OVERVIEW

Our policy is to respect the dignity, wellbeing and human rights of our employees, the workers in our supply chain and the communities in which we operate. We are committed to conducting our business in a responsible and sustainable way, seeking to mitigate the risks and potential impacts of human rights abuses both within our direct operations and supply chains.

We have a collaborative approach to human rights, partnering with key stakeholders across our value chain to make positive societal impact. Our commitment to human rights extends through several Group policies. Our Code of Conduct and Supplier Code of Conduct set out the foundations to our approach to human rights, which all our employees, suppliers and business partners are required to adhere to. 
 

WHY IS IT IMPORTANT?

Respecting human rights is important in relation to our own employees, external reputation and supply chain sustainability. Our Policy and approach are guided by the international human rights principles in line with the International Bill of Human Rights, the International Labour Organization’s (ILO) core conventions and the principles and guidance contained within the United Nation Guiding Principles on Business (UNGP) and Human Rights.

We recognise that, along with our direct operations, our supply chain has the potential for human rights abuses, and we are committed to working with our suppliers and business partners to improve supply chain standards. We establish a relationship of trust and integrity with our suppliers. We expect our suppliers to conduct their business in an ethical and responsible manner and comply with all applicable laws and regulations. The respect for human rights is predominately enabled through our requirements for supplier standards, business conduct and employment practices. Our Supplier Code, based on our Code of Conduct, sets out the behaviours we expect our suppliers to demonstrate.

Our Human Rights policy applies to all Imperial Brands companies and to any joint venture where Imperial Brands has management control. It applies to all employees, directors and officers of Imperial Brands companies, including temporary and contract staff. 

Our due diligence processes enable us to monitor compliance with our policy commitments and identify areas for improvement. Further information on our due diligence processes for our tobacco supply chain and non-tobacco material supply chains can be found in our Modern Slavery Statement 2020
 

WHAT ARE WE DOING ABOUT IT?

Our on-going commitment to human rights has included: undertaking Human Rights Impact Assessment to better understand the salient human rights in relation to our global supply chains; strengthening policy commitments and standards; and more recently reviewing how robust these policies are.

We're proud to be a founding member of the Slave Free Alliance (SFA) and continue to support the international charity Hope for Justice, in their pursuit of a slave free world. ​

In July 2019 we commissioned SFA subject matter experts to conduct a policy gap analysis and review of the policies and processes we have in place to mitigate against the risk of modern slavery. The review included stress testing processes, interviews with subject matter experts and testing the application of global policies on the ground including those detailed within our previous modern slavery statements.

Whilst a number of good practices were identified, including due diligence within the supply chain, several recommendations were also made by SFA.

Through recent stakeholder engagement, modern slavery and the broader management of human rights risk were identified as one of Imperial’s priority sustainability issues. In response to this and the recommendations from the SFA, we are committed to implementing a robust human rights framework for the Group, which will support in strengthening our processes for identifying, managing and mitigating human rights risk. 
 

RESPONDING TO ALLEGATIONS 

We take any allegations relating to human rights extremely seriously. We engage both internally and with the relevant external stakeholders, which may include suppliers and NGOs to investigate allegations and respond to the issues raised.

During 2020, there was a focus on our sourcing practices in Italy following a report by the Guardian newspaper in 2019, alleging the exploitation of migrant workers in tobacco growing in the Campania region of Italy.

We source a very small amount of tobacco from Campania through a third-party supplier. Our supplier works with tobacco farmers to promote good agricultural labour practices and monitors compliance with the Sustainable Tobacco Programme. Through our supplier’s audits and due diligence, as well as third party checks, there has been no evidence to support the claims made in the Guardian report.  

However, we take all such allegations seriously and in direct response to the report, our own Leaf Sustainability Manager visited supplier farms in Italy to further reinforce the good agricultural practices we expect from all the farmers in our supply chain. Further information can be found in our Modern Slavery Statement.
 

WHAT ARE THE KEY ISSUES?

ADDRESSING CHILD LABOUR

Child labour is unacceptable, and we make every effort to stop it happening in our supply chain.

MODERN SLAVERY  

We have partnered with the Slave Free Alliance to improve our processes for mitigating against modern slavery.

HEALTH AND SAFETY

We seek to provide a safe working environment for our employees and those working for us.

ADDRESSING CHILD LABOUR

Child labour is not acceptable. Our approach to respecting human rights, including child labour, is guided by the international human rights principles in line with the International Bill of Human Rights, the International Labour Organization’s (ILO) core conventions and the principles and guidance contained within the United Nation Guiding Principles on Business (UNGP) and Human Rights.

In accordance with the main international and legal instruments contained in the Conventions of the ILO and the Convention on the Rights of the Child (UNCRC), child labour is defined as work that can harm children’s well-being and hinder their education, development and future livelihood.

Similar to other agricultural industries, the risk of child labour is highest in our tobacco growing supply chain. Addressing child labour is a multi-stakeholder issue, one which no single entity can address in isolation. In collaboration with key stakeholders including the industry, suppliers and NGOs, we seek to address child labour through three main avenues;

(i) Leaf supplier programme known as the Sustainable Tobacco Program (STP); the Human and Labour Rights section of STP is a critical element for the respect of human rights and is aligned with the relevant ILO conventions and the UN Guiding Principles on Business and Human Rights.

(ii) Leaf Partnership Projects; working directly with our suppliers to fund projects in tobacco growing communities to help tackle some of the root causes of child labour. 

(iii) Our active support of the Eliminating Child Labour in Tobacco Growing Foundation (ECLT), which aims to tackle the root causes of child labour by improving access to education and providing alternatives to childhood working. It also has an advocacy role, raising awareness with governments and communities to galvanise positive action.

As an ECLT Board member we have signed a Pledge of Commitment and Minimum Requirements’, which affirms that “ECLT Board Members respect and recognise the principles and rights enshrined in the ILO Conventions and recommendations on child labour. The pledge further affirms a sector wide commitment to uphold the robust policies on child labour”.

We engage with NGOs including Human Rights Watch on the issue of child labour in agricultural supply chains. We believe in constructive dialogue and transparency in dealing with this very important issue.

In addition to the STP, which covers all of our leaf suppliers, we operate a Supplier Qualification Programme for our key non-tobacco material (NTM) and next generation product (NGP) suppliers. NTM and NGP suppliers are asked to complete a compliance check, which includes questions on business conduct, environmental management and labour practices. We also encourage our suppliers to evaluate their suppliers and sub-contractors. We prioritise audits on the basis of risk assessment, quality and performance.

Further detail on how we address the issue of child labour in our agricultural supply chain is detailed in our Addressing Child Labour overview.
 

MODERN SLAVERY

We recognise that modern slavery can include forced and child labour, servitude and human trafficking, all of which restrict a person’s freedom of movement whether that be physical or non-physical. Like all businesses, we run the risk of being exposed to modern slavery either within our direct operations or indirectly through our supply chain.

We published our first Modern Slavery Act statement, in accordance with the Modern Slavery Act, in March 2017. Our 2020 statement details how we continue to build upon and strengthen our approach to addressing modern slavery and potential human rights abuses. An archive of our Modern Slavery Statements is available in our download library.

Our focus in 2020 has been to begin implementation of the recommendations from the SFA. While some of these workstreams, particularly audit related, have been impacted and delayed by the impact of the COVID-19 pandemic, we have:

  • Mapped modern slavery risk aligned to our direct operations and workforce, focusing on the Manufacturing and Supply Chain (MSC) function. This is with the aim of better understanding peak periods of activity in our operations and ensuring we have effective recruitment policies in place for recruiting temporary and seasonal staff.
  • Developed a modern slavery audit module, specifically looking at facilities management. We had planned on piloting this module in partnership with our UK facilities management company, however this has been paused due to COVID-19.
  • Assessed employee training needs, to identify and target groups of employees and provide them with specific modern slavery training and awareness. This has included a workshop for our global Procurement Team conducted by SFA, as well as e-learning courses for the general employee populations and specialist END Slavery training for key functional representatives.

During the year we also translated our modern slavery e-learning course into a further two languages, Japanese and Czech, to further support employees in understanding the issue and explaining how to raise concerns on suspected human rights abuses. The e-learning is also available in English, German, Chinese, Dutch, French, Greek, Polish, Russian, Spanish and Ukrainian.

We are proud of our ongoing support to Hope for Justice in pursuing its vision of a world free from slavery. Since our partnership began in 2014, Hope for Justice has rescued more than 650 victims of modern slavery in the UK, while also running anti-trafficking projects, community prevention initiatives, aftercare facilities and education/training programmes across nine countries.

Want to know more?

OUR APPROACH

Our sustainability strategy is integral to the long-term success of our business and underpins our drive to create shared value for our stakeholders.

CASE STUDIES

Our case studies showcase our progress against our sustainability strategy. 

ESG PERFORMANCE

See the progress we’ve made against our key performance indicators during 2020.