suppliers, wherever appropriate.