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2018 Corporate Human Right Benchmark (CHRB)

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Structure of the report

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NEXT PLC.sustainability                   -case study

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NEXT PLC.sustainability                   -case study

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Deadlines for Critical Works of NEXT Project

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Deadlines for Critical Works of NEXT Project

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SWOT

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COS and sustainability: C-label | Buy sustainable brands

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COS has achieved the C-label. With this score, COS is on its way towards sustainability, but more improvement is needed. Brand owner H&M Group implements several policy measures to reduce the climate emissions of its own operations and in the supply chain.

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Primark, the Irish fashion retailer owned by Associated British Foods (ABF), is seen as one biggest fashion retail success stories of the past decade. Best known for its low price and high value offering, "Amazing fashion, amazing prices", the high street staple has extended its reach across Europe and overseas into the United States. However, in spite of its retail success, Primark has been struggling to overcome the consumer's pre-fixed notion that fast-fashion is not sustainable, and certainly not ethically made.

Following the tragic collapse of Rana Plaza, the most deadly accident in the history of the garment industry, more and more people begun to question how a t-shirt costing as little as 2 pounds could ever be responsibly made. On April 24, 2013 a building housing five garment factories which manufactured products for approximately 28 brands, collapsed in near Dhaka, Bangladesh, claiming the lives of 1,138 workers and injuring more than 2,000 individuals. The tragedy was not only seen as a wake up call for the international fashion industry to band together and protect those most vulnerable in their supply chains - it was also a immediate call to action for Primark, who sourced from New Waves Bottoms, a supplier in Rana Plaza, to take a closer look at its ethics and CSR, to see where it could improve.

Primark was among the first retailers to sign the Accord on Fire and Building Safety in Bangladesh, initiated by the IndustriALL and UNI Global Union. It was also one of the first to ensure the factory victims and families affected by the collapse receive financial support and food aid immediately following the disaster. The value retailer pledged to give both short and long-term financial compensation to those affected by the factory collapse and has paid a total of 14 million dollars to date - 11 million of which has gone to workers and families employed by its supplier, New Waves Bottom. Since then Primark has continued to work with local partners and non-profit organisations to ensure any funds or support they gave to workers and their families would be secure by offering financial advice and guidance. In addition, the Irish retailer launched the 'Pashe Achi Project' to ensure compensation recipients retain access to their financial compensation and understand their rights.

What steps Primark has taken to become more responsible following Rana Plaza

Lastly, Primark also tighten its programme of structural surveys in Bangladesh to assess the structural integrity of the factories from which it sources from. At the moment Primark has a team of over 80 experts dedicated to sustainability, ethical fashion and worker training as part of their Ethical Trade Team. These teams based in its nine key sourcing locations, such as China, India, Bangladesh and Turkey, act as the retailer's "eyes and ears on the ground," according to Katharine Stewart, Primark's Director of Ethical Trade & Environmental Sustainability. Primark regularly visits factories where it holds a 'lead' role in respect to the Accord and is in frequent contact with all other factories which it supplies from. But Primark's ethical and sustainable initiatives go much further than Rana Plaza.

Unlike fast-fashion competitors, such as H&M, who has been extremely open in communicating their sustainable initiatives to the public through campaigns such as 'Close the Loop', Primark has remained relatively quiet on what it does in terms of sustainability, ethics, and labour rights. Until recently that is. Following the expansion of its Sustainable Cotton Programme, which sees Primark working with CottonConnect and the Self-Employed Women's Association (SEWA) to support over 11,000 female cotton farmers in India, as well as increasing consumer interest in Primark's own sustainable and ethical practices, Primark has decided to become more vocal concerning its commitments to producing responsible fashion.

"Historically when we did not say anything, people believed that we were not being sustainable at all, when we were just trying to find our comfort level in communicating this," explains Stewart. "It's not something new, it's business as usual and we have been doing it for a very long time. But now our customers are asking us about it, so we are talking about it more...especially now that our customers are getting older, they want to know more." Over the years Primark has implemented a series of strategies and initiatives which vary from improving the livelihoods of its garment workers, to reducing its carbon footprint as well its chemical usage, water usage and waste output, to using more sustainable materials.

"Our purpose is to provide safe, nutritious, affordable food and clothing that is great value for money. In doing these things well we know we contribute to making millions of people's lives better," says George Weston, Chief Executive Officer of Associated British Foods, parent company of Primark in ABF 2016 Corporate Responsibility Update. "However, our decentralised structure, combined with the wide range of our activities, means it is not straightforward for people outside the Company to assess the difference we make to society. That is why we have begun to explore how we can better measure what we do so that we might provide more credible and tangible evidence of our impact."
But is Primark doing enough? FashionUnited shares its findings in its first long-form story looking into the value retailer's sustainability and ethical initiatives.

Foreword from Vivian Hendriksz, Author & Senior UK Editor at FashionUnited:
This in-depth case study on Primark's social and sustainable efforts aims to highlight the complexity and the difficulties faced in bringing around systemic change within the global fashion industry. It also underlines the opposing opinions on whether sustainability and fast-fashion can ever go hand-in-hand.

About Primark

Primark Facts:

Primark is a major retail group. Founded in Ireland in 1969 under the name Penney's.

It operates stores in the UK, Republic of Ireland, Spain, Portugal, Germany, the Netherlands, Belgium, Austria, France, Italy and the US, directly employing 68,000 people.

As of FY2016 it operated 325 stores in 11 countries - Primark does not have an online store.

Primark offers customers quality, up-to-the-minute fashion at value-for-money prices.

Primark's expansive product range includes womenswear, lingerie, childrenswear, menswear, footwear, accessories, beauty, hosiery and homeware.

Primark's buying and merchandising teams in Dublin (Republic of Ireland) and Reading (UK) travel internationally to source and buy fashion items that best reflect each season's key fashion trends.

Photo: Katharine Stewart, Primark's Director of Ethical Trade & Environmental Sustainability. Credit: Primark.

Infographic timeline Primark: FashionUnited

Rana Plaza disaster photo: AFP. Credit: Zakir Hossain Chowdhury / ANADOLU AGENCY

Podcast: Primark Offers Compensation to Dhaka Factory Victims. Credit: PRI's The World

Video: PRIMARK | Rana Plaza: Kushi Mela. Credit: Primark

Video: Primark - There is nothing like us on the high street. Credit: ABF plc

Photo: Katharine Stewart, Primark's Director of Ethical Trade & Environmental Sustainability. Credit: Primark.

Milan, Italy Primark store photo. Credit: Primark.

Milan, Italy Primark in-store photo. Credit: Primark.

What impact does Primark's Code of Conduct really have?

One of Associated British Food's five pillars of corporate responsibility is based on improving and strengthening its supply chain. This includes protecting its most vulnerable pieces - namely its garment workers and ensuring their rights are upheld in each country it produces in. Which is why Primark joined the Ethical Trading Initiative (ETI) ¹ in 2006, and became a leader in 2011. The value fashion retailer remains dedicated to working with other retailers, NGOs, trade unions and organisations across the industry to improve the lives of the people working within the garment industry's emerging markets.

Even before the Rana Plaza factory collapse, one of Primark's main points of focus looked to improve safety standards and worker wellbeing for all its employees around the world. Primark operates using a common set of global standards in all its sourcing hubs, known as its Code of Conduct ². This set of guiding principles is based on the internationally recognised labour standards from the International Labour Organization (ILO) Conventions ³ and the ETI's Base Code. Primark's Code of Conduct lays out the core principles their suppliers and their factories must adhere to when it comes to working conditions, such as working hours, fair wages and workers' rights in order to do business with them. In addition, Primark also works with the ILO Better Work Programme ⁴ in countries such as Vietnam, which aims to help factories meet and uphold international working standards. But just how reliable is Primark's Code of Conduct?

"Primark's Code is much in line with Fair Wear Foundation Code of Labour Practices," points out Lotte Schuurman, Communications Officer at the Fair Wear Foundation ⁵ (FWF). Primark shares a number of core principles within its Code of Conduct with the Fair Wear Foundation Code. For example, each Code states employment must be freely chosen, no child labour, and the freedom to form and join trade unions - all standards derived from the United Nations Declaration on Human Rights ⁶.

However, although Primark's Code of Conduct remains an internationally recognised code of labour conduct, ensuring all its eight principles are consistently upheld at all of its suppliers around the world is another issue in its own right. "Almost all companies have a Code of Conduct, it is just a formality," counters Tara Scally, Campaign Coordinator for the Dutch branch of the Clean Clothes Campaign ⁷ (CCC). "This written down reality says nothing about what is really happening within the supply chain. More transparency is needed to verify if the claims being made in Code of Conducts are really true."

Primark's approach to due diligence and factory audits

Ensuring suppliers and their factories uphold Primark's Code of Conduct is where the retailer's Ethical Trade Team comes in. Previously consisting of only two people in 2007, Primark's current 75 member Ethical Trade Team is of vital importance when it comes to monitoring supplier factory standards and addressing any issues concerning worker rights. The Ethical Trade Teams work in Primark's main sourcing locations, such as China, India and Bangladesh, and consist of trained experts like civil engineers, as well as local people who speak the language and understand local norms and context. "We are always concerned about workers needs and rights within our supply chain. Part of the programme we have in place now is what you call due diligence, and it is all about audits," says Katharine Stewart, Primark's Director of Ethical Trade & Environmental Sustainability.

For example in order to ensure that all garment workers understand Primark's Code of Conduct, which can be difficult in countries such as Bangladesh where many workers are illiterate, Primark has developed posters together with local charities. These posters depict the separate principles of the Code of Conduct in a cartoon-style images which can easily be understood by all workers. Primark also consulted with workers to ensure the posters were displayed in the best possible areas throughout the factories for maximum impact. "We are trying to look collaboratively as to what best practice looks like to build a framework to offer suppliers a consistent message on how this is the standard, and what implementation looks like. Because if there is no support on the systematic implementation of such initiatives, then it makes all the more challenging for suppliers," says Stewart. "What we see on the social side, is that everyone has very similar Codes of Conduct, but various degrees of implementation - which makes it harder for everyone."

The value retailer makes sure each supplier it works with has a full formal audit once a year, which is carried out by Primark's own team or approved external auditors. These audits, which can be announced before hand or not, include confidential worker interviews. This is of vital importance in countries such as India, Bangladesh and Pakistan where women make up 80 percent of the workforce. Female garment workers often face numerous issues such as sexual harassment, threats of violence and prejudice within the workplace. In a factory setting, where the management team usually male dominated, female workers can be pressured to work overtime without pay to reach production targets, or denied the right to maternity or sick leave. Without confidential worker interviews, many of these workers who fear losing their jobs - usually their only means of an income - may never share their real working experience with suppliers clients.

However, some worry that confidential worker interviews and audits are not enough to protect vulnerable garment workers. "Primark should focus on building a solid, long-term relationship with their suppliers based on trust; ensuring labour unions are allowed within the factories they source from and are protected enough so they can do their work freely without threats, or harassment," notes Scally. "Strong union representation can bring labour violations to light. But very often union members are threatened or fired for the work they do. Brands like Primark should use their power to make sure union members are protected." Scally also encourages Primark to join a multi-stakeholder initiative, like FWF, who can verify what is really happening in the supply chain. "Off-site worker interviews by trusted organizations will more likely reveal the truth than company organized visits."

However Primark does not tackle it's factory audits alone. It's own in-house teams are supported by independent, third-party auditing companies, which are said to be "critical" to ensuring Primark upholds its monitoring standards. "We pay for all our audits ourselves as well," adds Stewart. "Our reason for doing so is to control and retain the integrity of them." Usually suppliers contact an external party of their own choosing when conducting a factory audit. By paying for their own audit Primark is able to ensure the integrity of the audit is not influenced by any external factors and gain a clear picture of actual working conditions.

This short film explores the challenges the garment industry in Bangladesh faces as it
continues to develop, from the perspective of the manufacturers and the workers involved.

How transparent is Primark's supply chain?

Unlike some fashion retailers, Primark does not publicly share its audit reports, which raises numerous questions on what exactly Primark is doing to ensure the rights of its garment workers are protected. Fashion supply chains tend to be very long and complex, involving thousands of workers across the board. As Primark does not directly own any of the factories or suppliers it works with, an overall lack of transparency concerning their audit reports can make it hard to ensure their core working principles are constantly being maintained. "Unfortunately, Primark does not enclose their supplier list which makes it really hard to verify if what they communicate about their supply chain is actually true," continues Scally. "On their website, under 'Our Ethics,' ⁸ Primark claims that all factories are inspected and audited. But the inspection reports are not made public, so it is impossible to verify if these inspections are really taking place; what is monitored; what problems are found and what corrective actions come out of these audits."

"Being honest about the issues and problems and the steps brands are taking to improve labour conditions, is key," adds Schuurman. "Our members have to share that in yearly public reports, and we assess their performance, which is also published. Primark is part of the Better Work programme and a full member of ETI - all positive initiatives which can contribute to better labour conditions. From what I've seen is they are grading their factories based on their own audits. It would be interesting to see how they followed up on the audit findings."

"It is impossible for us to know the full scope of its audit programme or how frequently individual factories are audited," adds Jacinta FitzGerald, Head of Research at Project JUST ⁹."The brand does state that all its suppliers must comply with its Code of Conduct, and are audited before any orders are placed." Primark maintains it keeps its audit reports finding private to maintain the "authenticity" of their results - not even the factories and suppliers audited are given full access to Primark's audit reports. Instead, they receive external feedback from Primark and a checklist of areas they may need to improve on going forward. "That way they know what to focus on and we can protect certain parts, such as the confidentiality interviews," explains Stewart. "I think that this is something we made a decision on very early on and it gives us the confidence that the audit paints a clear picture of what is going on in that factory at that point in time."

For example, if an audit finds that factory workers are working more than the allowed overtime per week, Primark will work together with the factory managers to create a more flexible schedule, giving workers less overtime. Primark will then follow up with the factory in question at a later date, either through a pre-announced check or a spot-check, to ensure the issues have been handled effectively. "We try to be proactive and helpful partners when it comes to audits," points out Stewart. "Some factories need help improving certain areas, so we make sure we work together with them by explaining the implications and solutions on the audit checklist." Primark also runs an online supplier management system which offers training programmes on how suppliers can improve their working standards.

But the lack of transparency Primark has concerning its supply chain and workers is still problematic for many organisations. "Transparency is essential for accountability and credibility," counters Schuurman. "Yet it is also a challenge for garment and textile companies, who consider their competitive advantage to lie partially in their unique supply chain decisions - for example, where they are placing orders, prices paid and forecasting. Our experience is that transparency often can be among the most difficult requirements for companies that want to do good. However, some pioneering companies, like Filippa K and Nudie Jeans are beginning to break this mould and commonly report their factory lists, audit outcomes, and other data. But there is still a lot to do in this regard."

One of the reasons Primark does not intend to publicly share the names of all their suppliers is precisely because of their competitive edge. "We've always said that we have worked very hard with our suppliers," notes Stewart. "We currently feel that information is competitive intel we do not want to share. But we do share our supplier information with other partners we are in collaboration with, for example with the Bangladesh Accord ¹⁰. By sharing our supplier base information it enables the Accord to map all the factories that everyone is using in the region as effectively as possible. So we are sharing that information - we are just not making it public. We do share information on which countries we are sourcing from with the public, but not specific factories."

Primark's battle against modern day slavery in its supply chains

Another key issue Primark is focusing on within its supply chain is modern slavery. The value retailer publicly supported the development of the UK Government's Modern Slavery Act in 2015 and outlines all its policies on how it addresses risks within its supply chain in its annual Modern Slavery statement. However, following the influx of immigrants and refugees to Turkey, one of Europe's largest apparel manufacturing hubs, Primark has started to carry out all of its follow up audits and spot checks in the region unannounced to counter the increased risks of child labour and potential forced labour. "One of the issues we face is how to handle refugees and migrant workers in factories," explains Stewart. "We know what they need to have in terms of documentation, but we also know what the challenges are to get the right documentation. So we have put in place partnerships with local organisations who can help [illegal] workers in these situations."

Rather than cutting ties with suppliers who do employ vulnerable refugees, Primark works with suppliers and local partners to help them get papers for legal employment and proper payment. NGOs and trade organisations agree that this, as well as working with trade unions, is key for any fashion retailer in tackling cases of forced labour in developing countries. "Building a solid, long-term relationship with their suppliers based on trust; paying their supplier a fair price for their products; ensuring labour unions are allowed within the factories they source from and are protected enough so they can do their work freely without being harassed are all key to tackling forced labour in the supply chain," says Scally. "Strong union representation can bring labour violations to light. But very often union members are threatened or fired for the work they do. Garment brands should use their power to make sure union members are protected."

Primark does what it can do to help workers employed without the proper legal papers, but in the case of undisclosed sub-contracting, where approved suppliers outsource production to unapproved factories which use methods of forced labour, the value retailer takes decisive action, as it takes any breaches "extremely seriously." Over the years Primark has ensured that they work with local organisations in all of its sourcing locations in order to create a support net for any employment challenges that may occur, according to Stewart. For example, in India, Primark is working together with local partners like the Association for Stimulating Know How ¹¹ (ASK) in one of its main suppliers, Jeyavishnu Mill, to improve its recruitment process. "As a business we care about the impact. For us it's about making sure that the people who touch the supply chain, whether it's the workers or the communities or the environment we operate in, are looked after."

However, despite of all its initiatives aimed at modern slavery issues, Primark is still regularly accused of sourcing from sweatshops and forced labour camps. For example, back in 2014 and 2015 British shoppers are said to have found letters and hand stitched labels in garments pleading for help, which aimed to raise awareness for the terrible conditions workers were apparently forced to endure. After reaching out to the shoppers who found these letters and labels and conducting its own research, Primark claimed the distress calls were all part of an elaborate hoax looking to sully its name.

In addition, Primark failed to score very high in the first 'Corporate Human Rights Benchmark' ¹², the first public ranking of corporate human rights performance. Primark's parent company Associated British Foods (ABF) is listed in the 20-29 percent band range, together with the likes of Next, Kering and TJX Companies. The ranking awarded Primark points for having appropriate policies in place against excessive overtime, forced labour and child labour, but did not award any points to Primark later on, as they did not take sufficient action against alleged impacts of these issues. According to the ranking, the large majority of the low performing companies , which includes ABF, are "falling overwhelmingly behind, with all the dangers for human rights abuse of workers and communities that this implies."

But these rankings have not discouraged Primark from looking for new ways to improve the wellbeing of its garment workers in developing markets. In early 2016, the retailer started a new partnership with the Department for International Development ¹³ (DFID), which sees the two combining their presence, networks and expertise to boost the overall wellbeing of their workers in five of the retailer's key markets - Bangladesh, Pakistan, Burma, Ethiopia and India. A key part of the programme focuses on sharing lessons Primark and DFID learnt following the Rana Plaza incident, including the retailer's initiatives with local partners to provide both long-term and short-term aid. "At Primark, we are committed to ensuring that the people who make our products work in good conditions, are treated properly and paid a fair wage," says Paul Lister, Head of Primark's Ethical Trading Team in a statement. "We know that as well as ensuring worker rights are protected within the factories we work with, we can positively impact lives outside of the factory too. Whether it's financial literacy, health education or helping workers understand their rights, we've seen that simple initiatives with local partners can make a huge difference."

What Primark is doing to improve the lives & wages of its garment workers

Another pillar from ABF's five pillars of corporate responsibility focuses on enhancing the lives of its workers. One of Primark's long-term goals is to source all of its cotton more sustainably, which is why one of its most recent initiatives, and perhaps its most impactful to date, sees Primark working directly with female cotton farmers in India to improve the quality of cotton grown, while enhancing their livelihoods. Primark's sustainability cotton programme in India is a solid example of how a high street retailer can work together with local communities to make a positive change.

At the moment Primark does not purchase any raw cotton directly from farmers, as it does not directly own any mills or factories. Nevertheless cotton, a natural fibre, makes up a large percentage of its apparel range, even though it remains a labour and resource intensive product. Although it is grown on large-scale industrial farms in certain regions, in most cases the cotton used to make textiles and apparel comes from small farms in low-income countries, such as India, China and Pakistan. In these regions a lot of the knowledge concerning the best practices for growing cotton, as well as the most environmental friendly tactics available to do so, tends to be rather limited. Which is why Primark decided to partner with agriculture experts, CottonConnect ¹, and the Self-Employed Women's Association to launch the Sustainable Cotton pilot Programme in 2013.

"The reason we started our Sustainable Cotton Pilot programme four years ago is because cotton is one of the main fibres we use in our products, and we wanted to achieve greater visibility in our cotton supply chain to better understand how it works," says Katherine Stewart, Primark's Director of Ethical Trade & Environmental Sustainability. "We wanted to develop a deeper understanding concerning the manufacturing processes behind cotton." The programme was originally designed to introduce sustainable farming methods, improve cotton yields and increase the cotton farmers income. At the same time Primark decided to exclusively work with female cotton farmers in Gujarat, Northern India during the pilot because they realised many other cotton initiatives lacked gender focus. India currently ranks 130 out of 188 countries in the UN's Gender Inequality Index, as gender equality is seen as one of the most pressing development challenges facing the country.

Hover your mouse over the photos to learn more.

Primark's sustainable cotton pilot has been applauded by numerous international organisations as it focused on the environmental impact of growing cotton, such as the farmers use of water, chemicals and their effects on soil and aimed to improve cotton production by using less water, less chemicals and less pesticides. "In short, we were looking to decrease the cotton farmers input costs, but increase yield of cotton and income and improve their overall lives and health," continues Stewart. "I think that the results of the pilot in relationship to the impact they've had on the cotton farmers have been significant - they've just been phenomenal."

Primark's sustainable cotton pilot supported 1,251 female cotton farmers over three years. It turned out to be such a success that the participating farmers achieved the following results by the third year:

Average farmer profit increased 247 percent during its third year.

Input costs were reduced by 19.2 percent on average,

Use of chemical fertilisers were reduced by 40 percent,

Use of chemical pesticides were reduced by 44 percent,

Water usage was decreased by 10 percent.

"The reported results show that working with farmers at this level can have a number of positive impacts on yields, chemical and water use reduction and increased income," says Jacinta FitzGerald, Head of Research at Project JUST ². "Considering that the majority of Primark's products are made from cotton, we would suggest the brand dramatically increase its initiatives in this area by supporting similar programmes to achieve 100 percent sustainably grown cotton." In fact, the results of the cotton pilot programme were so successful they exceeded all Primark's expectations, which is why the value retailer has expanded the programme to support an additional 10,000 farmers in Gujarat over the next six years. Primark has already begun to train 5,000 new cotton farmers and plans to scale this up in time.

This short film follows the impact Primark's Sustainable Cotton Programme has had on female farmers in Northern India and includes interviews with some of the women involved.

How Primark's Sustainable Cotton Program is impacting the lives of female cotton farmers

"We always knew that we wanted to scale it up - which is why our initial pilot group was so large." The large size of the pilot gave Primark a solid grasp of what effect the programme would have on the lives of the small-scale female cotton farmers and helped them work out any issues they may have. "The key thing to take away from the pilot, apart from the fact than the average income has increased exponentially, is that the farmers have become financially independent," stresses Stewart. "They've been able to purchase equipment, such as tractors, things they would have normally have had to rent out. And not only are they buying their own equipment, they are also renting it out to their neighbours as well." Others have even built their own cotton storage facilities on-site to manage their own cotton sales.

However, this boost in income also brought on a new set of concerns for the female cotton farmers who participate in the pilot, as they were not used to managing a large cash flow. "So now we have implemented our Farmer Field School to help them manage their own income and run their own businesses." By offering these female farmers advice and guidance on how they can best manage their income and oversee their cash flow, Primark aims to ensure the cotton workers become financially independent. For Stewart, the community impact of the programme and the knowledge the farmers have gained thanks to the programme has been the most rewarding to witness.

"It's a ripple effect and quite incredible to see, because they may have a neighbour who grows cumin and now are able to share knowledge on which chemical or natural pesticides are best to use. For me, it's really all about education. Because if you give someone an education, it stays with them and that's sustainable." She stressed that the cotton project focuses on giving farmers a hand up, not a hand down in the form of free seeds, or pesticides or equipment. In addition the Farmers Field School has made Primark realise how important education truly is for farmers and what impact it can have on their lives.

Hover your mouse over the photos to learn more.

Primark has published the results of their sustainable cotton programme on their website, as well as personal stories from the farmers themselves, but Stewart admits the company is still learning on how to take what they have learned from the pilot all the way through to end production to bring it to scale. "It's still early days, but it's going very well...the whole process is a journey of understanding. But now that we have a formula that we know works, we can start to look at how we can do that in different locations." For now Primark has chosen to localise their efforts in Northern India, but it has not ruled out expanding the programme to other countries. "One of our long-term goals is to source all of our cotton more sustainably," says Stewart.

However, Primark's sustainable cotton programme is not its only initiative in place aimed at empowering and educating its female garment workers. For example, one initiative started by Primark together with Health Enables Returns 3 (HERHealth) and Business for Social Responsibility (BSR) in China, India, Bangladesh and Myanmar aims to educate female garment workers on their health needs and support them in learning. To date over 800 female workers have been coached and they in turn have taught more than 20,000 women.

Another programme that Primark has had in place since 2009, focuses on enriching the lives of its workers, and sees the value retailer working together with Social Awareness and Voluntary Education ⁴ (SAVE) to educate its workers in Southern India. The programme helps raise awareness on a wide range of topics, such as the importance of children's education, financial planning, general health and workers rights through the formation of worker education groups. In total 6,279 workers in 436 groups have been trained through the programme since 2009, which has impacted the lives of approximately 30,000 garment workers.

This short film shows how Primark's programme in Bangladesh has help provide essential health, hygiene and nutritional education for garment workers.

But how sustainable is Primark's sourced cotton?

However, although Primark has heavily invested in improving the livelihoods of these female cotton farmers, some wonder what other initiatives Primark has taken to ensure the rest of the cotton it uses is as ethical and sustainably sourced. For example, Primark previously sold organic cotton products in the past, but no longer does so. The value retailer claims it aims on selling organic and Fairtrade cotton products in the future, but that it depends on market demand - thereby leaving it up to their customers to ask for it. Unlike cotton from Primark's sustainable cotton programme, organic cotton is grown without the use of chemical pesticides and fertilisers which reduces the potential negative impact of cotton production on the local environment.

In addition, the fashion retailer received the worst score on the Ethical Consumer ⁵ rating, an independent public consumer rating, for its cotton supply chain. Primark previously signed the Responsible Sourcing Network's Cotton Pledge ⁶, and in doing so committed to not knowingly source any cotton from Uzbekistan ⁷ - one of the world's largest exporters of cotton - for the manufacturing of its products. However, the Government of Uzbekistan forces more than a million people ⁸ to work in the cotton fields each harvesting season and numerous reports highlight cases of human rights violations and forced child labour are "rife"in Uzbek cotton production. Although Primark has pledged not to knowingly source cotton from Uzbekistan, it does not seem to have any secure policy in place to guarantee it is not sourcing cotton from there, raising concerns about traceability and transparency within Primark's supply chain once more.

The steps Primark is taking to improve garment workers wages

As a leading member of ETI, Primark's Code of Conduct is founded on the ETI Base Code which stresses that "wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmarks, whichever is higher. In any event, wages should always be enough to meet basic needs and to provide some discretionary income." Primark states it requires all its suppliers to adhere to this definition for all workers within its supply chain. For the value retailer, a living wage is seen as one which includes the total cost of living, healthcare, food, education and housing. Primark adds that it does acknowledge the inherent challenges in defining and calculating a living wage, but it believes that a "negotiated approach" remains the most practical and sustainable move and supports the development of all industrial strides taken to achieve this.

For example, Primark is a founding member of Action, Collaboration, Transformation (ACT) ⁹, an initiative consisting of other retailers, manufacturers and trade union IndustriALL which aims to improve wages by establishing an industry collective bargaining power in key sourcing countries such as Cambodia and Bangladesh. ACT aims to uphold world class manufacturing standards as well as responsible purchasing practices. Primark stresses that its programmes aim to help its workers have better livelihoods. At the moment Primark is developing a holistic strategy aimed at improving wages, which includes country-specific approaches. The strategy aims to build on its current pilot programmes while building on key areas of focus, such as factory improvements, worker empowerment and benchmarking supplier performance. Another key initiative to help its workers manage their finances sees Primark partnered with banking service Geosansar ¹⁰ in India.

Acting as an agent and intermediary between banks and customers, Geosansar and Primark have aided workers in opening a bank account for the first time. In order to ensure garment workers can have easy access to their bank accounts, Geosansar bank kiosks are located close to factories and worker communities. The partnership, which sees Primark and Geosansar also provide financial education, as well as access to banking, has helped over 400 workers.

This short film shows how Primark's partnership with Geosansar helps garment workers open a bank account for the first time, while offering financial education as well as easy access to banking.

But is Primark doing enough to boost wages for garment workers?

While Primark's work does show that the retailer is committed to improving wages for its garment workers, the value retailer seems to be stuck at the strategy level and research stage and has yet to begin developing long term building blocks to paying livable wages. For example, Cambodia was the first country in which the ACT initiative began its first process to develop an industry-wide collective bargaining for higher wages. In September 2015, an ACT delegation, which consisted of IndustriALL and leading representatives from Primark, H&M and Inditex travelled to Cambodia to meet with suppliers, garment unions, the Labour Ministry and the Ministry of Commerce and the garment manufacturers association of Cambodia. However, since then there have been no further updates or concrete outcomes on record of what exactly has been done to date. "Work is in the early stages," notes Stewart, so it has yet to be seen what, if any achievable impact, the initiative has on the wages of garment workers.

So while Primark's work does show that the retailer is committed to improving wages for its garment workers, the retailer seems stuck at the strategy level and research stage and has yet to begin developing long term building blocks to paying livable wages. "Brands should take wages out of the competition and start working together on payment of a living wage," stresses Tara Scally, Dutch Campaign Coordinator Clean Clothes Campaign ¹¹. "Fair Wear Foundation ¹² has done interesting research revealing the possibilities. Brands could also work together on other labour rights issues, such as supporting labour unions, setting up worker committees, setting realistic workloads and working hours...Primark should be more transparent in their sustainability efforts. Publicly showing their wage calculations would be a good start."

Other NGOs agree that the key to implementing fair, livable wages within the industry's supply chain lies within collaboration. "One brand cannot single handedly reduce overtime or raise wages for the workers who make their clothes," says Lotte Schuurman, Communications Officer at the Fair Wear Foundation. "Brands can work very hard on improving their purchasing practices - on forecasting, on production planning - all of which can reduce their risk of causing overtime - but if they are a small player and other brands have poor management practices, the results on the factory floor can still be disappointing. That's why collaborative action is so important. Where possible we encourage our members -and all other garment brands- to increase leverage. Hence whenever we see that there are more member companies sourcing from the same factories, we encourage them to exchange information on audits, remediate together and cooperate on further improvement plans."

What Primark is doing to produce clothing with the least amount of harm to the environment

Outside of its sustainable cotton programme, Primark has been working hard on what good guidance looks like and is searching for ways to decrease its overall water usage, chemical usage, waste production to help protect the environment. As part of one ABF's five pillars of corporate responsibility - looking after the environment - manufacturing its products with as little harm as possible to the environment remains one of the Primark's key sustainability goals.

"Primark is committed to reducing the impact of our operations on the environment and has implemented a number of sustainability initiatives across the business, including environmental health and safety audits, energy audits, central building management system to optimize energy consumption, LED lighting, extensive employee training, extended producer responsibility measures and waste recycling programmes," explains Katharine Stewart, Primark's Director of Ethical Trade & Environmental Sustainability. For example, Primark has a team of specialist auditors who conduct audits in all of its stores across 11 countries. The team works together to make sure each location is fully compliant with the regulatory requirements and that the value retailer continues to meet accepted good practices within the retail industry. The audits include onsite waste management practices, review of store emissions and ensuring all equipment is properly maintained.

Primark also conducts energy audits in all its stores and reviews how much energy each store consumes. The value retailer was even awarded the Carbon Trust Energy Standard ¹ in recognition of its continued commitment to energy efficiency in its stores in 2014. Thanks to its energy-efficiency projects, Primark's store energy intensity, which is measured by kilowatt-hour (kWh) per square foot, has been reduced by 11 percent since 2015. Primark has saved approximately 30 million kWh of energy through its bespoke software system called ERICC (Energy Reduction Information and Control Console). The ERICC system offers real-time information on the primary energy drivers within any store and indicates how a store should be performing from an energy management point of view. "All Primark staff complete online training as part of their induction on Environmental Health and Safety," adds Stewart. "This includes guidance on onsite environmental health and safety issues, as well as waste and energy management."

In addition Primark has also achieved the Carbon Trust Standard for Waste for its waste management systems in store and is working to assume direct control over as much of its recyclable materials used during packing and transport as possible. For example, Primark established a resource recovery unit in its German depot centre in July 2015, where cardboard, plastic and hangers are collected from its Northern European stores to be reprocessed and sent for recycling. The value retailer has had a similar system in place in the UK for a number of years now, which ensures all recyclables are collected from its stores via its delivery trucks and transported back to the central distribution centre. As Primark has become more actively involved in the recycling process of its materials, it has been able to significantly reduce the volume and frequency of waste collections at each store and aims to expand this system to additional regions. "Last financial year, 94 percent of waste generated by all of Primark's stores and warehouses was recycled or beneficially reused," points out Stewart.

But what about Primark's Greenhouse Gas Emissions?

Although its high energy is often cited as another reason as to why the fashion industry is seen as one of the most polluting in the world, there is another factor which contributes to this picture. The purchase and use of clothing is said to contribute approximately 3 percent of the global production of C02 emissions, over 850 million tonnes a year according to the Carbon Trust. And Primark's fast-fashion system makes it one of the larger contributors to the problem. The value retailer has been working hard to ensure its energy usage is as low as possible and reduce its store and warehouse waste, but it has yet to fully tackle its greenhouse gas emissions (GHG), one of the biggest contributors to climate change.

According to Associated British Foods Corporate Responsibility Report for 2016 ², Primark's GHG emissions have increased by 15 percent over the last three years. Primark's GHG emissions grew 3 percent alone last year, as the value retailer attributes this growth to its expanding network of stores across Europe and the United States, leading to more transport movements of its products. At the moment 57 percent of all Primark's GHG emissions result from the transporting of its goods and as Primark continues to grow, this percentage is only likely to increase. Primark notes it is constantly reviewing its routes, type of vehicles used and shared services to ensure it minimise miles and the resultant emissions as the company expands. But the value fashion retailer has yet to explore alternative solutions or set itself fixed goals in reducing its greenhouse gas emissions.

Although Primark has been transparent with its energy efficiency and waste management, it is clear the value retailer still has some ways to go to ensuring both its supply chain and vast store network become more sustainable. "Sustainability is a complex issue," stresses Jacinta FitzGerald, Head of Research at Project JUST ³. "It involves looking at a product's full set of inputs, including raw material, water, energy and chemical use, along with the social inputs, manufacturing, consumer use and end-of-life. Taking into consideration fast-fashion's current business model, which is focused on high volume, low price and disposable products, this cannot by definition nor intention, go hand in hand with sustainability," she adds. "In order for Primark, or any fast fashion brand, to improve their practices to be more sustainable, we believe they need to address the full scope of these inputs. We would suggest the brand show leadership by setting goals to reduce greenhouse gas emissions for its manufacturing supply chain, and start to introduce the use of renewable energy, along with increasing its use of sustainable fibres, increasing transparency of its supply chain and working to increase the percentage of its First Tier suppliers that comply with its Code of Conduct."

Primark's stance on recycling textiles and sustainable fibres

In order to increase its usage of sustainable fibres and materials outside of its cotton programme, Primark has signed up to the UK's Sustainable Clothing Action Plan (SCAP) ⁴ led by WRAP ⁵, and the European Clothing Action Plan (ECAP) ⁶. "ECAP is still in formation really," says Stewart. "But we have been working with the UK equivalent, SCAP for a while now. I think ECAP will be a European wide evolution of that." Primark's partnership with SCAP has been looking at how the value retailer manages its waste and the materials it uses in its products, as well as the environmental impact of those resources. "One of the things that I hope for with ECAP is the development of the consumer facing side, as I think that is important. For example, SCAP have developed a logo and label called "Love Your Clothes", which supports a positive communication with consumers about recycling your clothes and looking after them. I hope that ECAP will take heed and look at how they can implement that on a European-wide basis."

Launched in 2014, the 'Love Your Clothes campaign' has been developed together with industry organisations to help change the way the UK consumers buy, use and dispose of their clothing. Their ultimate aim is to reduce the environmental impact of clothing across the UK and influence a more circular approach to clothing globally.

In addition to working with SCAP and ECAP, Primark has been running a clothing recycling pilot for the past few months in selected stores in Germany and the UK together with I:CO ⁷. The pilot was well received by Primark's shoppers in the test stores, and at the moment Primark is currently working out all the legal requirements to roll out the initiative to all its stores in all its markets. "We probably do not realise the full potential of the recycling programme yet, as we have not been advertising it," says Stewart. "But we have been very pleased with the trial and our decision to roll it out." Stewart notes that they may have to adopt a slightly different model in the US due to legal reasons, but they aim to have a similar system in place overseas. Primark is not the first fashion high street retailer to initiate an in-store recycling scheme with I:CO, but one key difference between the Primark clothing recycling pilot and other fashion retailers textile recycling programmes is the customer incentive. Rather than giving customers a discount voucher for their next purchase in-store, Primark gave customers an organic cotton bag in return for a clothing donation. "[Giving a voucher] just seems a little counter-intuitive in my opinion."

This short film shows how I:CO works with retailers to initiate clothing recycling drives in store, and encourages consumers to be more mindful with their unwanted textiles.

Primark's partnership with I:CO is a good example of how collaboration can bring around positive change in terms of sustainability. However, in order to reach its goal of creating clothing with the least amount of harm done to the environment, the value retailer should be looking into additional avenues to increase its use of sustainable resources, as well as its use of recycled materials. At the moment it remains unclear what percentage of Primark's apparel collections consist of recycled materials, or if they use recycled fibres in their clothing at all, an area which they should consider moving into according to international organisations. "We would suggest Primark increase its use of sustainable fibres, including developing further sustainable cotton programmes and using recycled fibres, along with tencel and modal instead of the less sustainable viscose fibre," says FitzGerald. "We would suggest Primark share the long term intentions of its recycling program, the anticipated impact of diverting these textiles from the waste stream and the current and future destination of the textiles collected from these programs."

Next to its textile and garment recycling initiative, Primark has been working with two organisations to efficiently manage its textile waste while helping those in need. "The one in the UK, which covers all our European stores, is Newlife ⁸, a foundation which supports children who are either terminally ill or very physical disabled," explains Stewart. "All the stock we have in store which we can't sell, all our buying office samples and excess stock, is donated to Newlife." Primark first started working with Newlife in 2010, and since then has managed to generate more than 2 million pounds in donations, which has been used to purchase equipment such as wheelchairs, nurse services and fund medical research. "In the States we set up a similar model with an organisation called KIDS Fashion Delivers ⁹." All of Primark's stores in the US have been donating their excess stock to the non-profit organisation since 2015, which goes to those in need in 50 states throughout America. In addition Primark's European stores donated a total of 100,000 cartons apparel goods to the European Red Cross Refugee Appeal ¹⁰ in 2015 to help refugees and migrants.

Is Primark doing enough in terms of sustainability with its excess stock?

Primark's charity efforts show the value fashion retailer has its heart in the right place, but some worry that its garment recycling initiative is not enough to tackle the problems at hand, as there are alternative ways to handle excess stock. "Primark could explore the concept of demand planning, having systems in place to understand and gauge the demand of a particular item, and then only produce to meet that demand, rather than over producing and creating surplus stock," points out FitzGerald. "We know that this is possible, as other brands work this way. Making items in lower quantities so that they sell out and making them more exclusive, will reduce the need for Primark to explore donating its unwanted items." Another issue concerning Primark's apparel donations revolves around the quality of its garments. Some NGOs and charities have even raised concerns with donating second hand or even unworn clothing from Primark due to their poor quality - a trait which is often associated garments made quickly out of synthetic fibres and polyester/cotton blends.

The value retailer disagrees with this opinion, as Stewart says Primark has invested a lot in improving the quality of its garments over the last few years. However, the opposing views on the quality of Primark's clothing does not change the fact that a large percentage of its clothing - as well as that produced by other fast-fashion retailers - ends up going to waste once it is discarded by consumers. According to WRAP, approximately 140 million pounds worth of used clothing is sent to landfills in the UK each year - accounting for 30 percent of consumers unwanted clothing. "It is a shame that so much hard work of workers worldwide ends up as waste," Tara Scally, Dutch Campaign Coordinator for Clean Clothes Campaign (CCC) ¹¹. "This does not do justice to the hard working garment workers, but into the production of the clothing. Many workers take pride in the work they do and the clothing they make and do not deserve to be exploited as they are now. Brands should plan accordingly so no garments go to waste."

What Primark is doing to cut down its use of chemicals

Outside of energy, waste and water management, Primark has also begun to look further down the supply chain on how it can help fabric mills decrease their chemical usage. This way the value retailer can manage its chemical usage before the material even arrives at garment factories. Part of Primark's chemical management requirements includes two restricted substance lists ¹² - Product Restricted Substance List (PRSL) and a Manufacturing Restricted Substance List (MRSL), which detail the limits for chemicals usage in the materials used to make its products, including dyeing and washing. In 2014 Primark signed up to Greenpeace's Global Detox Campaign ¹³ and committed to phase out the use of certain harmful chemicals by 2020. In 2015 the value fashion retailer was recognised as a Detox leader by Greenpeace and joined the Sustainable Apparel Coalition (SAC) ¹⁴, committing to use SAC's sustainability tool, the Higg Index, to help drive sustainable improvements across its supply chain. Apart from joining SAC and the Greenpeace Detox Campaign, Primark also joined the initiative Zero Discharge of Hazardous Chemicals (ZDHC) ¹⁵ together with 22 global apparel retailers. Together the group has created a list of restricted manufacturing substances, developed audit protocol tools and waste-water quality guidance and are in the process of creating a common training tool on chemical management. By encouraging mills to use less chemicals in the dyeing or processing of the fabrics, Primark is driving sustainable change further down the supply chain to lead to sectoral change.

Primark also supports the Partnership for Cleaner Textile industry (PaCT) ¹⁶, a holistic programme which supports the Bangladesh wet textile processing factories in adopting cleaner production methods. Twelve factories have already benefited from the programme to date, and an additional seven are currently benefitting from the PaCT training through Primark's nominations. The training focuses on denim and jersey production, paying attention to the environmental impact of the main technologies used during the dyeing and washing processes. "We actively engage with our suppliers, chemical experts, other retailers and organisations to help bring about sustainable change," states Primark in its Corporate Responsibility Report 2016. "We provide suppliers and their factories with formal training, tools and support to enable improvements to be made throughout the manufacturing process."

However, in spite of the numerous initiatives Primark has undertaken to combat its chemical usage, the value retailer may not be able to reach its Detox commitment to Greenpeace by 2020. "Please note, Greenpeace no longer recognized Primark as a Detox Leader," says FitzGerald. "The most recent report released in July 2016, ranks Primark in 'Evolution Mode', with Greenpeace stating that although the brand performs well on the elimination of perfluorinated chemicals (PFCs) and transparency, it fails to take individual responsibility for the main tools it needs to meet its Detox 2020 plan." The report notes that Primark chooses to rely on the ZDHC's "flawed methodology", which means the retailer is not selecting new target chemicals for eradication, or ensuring when it does test for their elimination, it is as close to possible to 'zero.' Greenpeace encourages Primark to adopt a "clean factory" approach, which sees chemical elimination targets applied to suppliers entire factory floor and not just to Primark's own production lines.

Primark's stance on a Circular Economy

"Additionally, other fast fashion brands are researching circularity, where used garments can be returned to the brand, the garment broken down (either mechanically or chemically) and respun into new yarn, then made into a new garment," adds FitzGerald. "Circularity addresses the problem of increased consumption and disposal of limited resources. This technology is still in development for the process to work at scale, but there is exciting potential here for a large reduction in garments being sent to landfill, and the decreased use of virgin raw materials." She encourages Primark to start looking into future options for implementing a circular economy, similar to the goal set by rival fast-fashion retailer H&M.

When asked on Primark's current opinion on adopting a circular business model, Stewart acknowledges that it is an area the value retailer is exploring, but is not ready to take on as a future goal. "We are looking at it. The thing about Primark is that we communicate the things that we have done - rather than the things we want to do," explains Stewart. "It's a bit brutal, considering we do have a lot of future goals, but that's how it is. If you think about the cotton project for example, we only started communicating that last year, when we have been working on it for three years. We want to be able talk about the things we have done and show what results we have achieved. I think it is a bit hard to talk about things you might do in the future because the challenge is keeping up with the ever-changing world. Circular economy - we will talk about that when we have something we have done about it."

How Primark is improving its workers well-being and educational initiatives

Primark's focus on employee health and wellbeing extend well past its supply chain and into its stores. Ensuring its warehouse and store staff feel supported, well-trained and able to grow with its business into the future, remains another key focus for the value retailer. However Primark is also keen to educate its consumers as well as its employees, which is why it is in the process of renewing its website. Even though Primark does not have an online store, its global website ¹ gets a significant number of visitors each month. "Our website will really be the platform that we use as our major communications tools with customers," says Katharine Stewart, Primark's Director of Ethical Trade & Environmental Sustainability. The website also features information on career possibilities at Primark, as well as a number of programmes and initiatives the value retailer has launched aimed at improving safety behaviours, employee wellbeing and working conditions in store.

For example, Primark is working on improving its injury rate as part of its wider scheme to boost its safety performance, according to its Corporate Responsibility Report 2016. The value retailer states it is targeting efforts in certain countries where national safety standards differ from its own standards, but does not outline in detail which countries it is focusing on at the moment. However, Primark does ensure that all its workers undertake an online health and safety induction programme in their local language, at a time and pace which is suitable for them. The programme covers key issues workers should be aware of, such as health and safety responsibilities, hazard identification, and manual handling. In addition to the online course, Primark's safety platform also includes additional information on safety topics, like office safety and emergency procedures. Primark also runs its Retail Manager Development Programme (RMDP), a bespoke supervisor development programme in the UK and northern Europe and is in the process of rolling it out to its other countries.

But how responsible are Primark's in-store working conditions?

But this training programme does not seem to be adequate enough in preparing staff for the the mental and physical demands needed for working in one of the busiest high street fashion chains in Europe. For example, a recent online survey from FNV ², the Dutch Federation of Trade Unions, found that 75 percent of current and former Primark employees felt their workload was too high. The trade union previously opened an investigation into the working conditions at Primark in the Netherlands after store workers in Groningen filed numerous compliments concerning intimidation and heavy workloads. The survey, which was filled out by 1,186 employees across the Netherlands in February 2017, also saw 71 percent of respondents claim they faced difficulty when applying for holidays or days off. In addition, 66 percent of respondents also reported problems with calling in sick and 54 percent raised concerns with privacy. Employees argued that store managers used camera images to spy on them and played doctor by determining if they were too sick or not to work. "If you are momentarily in another place or talking to someone, then you are immediately asked/yelled on what you're doing," wrote one employee from Primark's Amsterdam location in the survey. "At times you are even threatened with a (written) warning."

Facts on Primark in the Netherlands

Primark opened it first store in Rotterdam, the Netherlands in 2008.

Primark currently counts 16 stores across the country, including its flagship store in Amsterdam.

Primark employs a total of approximately 4,800 workers in the Netherlands.

In addition, 81 percent of respondents said they felt that Primark was missing a workers council who could negotiate agreements on their behalf concerning use of store cameras in relation to their privacy - even though the council is required by law in the Netherlands for any company with more than 50 employees. "The results are truly shocking. Primark governs with hard hard," says Niels Suijker, union member at FNV in a statement. The value retailer said it was both "quite shocked and moved" by the results of FNV online survey and noted that it has been working for several months to launch its workers council. Since the survey's results were published ³ Primark has met with FNV and agreed to make a number of changes to improve working conditions for staff, including respecting employee privacy, improved procedures for holiday leave, and the establishment of a workers council. However, even though Primark responded quickly to the allegations and was eager to improve conditions, FNV is aware time will show if working conditions improve and has therefore scheduled a meeting in three months time.

However, store employees in the Netherlands who voiced these concerns are not only ones working at Primark who feel this way. Over in the UK and in the US, Primark sales assistants have also shared concerns feeling overworked and underpaid, having to deal with overbearing management teams, as well as difficulty in taking time off, on job boards Indeed and Glassdoor. These complaints from the UK have come even after Primark implemented the "national living wage" ⁴, which aims to ensure its workers are paid enough to live off of. In France, employees also complained of difficult working conditions in Primark, with complaints ranging from unpaid sick leave, to constant monitoring, to unexplainable gaps between sales assistants' wages ⁵. Over in Spain, in Madrid one Primark retail worker claimed he was making the same amount of money working 30 hours a week at Primark in 2016, as he was working 12 hours a week at department store El Corte Inglés in 2007 ⁶. So even though Primark may have a number of initiatives in place aimed at improving employee wellbeing, it seems as if the effects of these programmes are not as beneficial or effective for all its workers - in particular its store employees.

Should Primark be more open with consumers concerning sustainability?

Another area of store development and training which Primark is keen on developing concerns communication. Over the past years the value fashion retailer has remained relatively quiet concerning its sustainable and ethical practices, which in turn has led to numerous consumers questioning how responsible the retailer really is. A common misconception, according to Primark, is that cheap clothing is made in worse conditions than more expensive clothing. So in order to overcome this misinterpretation Primark is in the process of rolling out an ethical trade and environmental sustainability training programme called 'Our Ethics' in its stores. "The training programme covers all of the company's ethical policies, including ethical sourcing, the code of conduct, environmental sustainability and social responsibility," explains Stewart. "The aim is to educate our in-store employees on the work we do on Primark's Ethical Trade programme as a whole."

Primark is also updating its website to offer consumers more information on its ethical and sustainable activities. "We will be putting a lot more information concerning our ethics on there come May," continues Stewart. "We are starting to share more films - our cotton film is a good example of that - but we are trying to make it more engaging and interesting for customers based on the feedback we get and offer as much information as possible." This is why Primark is developing the communication around everything in terms of ethical and sustainable programmes, to make sure it is as informative and visual as possible for its readers. NGOs applaud the move from Primark and agree the retailer should explore further avenues on how it can share more information on its sustainable and ethical programmes. "We suggest Primark share more data with its shoppers concerning the workers that make its clothing, and show how the brand is working to ensure they are treated ethically, so shoppers can see first hand the stories behind their clothes," says Jacinta FitzGerald, Head of Research at Project JUST ⁷. "We also believe Primark could do more to educate its shoppers on how to care for their clothes and encourage them to look after them and keep them for longer."

At the moment Primark does have a few initiatives in place aimed at educating consumers on how to care better for their clothes, such as their partnership with SCAP ⁸. But in order to properly tackle many consumers perception and predisposed disposition against Primark and its products, the value fashion retailer may have to dig a little deeper. Primark does agree that it could be sharing more information on its sustainable and ethical practices with the public, even if consumers are not always asking for it. "It's a bit like the chicken and egg conundrum isn't it?," says Stewart on sharing more on their corporate responsibility practices. "I think that the information has to be there for the consumer to make an educated choice. But if it isn't available, then consumers should also be proactively asking why not, and what retailers are doing on certain subjects. We do get many queries concerning our sustainable practices and we do answer those as best we can." Primark even has a FAQs section on its website under its 'Ethics' section which answers it's most commonly asked questions.

Does Primark's Low Prices equal Low Quality and Disposable Fashion?

Unsurprisingly Primark's low prices are one of the main things which gain the value retailer the most attention - both good and bad. While it's affordable and accessible price point is undoubtedly one of retailer's driving factors, it is also one of the main reasons why the brand is often thought of as unsustainable and unethical. Primark's prices are so low, that they pushed Belgian MEP to the European Parliament Marc Tarabella to request the European Commission to investigate the brands working conditions and pricing scale. "The Irish giant Primark is known for its ultra-low prices, but also for the working conditions at its suppliers' factories. Many people wonder about their prices, which are up to five times lower than those of the competition. Primark has always responded by saying that it is it's competitors who are charging inflated prices," ⁹ wrote Tarabella in his request in 2015, which was ultimately dismissed by the EU Parliament. Consumers still ask how t-shirt which retails for 2 pounds can be made in a fair and honest way. Some argue that it is precisely because Primark's clothing is so cheaply made and in such excess that is has contributed to the idea that fast-fashion disposable, something to throw away after a few wears.

Unfortunately cheaper prices are also more likely to trigger consumers into making an impulse purchase in store. And thanks to Primark's low prices shoppers can easily fill a recycled paper bag full of garments for 50 pounds or less. But this also means consumers are more tempted to buy something without trying it and will be less inclined to return an ill-fitting garment, as it could cost them more in travel costs going back to the store than the actual garment itself. "It is hard to resist the allure of a good bargain, but fast fashion means we're consuming and trashing fashion at a higher rate than our planet can handle," warns Kirsten Brodde, head of Greenpeace's Detox My Fashion campaign ¹¹ in a statement.

What is Primark doing to offer affordable fashion at an amazing price?

So what is Primark doing to reassure its consumers that its products should be cherished and that people should not buy more than they need? On its website, the value retailer has a dedicated area under its 'Ethics' page which explains how they are able to offer the lowest prices on the high street. For example Primark claims to not spend any money advertising and orders its products in large volumes well in advance, so they can keep their overhead costs as low as possible. Primark's margins are also said to half a high as those of its fast-fashion competitors. Primark also ensures its suppliers use a streamlined production process to make its clothing in the most effective way possible. Combined, these tactics are said to ensure Primark remains accessible and affordable to all shoppers, while offer good value for money - a goal the company has always kept in sight, according to Primark's Director of Ethical Trade & Environmental Sustainability. "Unlike other clothes shops, people often come to Primark because they know they'll be able to afford a whole outfit. This means we get the savings from buying in bulk," explains Stewart.

"As long as we stimulate seeing clothing as a disposable product instead of an investment, the race to the bottom will continue"
Tara Scally, Dutch Campaign Coordinator for Clean Clothes Campaign ¹²

Stewart adds Primark has also been investing in creating better quality clothing to help combat the stigma that its offers throw-away clothing and ensure their products last longer. "I know people will often say that the quality isn't very good at Primark, but we have invested a lot in quality over the last few years," says Stewart. "Right from the start, when the buyers are developing the product, we ensure we have the quality team looking at the design of product. Then when the product goes into the production side, we have quality checks during the product's manufacturing as well, which has made a real difference as we are noticing a positive response from customers. We are building things to last." She claims she has had a suedette jacket she is wearing from Primark for years, and that her co-workers have even begun to joke about how often she wears it. "I don't care really, I love this jacket."

Nevertheless, Primark cannot argue with the fact that many consumers do shop excessively at Primark and are more likely to make an unnecessary, or unneeded purchase if the price is low enough. The rise of 'haul' style shopping videos on YouTube is just one example of how the value retailer's pricing is affecting the way people shop and how they view their products. A quick Google search shows exactly how fast Primark haul videos are growing in popularity - with 3.63 million results showing up for 'Primark haul 2017' versus 2.95 million hits for 'Primark haul 2016.' Many of these videos attract millions of views - for instance YouTube favourite Zoella's latest 'Primark Haul', entitled 'The Biggest Primark Haul I've Ever Done', was uploaded on March 21, 2017 and already counts over 2.6 millions views. The 20-minute video features numerous items from Primark's Spring/Summer 2017 collection including boyfriend style jeans, striped cropped tops and lacy triangle bras - all in several colours and sizes. In the video Zoella shows off each item one by one to her viewers: young, impressionable women who all want to look and dress just like her - which leads to many of them also shopping in bulk at Primark.

This is Primark's first 360 degree video. It is a virtual tour. When watching the video via a desktop computer, or laptop, please use your mouse to virtually 'look' around the space. When watching the video via a smartphone, the direction of the video will shift depending on the position of the phone - in order to view the full 360 degrees in the video, please physically rotate your smartphone around.

Can Primark really offer responsible fashion at an amazing price?

Some may think the Rana Plaza factory collapse 2013 was a turning point for the fashion industry - a wake up call for the retailers producing their garments there to band together to make a change for good. However for others, like Primark, it was a call to take a closer look at its supply chain and operations to see where it could make even a larger impact through its sustainable and ethical initiatives. For years Primark has been fighting against the stigma that cheap fashion is not sustainable or ethical, even though the value fashion retailer shares 98 percent of its suppliers and factories with other high street retailers, such as H&M, Zara and Mango.

For example Primark has partnered with numerous NGOs, such as Solidaridad, CottonConnect and Made-By, as well as organisations like The Ethical Trading Initiative (ETI) ¹ and together has instigated many initiatives aimed at improving the livelihoods, health and safety of its workers. In addition Primark has joined a number of partnerships to ensure its products are made as sustainably and responsibly as possible, with as little harm to the environment. The value retailer believes that collaboration is one of the keys to improving environmental standards and working conditions across the industry in main manufacturing hubs. "What certainly has helped over the last two years is there has been more of an appetite to collaborate," says Katharine Stewart, Primark's Director of Ethical Trade & Environmental Sustainability. "There were a number of brands before who did not want to collaborate. But now, we are all sharing factories and therefore human rights has to be a prerequisite for us, as it should be for all."

Publishing more information on its website, training its members of staff and creating behind the scenes videos of the factories it works with, are just a handful of avenues Primark has taken on share what it does in terms of sustainability and social responsibility. And the value retailer's efforts have not gone completely unnoticed within the industry. "It is commendable that fast fashion companies are reacting to the challenges we face and creating positive intervention towards socially mindful solutions. In the case of Primark, and others, I dare say, it's about time," says Orsola de Castro, Founder and Creative Director at Fashion Revolution ² and Esthetica. However, although fast-fashion retailers like Primark have been working hard to improve working conditions and dramatically decrease their impact on the environment, in reality they have been unable to match their sales gains with corresponding improvements in terms of the social and environmental aspects.

At the end of the day, the fashion industry remains one of the most polluting sectors in the world. The social, sustainable and ethical impacts of the industry - both good and bad - continue to grow as the number of garments produced does. Since the global emergence of fast-fashion retailers like Primark back in 2000, the number of garments produced annually has doubled, exceeding 100 billion garments in 2014 - which is equal to nearly 14 items of clothing for every person on earth according to data from McKinsey & Company ³. With limited resources for apparel production, there is only so much retailers like Primark can due to limit the negative impacts of its current business model. The value fashion retailer's parent company, Associated British Foods, acknowledges it faces pressure to set itself fixed goals in terms of responsible and sustainable production, but stresses transparency is key to making a real difference.

Acknowledgements from Vivian Hendriksz, Author & Senior UK Editor at FashionUnited:
The premises for this in-depth case study came around after an interview with Katharine Stewart, Primark's Director of Ethical Trade & Environmental Sustainability, when it became clear to me that this was an area which touched on a number of relevant issues within the fashion industry. I believe that incorporating sustainability as driving factor within the global fashion industry is vital to ensure its future survival, but unfortunately it seems to remain an effusively difficult area for many retailers, designers and brands to grasp. For many companies within the industry producing responsible fashion is becoming more and more important, but it is still not their majority number one priority. This long-read article aims to touch on all the points mentioned above and encourage industry insiders to rethink their views on social responsibility in general, as well as their opinions on Primark.

Following my interview with Stewart, I reached out to numerous organizations to learn more about their thoughts on Primark's current stance concerning their sustainable and ethical initiatives and would like to thank the Clean Clothing Campaign and their Dutch brand 'De Schone Kleren Campagne', Project Just, the Fair Wear Foundation, Fashion Revolution and Greenpeace for their help and contributions to the piece. I would also like to thank Primark for sharing more information on their sustainable and ethical initiatives, in particular Katharine Stewart.

Photo: Leipzig - Germany. Credit: Primark.

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Case study on Primark sustainability, ethics, supply chain.

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Primark, the Irish fashion retailer owned by Associated British Foods (ABF), is seen as one biggest fashion retail success stories of the past decade. Best known for its low price and high value offering, "Amazing fashion, amazing prices", the high street staple has extended its reach across Europe and overseas into the United States.

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The fashion industry needs to rethink the future of fashion. Clothes are and will continue to be an everyday necessity, but the fashion industry is today too dependent on virgin and non-renewable resources. H&M group is therefore pushing the development towards a shift to a circular model; where materials are maximised and waste is minimised. The company is also working towards its ambition to ensure that everyone in its supply chain has access to a fair job. This includes everything from supporting a well-functioning relationship between workers and management to the safety and wellbeing of factory workers, as well as fair living wages. Another important part of H&M group's sustainability strategy is to identify, invest in and promote sustainable innovations necessary for transforming the fashion industry.

Change is happening through innovations
"Innovation is key to solve many of the challenges the fashion industry is facing. Especially when it comes to accelerating the shift from a linear to a circular model. But it will not be one technology, one innovation, that will do the trick; instead it will be several ideas, scientists and companies putting the puzzle together, pushing the development forward. That is why we invest in and partner with innovation companies such as re:newcell and Treetotextile", says Cecilia Brännsten, Acting Environmental Sustainability Manager at H&M group.

Towards only recycled or other sustainably sourced materials
"Every year we take new steps towards our bold goal to only use recycled or other sustainably sourced materials by 2030. This significantly reduces the use of natural resources and the negative impact our business has on the climate. It's important to use already existing sustainable materials but also test completely new fabrics. When it comes to recycled materials, they are truly a win-win since they stop waste material going to landfill and at the same time reduce the use of virgin raw material", says Mattias Bodin, Sustainability Business Expert - Materials & Innovation at H&M group.

Tackling challenges together
"Collaboration is the best way to tackle the challenges connected to working conditions and wages within the textile industry. That is why we value the ground-breaking collaboration with 16 other global brands and trade unions within the ACT platform. Our joint goal is to establish mechanisms to support freedom of association and industry-wide collective bargaining", says Cecilia Tiblad Berntsson, Social Sustainability Manager at H&M group.
Highlights Sustainability Report 2017:

Recycled or other sustainably sourced materials made up 35% (26%) of H&M group's total material use. The goal is to only use this kind of material in 2030.

H&M group partnered with the innovation company re:newcell whose unique technology recycles used cotton, viscose and other cellulosic fibres into new textile fibres.

H&M group became one of the two core investors in the innovation company Treetotextile developing a new sustainable textile fibre based on forest raw materials.

59% (43%) of the cotton H&M group used came from sustainable sources. The goal is to only use this kind of cotton in 2020.

H&M group used recycled polyester equivalent to 100 million PET bottles.

Weekday debuted its first-ever sustainable swimwear collection made from recycled polyamide and recycled polyester.

H&M launched its first garments made from recycled shore-line waste; Bionic® within the annual H&M Conscious Exclusive Collection.

H&M group collected almost 18,000 tonnes of textiles through its garment collecting initiative. That is the equivalent of 89 million T-shirts. 61,000 tonnes of textiles have been collected since 2013.

96% of H&M group's electricity came from renewable sources. The goal is to become climate-positive across the entire value chain by 2040.

ARKET launched a new way for customers to filter products based on country of production and material type - increasing the level of customer transparency.

458 supplier factories and more than 620,000 workers were reached by H&M group's workplace dialogue programmes. This means one of the goals for 2018* was reached already in 2017.

As part of the 2018 goal, 100% of the garment manufacturer units in Bangladesh conducted democratic election of worker representatives. In total, 2,882 persons were elected and 40% of those were women.

227 supplier factories**, covering over 375,000 workers, implemented improved wage management systems. They help to create a dialogue between management and workers on wage-related issues and ensure that wages take skills, experience and responsibility into consideration.

To support the development of industry-wide collective bargaining agreements and purchasing practices supporting a fair living wage, H&M group, IndustriALL and other brands within the ACT platform signed an MoU.

In spring 2018, H&M will pilot the innovative concept Take Care, aimed at inspiring customers to prolong the lifespan of their garments through refreshing, remaking and repairing.

For more information see an with Anna Gedda, Head of Sustainability, about H&M group's sustainability work. Read the executive summary of the Sustainability Report or the full report.
*The H&M group's goal for 2018 is to set up democratically elected worker representatives committees and improved wage management systems at suppliers representing 50% of H&M group's product volume. **Representing 40% of the total product volume.

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H&M group makes strong progress towards its vision to lead the change towards a circular and renewable fashion industry, while being a fair and equal company. This is outlined in its Sustainability Report 2017, launched today. Take a look at some of the highlights below.