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SUPPLIER WORKPLACE ETHICAL AND ENVIRONMENTAL

ASSURANCE (SWEEA) POLICY STANDARD

Approved by: Group Executive

Approval date: 31 August 2016

Version: 2016 v1

Number of pages (exc. annexures)

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Document owner: Chief Customer Officer and Chief Offer and Supply Chain Officer

Document for the attention of: All employees and individuals acting for and on behalf of Kingfisher Group Business Units

Next review date: August 2017

Related Policy Document: - Ethical Sourcing Policy Statement - Supply Chain Workplace Standards - SWEEA Procedure documents

Policy circulation:

For internal management and external use (e.g. Kingfisher website, vendors).

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Table of Contents

1. INTRODUCTION 3

1.1. Summary and objectives 3

1.2. Definitions 3

1.3. Who should use this document 3

1.4. Main points of contact 4

2. STANDARD 5

2.1. Scope 5

2.2. Obligations 5

2.3. Consequences for non-conformance 7

3. APPENDIX 8 APPENDIX 1: EXTERNAL STANDARDS, LAWS AND REGULATION (referenced in this Group Standard) 8 APPENDIX 2: SUPPLIER GRADING AND CRITERIA 10 APPENDIX 3: OVERVIEW OF ETHICAL SOURCING PROCESS 11 APPENDIX 4: DEFINITIONS 12 APPENDIX 5: MAIN POINTS OF CONTACT 18

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1. Introduction 1.1. Summary and objectives

Kingfisher is committed to promoting the ethics, health and safety, human rights standards

and good environmental practices we set within our own business in our Supply Chain. Our

Ethical Sourcing Policy Statement sets out our aspirations and commitments on ethical

sourcing. This Supplier Workplace Ethical and Environmental Assurance (SWEEA) Policy

Standard provides details of how we will implement our Ethical Sourcing Policy Statement

and monitor compliance with our ethical and environmental requirements.

Note: This Standard has been informed by the Global Social Compliance Programme (GSCP)

Reference Code and GSCP Environmental Reference Requirements, widely recognised as

the international best practice standard for fair labour and minimum environmental workplace

conditions in the global supply chain developed by and for global buying companies.

The objectives of the SWEEA Standard are to:

Set out the processes and tools we will use to check that production sites in our supply chain meet our ethical and environmental requirements. This includes production sites for products, packaging and services sold or used within the business;

Set out the governance process we will follow if suppliers fail to meet our ethical and environmental requirements;

Outline the process we will follow to engage with suppliers to work towards continuous

improvement in workplace standards;

Provide the framework for meeting our published targets for all priority suppliers of Goods for Resale (GFR) and key Goods Not for Resale (GNFR) contracts to meet or exceed Kingfisher’s supply chain workplace standards by 2020;

Ensure that Kingfisher meets legal obligations on ethical sourcing in respect of the UK Modern Day Slavery Act 2015 (see Appendix 1).

Related policy documents:

This SWEEA Standard should be read in conjunction with the appendices, the Kingfisher

Supply Chain Workplace Standards and Kingfisher Ethical Sourcing Policy Statement.

Our Standard Operating Procedures on Ethical Sourcing provide further detail on the

processes and procedures on ethical sourcing.

1.2. Definitions Terms are defined in Appendix 4.

1.3. Who should use this document

a) Within the Kingfisher Group This document is applicable to all Kingfisher entities; specific roles and responsibilities are set out and assigned in our Standard Operating Procedures on Ethical Sourcing.

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b) Externally to Kingfisher

This document, or aspects contained within, may be made available to suppliers, contractors, service partners (i.e. auditing companies, Sedex, etc) and other relevant entities as deemed necessary or helpful by individuals who have specific roles and responsibilities under this Group Standard.

1.4. Main points of contact See Appendix 5

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2. Standard

2.1. Scope This policy applies to suppliers of Goods for Resale (GFR) and Goods Not for Resale

(GNFR).

2.2. Obligations

General We will use a universal tool (SEDEX1) to monitor the performance of suppliers – using the SMETA audit protocol, a universal and standardised methodology which defines ethical and environmental workplace standards and measurement criteria. Our vendors will be required to pay the SEDEX membership and associated audit fees2 as applicable to their operations. Audit process:

The key stages to the audit process include: o Supply chain mapping: We will require suppliers to create a supply chain map

on SEDEX, which includes linking to Kingfisher and identifying all sites producing goods for Kingfisher, including their own production sites and sites in their own supply chain (these are Kingfisher’s ‘indirect’ suppliers). As a minimum, we will require suppliers to identify all sites producing finished goods for Kingfisher. Further disclosure of sites in the extended supply chain (e.g. sites producing component parts) may be requested on a risk basis.

o Risk assessment: We will take a risk based approach to auditing and will identify high risk production sites using a desktop assessment which takes into account considerations such as geographical location and product sector. We will require a SEDEX self-assessment questionnaire to be completed for each site producing goods for Kingfisher (identified via the supply chain mapping). This will provide us with the basis for the risk rating covering inherent risks associated with the country and product sector and an overall risk (based on the questionnaire results).

o Ethical audit: We will require an ethical audit for production sites we consider to be high risk. These audits must be in accordance with our ethical audit criteria (see section ‘supplier auditing requirements’). The audits should be conducted before new contracts or new orders are placed as a minimum.

Outcome of audits:

Continuous improvement: We aim to engage with supplies to encourage continuous improvement and will grade all suppliers using the Kingfisher grading system (see Appendix 2 and section on ‘supplier grading and continuous improvement’).

Non-conformances: We will require suppliers to act on non-conformances by developing and completing Corrective Action Plans. In the event that Critical Failure Points (CFPs) have been identified, no new contracts or new orders will be placed until they have been fully remediated (see section on ‘consequences for non-conformance’).

1 SEDEX is the Supplier Ethical Data Exchange 2 The costs associated with joining SEDEX (www.sedexglobal.com) are £60 + VAT per site. A higher membership bracket is available but not stipulated by Kingfisher Plc.

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a) Supplier auditing requirements Audit criteria:

All audits must be conducted using a universal & standardised methodology –

SMETA (or by exception SMETA equivalent standards)3

Suppliers pay for audits

Audits must be no more than two years old.

SMETA is a 4 pillar auditing framework. Suppliers must select auditors to perform the audit

from the list of approved auditors as listed on the SEDEX website.

We use the SEDEX scoring system to identify non-conformances and critical failure points.

See section below and Appendix 2 for details of our supplier grading methodology and the

action we take in response to the audit results.

b) Supplier Grading and Continuous Improvement

The progress of suppliers and their production sites is reviewed on a regular basis. We review

the audit Corrective Action Plans (CAP) to ensure they have been completed and we also

monitor if the suppliers SEDEX account has been updated to reflect any improvements made

and re-audits conducted.

See Appendix 2 for further details of our supplier grading system. This shows the criteria we

use to allocate the grades and summarises the actions we take in response to the audit results.

In the event the sites’ grade is:

“Fair”, “Good” or “Excellent”: we support and encourage them in maintaining and building on existing good practices whilst addressing any areas of improvement.

”Need Improvement”, or “Unacceptable”: the production site is required to complete the agreed Corrective Action Plan with the ultimate aim being that the facility’s grade improves to at least “Fair”. The section on ‘consequences for non-conformance’ sets out how we respond to any Critical Failure Points (CFPs).

As well as auditing suppliers, we aim to work with suppliers to help them reduce their impact

on the environment and manage the challenges of sustainable business growth. We are

working to develop the programme and begin the process of engaging with our suppliers to

achieve our and their sustainability targets on issues including climate change, sustainable

home products, labour, health and safety, timber, packaging and chemicals.

3 SMETA is the SEDEX Members Ethical Trade Audits. In addition, whilst we transition to the new approach we will also accept equivalent standards including audits conducted by: BSCI – Business Social Compliance Initiative, SA8000 – Social Accountability 8000, FFC – Fair Factories Clearing House, FLA – Fair Labour Association, ICTI – International Council for Toy Industries.

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c) Governance Kingfisher Offer and Supply Chain is responsible for implementation of this policy for Goods

for Resale (GFR).

Kingfisher Goods-Not-For-Resale (GNFR) teams at Group and within Operating Companies

are responsible for implementation of this policy for GNFR.

See appendix 5 for the main points of contact.

d) Record keeping Kingfisher must maintain appropriate records associated with this Group Standard for a

minimum of 3 years.

e) Vendor communication

Our vendors will be informed of our SWEEA Policy requirements on an ongoing basis. For

both new and existing vendors, related questions and information will be asked/requested

during the Request for Information/Proposal/Quotation phases and in vendor contracts.

2.3. Consequences for non-conformance

The relevant sourcing functions must be alerted when an audit highlights a non-conformity

classed as a ‘Critical Failure Point’.

A Critical Failure Point represents the highest level of breach and requires immediate action

as set out in the ‘Governance’ section of this Group Standard and in detail in the SWEEA

Procedure document.

The sourcing functions will inform all relevant Kingfisher Group Business Units of any Critical

Failure Points relating to the local entities products.

A Critical Failure Point may be:

An issue which presents imminent risk to Workers’ safety/risk to life and limb or

constitutes a significant breach of Workers’ human rights, and/or;

Represents an imminent threat to the environment or community; or

A breach of local, national or international law or regulations; or

A Non‐Conformance that has not been addressed or for which no significant

improvement has been made by the time of a Follow up Audit, in spite of Supplier

commitment to resolve the issue.

An attempt to pervert the course of the Audit through fraud, coercion,

deception or interference.

The sourcing functions must immediately put on hold any orders placed with the supplier /

employment site until such a time as the:

Immediate risk or threat is removed; and/ or

Follow up improvements have been verified.

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3. APPENDIX

APPENDIX 1: EXTERNAL STANDARDS, LAWS AND REGULATION (referenced in this Group Standard)

Document Name

What this is Reference / link

SMETA auditing standard

Auditing standards and guidelines produced and published by Sedex

Publicly available on Sedex website

Devoir de Vigilance

French legislation to ensure French organisations that meet certain criteria ensure the health and safety of the workers throughout their supply chains

http://www.assemblee-nationale.fr/14/dossiers/devoir_vigilance_entreprises_donneuses_ordre.asp

UK Modern Slavery Act (2015)

UK legislation which creates two new civil orders to prevent modern slavery, establishes an Anti-Slavery Commissioner

Includes the Transparency in Supply Chains section and makes provision for the protection of modern slavery victims.

http://services.parliament.uk/bills/2014-15/modernslavery.html

Please also refer to: Transparency in Supply Chains – a practical guide for business

Please Note: The Modern Slavery Act 2015

The Modern Slavery Act 2015 is UK legislation which creates two new civil orders to prevent modern slavery, establishes an Anti-Slavery Commissioner and makes provision for the protection of modern slavery victims.

Section 54 of the Modern Slavery Act 2015 requires companies with a turnover of more than £36m to publish an annual slavery and human trafficking statement. The main contact people within the Kingfisher Companies are responsible for publishing a statement that describes the steps its business(es) have taken to ensure that slavery and human trafficking is not taking place in any of its supply chains or its own businesses, or they must disclose that they have taken no such steps.

Any organisation doing business in the UK with a turnover that exceeds £36m will be required to produce a slavery and human trafficking statement for each financial year of the organisation.

'Transparency in Supply Chains' in Part 6 of the Modern Slavery Act 2015 contains a list of other existing laws that define what 'slavery and human trafficking' currently means:

"Slavery and human trafficking" is conduct that constitutes any of the following:

The offences of slavery, servitude and forced or compulsory labour and human trafficking in sections 1, 2 or 4 of the Modern Slavery Act 2015.

The offences of slavery, servitude and forced or compulsory labour and human trafficking in sections 1, 2 or 4 of the Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015.

The traffic in prostitution offence under section 22 of the Criminal Justice (Scotland) Act 2003.

The trafficking for exploitation under section 4 of the Asylum and Immigration (Treatment of Claimants, etc.) Act 2004.

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The offences of slavery, servitude and forced or compulsory labour under section 47 of the Criminal Justice and Licensing (Scotland) Act 2010.

Conduct that would constitute an offence in a part of the UK under any of the above provisions if the conduct took place in that part of the UK.

Application to the Kingfisher Group:

1. B&Q and Screwfix do business in the UK and are therefore required to publish their own annual slavery and human trafficking statements.

2. Kingfisher’s annual slavery and human trafficking statement needs to include its subsidiaries that do business in the UK and if a foreign subsidiary is part of Kingfisher’s supply chain, then Kingfisher’s statement should seek to cover any actions taken in relation to that subsidiary to ensure that it is slavery free.

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APPENDIX 2: SUPPLIER GRADING AND CRITERIA

Kingfisher’s overall aim is to drive improvement in the supply chain with Suppliers and their

sites moving up the Kingfisher Supplier Grading scale (below). The table shows the criteria

we use to allocate the grades and summarise actions we take in response to the audit

results. The grades also help to support internal benchmarking.

Kingfisher

Grade

Equivalent

SEDEX

classification4

Criteria Kingfisher actions

1 - Excellent Good example There are no Non-

Conformance issues for at

least two consecutive

workplace audits.

Allow orders to continue – re-

audit required within 2 years.

2 - Good Observation There are no Minor Non-

Conformance issues in the

most recent audit.

Allow orders to continue – re-

audit required within 2 years.

3 - Fair Minor There are no Major Non-

Conformance issues in the

most recent audit.

Allow orders to continue – re-

audit required within 2 years.

Evidence required that

Corrective Action Plan (CAP) is

being closed out.

4 - Needs

Improvement

Major

(previously

classified as

‘major/minor’)

There are three or fewer

Major Non-Conformance

issues.

Allow orders to continue – re-

audit required within 2

years. Evidence required that

Corrective Action Plan (CAP) is

being closed out.

5 –

Unsatisfactory

Critical

(previously

classified as

‘major’)

There are three or fewer

Critical Non-Conformance

issues. Also applies if there

are four or more Major Non-

Conformance issues.

Allow orders to continue – re-

audit required within 1 year to

confirm progress made on non-

conformances. Evidence

required that Corrective Action

Plan (CAP) is being closed out.

CFP -

Unacceptable

Business Critical

(previously

classified as

‘critical’)

Business Critical = Critical

Failure Points (CFPs) have

been identified. Also applies

if there are four or more

Critical Non-Conformance

issues.

New suppliers: Blocks orders

until re-audit conducted and

CFP’s resolved.

Existing suppliers: Window of

time given in which vendor to

meet requirements (as per

CAP), after which orders

blocked until resolved.

Note: the timescale for closing out non-conformances is determined by the auditor and is stated in the corrective action plan of the audit report. Auditors give between 30 to 60 days on average for an issue to be closed out, but the exact timescales depend on the severity and nature of the non-conformance issue.

4 This is the updated SEDEX classification in 2016; the previous SEDEX classification is show in brackets.

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APPENDIX 3: OVERVIEW OF ETHICAL SOURCING PROCESS

*As a minimum, we will require suppliers to identify all sites producing finished goods for Kingfisher. ** Route c – this is only an option for sourcing locations that are producing component parts for Kingfisher products. Other sourcing locations producing finished goods must follow routes a and b. We review the risk for sites reported via the small supplier function and may require the site to join SEDEX on a risk basis.

Supply chain

mapping

Risk assessment

Audit

Suppliers join SEDEX & link to Kingfisher

Suppliers create a supply chain map on Sedex They identify their own sites & sites in their own supply chain (‘sourcing locations’) which produce products for Kingfisher*

Each site completes the SEDEX Self-Assessment Questionnaire (SAQ)

b) Supplier sourcing locations – option 1: each sourcing location joins SEDEX, links to Kingfisher as a supplier & moves to next stage – SAQ)

a) Supplier own

sites:

move to next stage – SAQ (see below)

c) Supplier sourcing locations - option 2**: the supplier enters key details for their sourcing locations using the ‘small supplier’ function.

Kingfisher reviews information & determines the level of risk

High risk sites

Low risk sites

Ethical audit required

Site approved Reassessment scheduled

Kingfisher allocates grade & reviews Corrective Action Plan if required

CFPs closed out

No CFPs

Site not approved

CFPs not closed out

Kingfisher reviews key details for sourcing locations. Taking a risk approach, we may require sites to join Sedex, link to Kingfisher & move to the next stage (SAQ)

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APPENDIX 4: DEFINITIONS

Unless the context otherwise requires, words in the singular include the plural and in the plural include the singular.

Agent / Importer

Intermediaries directly contracted by a Group Company to source,

import and supply products for sale or use but do not actually

produce the products themselves.

Agency Worker Workers that are employed by an employment agency (labour

broker) but that undertake work for one of the employment

agency’s clients (e.g. an Employment Site). Typically, Agency

Workers are paid by the employment agency and the labour user

(e.g. the Employment Site) will pay the employment agency a fee

for the use of its workers).

Audit Systematic, independent and documented process for obtaining

evidence and evaluating it objectively to determine the extent to

which ethical and environmental standards criteria are met.

a) Announced Audits: A mutually convenient date is agreed with

the Employment Site. The right to perform an Announced Audit is

part of the commercial relationship. However there is a risk that

Employment Sites may make special preparations for the Audit

and best practice is to use a mix of Announced, Semi‐Announced

and Unannounced Audits to mitigate this risk. Kingfisher Group

Business Units should clearly communicate the policy on

Announced Audits to Suppliers and Employment Sites. The policy

includes the following:

An Audit date will be agreed with the Employment Site in

advance

The Employment Site is required to provide up‐to‐date and

accurate pre‐audit and self-assessment information in advance

of the Audit

Auditors presenting the correct credentials on the date of the

Audit should be allowed full access to the Employment Site

The necessary records and the concerned personnel should be

available at the Employment Site on the day of the Audit

b) Semi-Announced Audits: The Employment Site is aware that

Audit will take place during a given time period, but the actual

date of Audit is not communicated. Semi‐Announced audits

reduce the risks to the commercial relationship and increase the

ability of the Group Company to remediate. The Group Company

should clearly communicate the policy on Semi‐Announced Audits

to Suppliers and Employment Sites, which includes the following:

A window will be specified during which an Audit may take

place. Audit windows may range between 2 weeks and 2

months.

All Employment Sites are required to provide up‐to‐date and

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accurate pre‐audit and self-assessment information at the

beginning of the window.

Auditors presenting the correct credentials during the Audit

window should be allowed full access to the Employment Site.

The necessary records should be kept at the Employment Site

during the window.

c) Unannounced Audit: The Employment Site has no prior

warning of the Audit. Unannounced Audits allow auditors to

assess the conditions at an Employment Site in their normal state,

since the Employment Site has not had the opportunity to make

any special preparations. However there is a risk that the

Employment Site will perceive unannounced auditing as deceitful,

that the auditor will not be able to gain access to the facility and/or

that the necessary information and personnel may not be

available on the day of the visit to complete the Audit.

To minimise these risks, the Group Company should clearly

communicate the policy on Unannounced Audits to Suppliers and

Employment Sites. The policy should state that:

Audits may occur at any time on an unannounced basis

All Employment Sites are required to provide both pre‐audit and

self-assessment information on a regular basis and this

information must be accurate

Auditors presenting the correct credentials should be allowed full

access to the Employment Site

The necessary records should always be kept on the

Employment Site or readily available.

Note: Whilst Unannounced Audits are extremely effective at

identifying an accurate picture of working conditions at the

Employment Site, and may help uncover high risk issues, their

use can undermine the relationships along the supply chain,

reducing the ability of Kingfisher to remediate. Unannounced

Audits should be reserved for Due-Diligence checks or to

investigate specific issues (critical issues suspected, lack of

commitment/involvement of the suppliers, suspicion of fraud).

Capacity Building

The strengthening of internal structures, systems and processes,

management, leadership, governance and overall staff capacity to

successfully manage sustainability issues and improve their

sustainability performance.

Casual Worker Workers who are not part of the permanent workforce, but who

supply services on an irregular or flexible basis, often to meet a

fluctuating demand for work.

Child Labour Child Labour: defined either by the national minimum age for employment or the age of completion of compulsory education or any otherwise specified exceptions; and any person under the age of 15, whichever of these is higher. If however, local minimum age law is set at 14 years of age in accordance with developing

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country exceptions under ILO Convention 138, this lower age may apply.

Civil Society

Organisation

Non-governmental (NGOs) and not for profit organisations that

have a presence in public life, expressing the interests and values

of their members or others, based on ethical, cultural, political,

scientific, religious or philanthropic considerations. These

organisations include community groups, NGOs, trade unions,

indigenous groups, charitable organisations, faith-based

organisations, professional associations and foundations.

Contemporary Slavery Modern Day Slavery is a collective term used to describe forms of

slavery that still exist today, even after traditional slavery has

been outlawed everywhere. It covers a range of abuses, debt

bondage, serfdom, forced labour, child slavery, sexual slavery,

forced or early marriages etc.

From the first draft of the business guidance for the transparency in supply chains (TISC) provision in the Modern Slavery Act 2015, which provides the following definition of slavery: “Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised.”

Corrective Action

Measures taken to eliminate a Non-Conformance identified during

an Audit.

Corrective Action Plan A plan of action drawn up at the end of an Audit that records what

measures have to be taken and within what timescale to remedy

the Non-Conformance.

Critical Failure Point Define the minimum entry standard for all Suppliers as a condition

of supply. A CFP must be corrected before any new contracts or

orders are placed.

Due-Diligence

The investigation or Audit of a potential business partner (individual or company) before entering into a contract, in order to determine the ethical and environment including corruption or bribery risks of the engagement.

Employment Site For the purposes of this Group Standard, all upper tier Employment Sites used in connection with producing and supplying items to Kingfisher Group Business Units should be disclosed (e.g. in the case of employment sites this would be final finishing and assembly location. We are also including any subcontractors and homeworkers that are used and locations used to store and distribute finished goods). An employment site could be an individual / specific production site, farm, quarry, mine, service site etc (including where applicable Subcontractors / Homeworkers) producing, distributing or supplying products and services to Kingfisher’s Supplier.

Follow-up Audit An Audit to assess the effectiveness of Corrective Actions,

undertaken to address from a previous Audit. A Follow-up Audit

can be either a Full or Partial Follow-up Audit.

a) Full follow-up audit: An Audit to assess the effectiveness

of Corrective Actions, undertaken to address from a

previous Audit. The Audit should include a full review of all

areas of the standard Audit process, including the

complete re-sampling of documents, conducting interviews

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and the Employment Site tour.

b) Partial Follow-up Audit: An Audit to assess the

effectiveness of Corrective Actions, undertaken to address

from a previous Audit. The Audit does not include a full

review and only focusses on the issues identified in the

Corrective Action Plan.

Global Social Compliance Programme

Global Social Compliance Programme (GSCP) is a business-

driven programme for the continuous improvement of working and

environmental conditions in global supply chains. The GSCP was

created by and for global buying companies wanting to work

collaboratively on improving the sustainability (social and

environmental) of their often-shared supply base. To this end,

these companies are working on harmonising existing efforts to

deliver a shared, global and sustainable approach based on

consensus and best existing practice.

Group Business Units

All business entities and subsidiaries of Kingfisher plc, including Operating Companies, Offer and Supply Chain (OSC), Joint Ventures where Kingfisher plc has a holding of 50% or more. ‘Kingfisher Group Business Units’ has been used as the preferred term throughout, unless a specific Business Unit is identified in the text.

Homeworker A Homeworker is someone who, for a fixed rate of remuneration,

carries out work in their home for an employer who is not the final

consumer of the product or service provided.

Human Trafficking

the movement of a person from one place to another into conditions of exploitation, using deception, coercion, the abuse of power or the abuse of someone’s vulnerability. It is possible to be a victim of trafficking even if consent has been given to being moved. Although human trafficking often involves an international cross-border element, it is also possible to be a victim of human trafficking within the victims own country. From the first draft of the business guidance for the transparency in supply chains (TISC) provision in the Modern Slavery Act 2015 which provides the following definition of human trafficking: “An offence of human trafficking requires that an individual arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or may be a child who is influenced to travel by an adult. The exploitation of the potential victim does not need to have taken place for the offence to have been committed, simply that the movement of the individual was with a view to exploiting them either for sexual exploitation or non-sexual exploitation, including labour.”

Initial Audit

The first Audit undertaken on an Employment Site which

assesses conformance against Kingfisher’s ethical and

environmental requirements.

Migrant Worker

A person who is engaged in remunerated activity, who has moved

to a country, province or region of which there are not a native,

where there are not eligible to or do not intend to become

permanent residents.

Non-Conformance A confirmed breach of Kingfisher’s Minimum Workplace

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Standards and may be classed as a Critical Failure Point

(Business Critical), Critical, Major Non-Conformance or Minor

Non-Conformance.

Non-Compliance A confirmed breach of a local, national or international law or

regulation.

Preventive Action Actions implemented in response to the identification of potential

sources of Non-Conformance or to prevent occurrence of a

similar Non-Conformance elsewhere in the facility in the

company’s other operations.

Product Categories Products are classified according to the following categories

within Kingfisher:

International Brand: Supplier of branded products not

unique or exclusive to Kingfisher Group Business Units

and sold internationally (more than one jurisdiction).

Should Kingfisher Group Business Units wish to apply

more stringent criteria for any of the identified International

Brands, they are welcome to do so. Where an

International Brand provides own-branded as well as its

own branded products, they must be treated as an own-

branded product suppliers. The criteria are 1. At least 30%

of revenue must come from outside the brand’s home

region and it must have a significant presence in Asia,

Europe and North America, there must be sufficient

publicly available data on the brand’s financial

performance. If in any doubt please contact the Head of

Net Positive Delivery for a definitive decision

Manufacturer / Vendor Brand: branded products not

unique or exclusive to Kingfisher or its Kingfisher Group

Business Units, the brands do not operate in more than 1

geography. Increasingly referred to as Unified Local (UL).

Own-Brand: products owned by Kingfisher Group

Business Units (e.g. Diall, Mac Allister, Castorama,

Screwfix etc) and/ or products with the name of the brand

or Kingfisher / Group Companies identifiable on the

product and / or packaging.

Exclusive Brand: branded products made exclusively for

Kingfisher Group Business Units for sale in stores either

indefinitely or a defined period of time.

Unbranded: often referred to as ‘No Name’ a product with

no brand or has no major national presence. For the sake

of this Group Standard we intend to treat unbranded

products on a par with own-brand & exclusive brand

products

Goods Not for Resale (GNFR): Otherwise known as

‘indirect procurement’ and refers to goods and services

that enable Kingfisher Group Business Units to function

and operate (i.e. anything that is not sold to customers).

Packaging: Materials used for the containment,

protection, handling, delivery and preservation of goods

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from the producer to the user or consumer.

QMT Quality Management Tool (QMT) is used by the QA team when

validating products and vendors against a range of technical and

sustainability requirements. Currently under development is the interface

between the SEDEX platform and the QMT, due to be completed in

Q3/Q4 of 2016. This will allow for the transfer of factory ethical audit

data from SEDEX to the QMT.

Re-audit

A new Audit which is performed on an Employment Site that has

already been audited against Kingfisher’s Minimum Workplace

Standards.

Recruitment fees Migrant workers frequently pay fees to agencies and brokers for recruitment and placement in jobs abroad. These fees may cover costs including the recruitment itself, travel, visa and administrative costs, and often other unspecified ‘fees’ and ‘service charges’. These fees are often substantial and are sometimes set up as loans with high rates of compound interest. As a result many workers are already exploited and vulnerable before they even arrive at their place of work.

Root Cause A Root Cause is the underlying reason behind a Non-

Conformance and should be permanently eliminated through

process improvement. Root Cause analysis is a collective term

that describes a wide range of approaches, tools, and techniques

used to uncover the underlying cause of problems.

Service Provider Suppliers who have a central head office with management

structures to administer the provision of staff to provide services

which could be on other third party sites or sites owned by

Kingfisher Group Business Units. Examples include general and

specialist cleaning companies, waste management, installation or

servicing of equipment, professional services, and transport and

logistics services.

Supplier Any contracted partner which supplies a Group Company with

products or services.

Existing Supplier: Those Suppliers are where there is a ‘live’

contract in place and are actively producing and supplying

products and services to Kingfisher Group Business Units.

Subcontractor

An individual or a group of individuals to whom a contract outsources the manufacture of a product or part-product or supply of a service.

Supply Chain Workplace Standards

Kingfisher’s Supply Chain Workplace Standards set out ethical

and environmental standards for suppliers. We now audit

suppliers against the standards set out in the SMETA audit

protocol, which are in line with our standards.

Temporary Worker

A Temporary Worker is a Worker who is employed directly by the employer, but on a contract that is for a specified period of time. When the contract ends there is no obligation for the employer to continue the employment agreement.

Top Supplier

Suppliers in scope for the Top Supplier programme as defined

and amended from time to time by Offer and Supply Chain.

Kingfisher Group Business Units who work with ‘Top suppliers’ on

more strategic and / or long-term basis, can clarify with the

Director of Sustainability, Offer and Supply Chain what

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requirements would be needed to leverage the strategic nature of

these suppliers. This might involve integrating our ethical and

environmental requirements into a longer-term, strategic plan and

should set the direction, strategy and action for the Supplier’s

implementation of sustainability requirements. The aim of any

strategy might include elements of:

Improve performance and risk management;

Build capacity;

Foster commitment to sustainability; and

Improve the flow of reliable sustainability information from

supplier to Group Company

Verification

Examination of claims made about the actual observance of code

or standard provisions by Suppliers or of claims made about the

activities that a company undertakes to give effect to its code.

Verification implies that participating companies must have

internal auditing or monitoring systems in place.

Young Worker Any worker between the ages of 16 and 18 years old

Worker A person working on an Employment Site in any capacity.

Workplace synonymous for the purpose of this Group Standard with

‘Employment site’

APPENDIX 5: MAIN POINTS OF CONTACT Key contacts:

Head of Sustainability – general queries about this policy

Sustainability Director, Offer and Supply Chain – queries about ethical sourcing for Goods for Resale.

Our Standard Operating Procedure on Ethical Sourcing provides further detail of the escalation process for resolving issues associated with our ethical sourcing policy. There are also sources of guidance on Sedex http://www.sedexglobal.com/.