Case study: How Royal Mail combats human trafficking
Committed to upholding and respecting human rights, Royal Mail, as the UK’s pre-eminent delivery company, welcomed the UK Government’s Modern Slavery Act and seeks to prevent any practices in its business and supply chain that impinge human freedom through servitude, forced and compulsory labour, and human trafficking.
This case study is based on the 2016-17 Corporate Responsibility Report by Royal Mail published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Recognising that human rights violations, including forced labour and trafficking, can occur in all sectors and countries, Royal Mail put new measures in place in 2016–17, to strengthen the protection of human rights across its operations. Tweet This! In order to combat human trafficking Royal Mail took action to:
- tighten controls
- provide training
- encourage employees to raise concerns
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With this case study you will see:
- Which are the most important impacts (material issues) Royal Mail has identified;
- How Royal Mail proceeded with stakeholder engagement, and
- What actions were taken by Royal Mail to combat human trafficking
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What are the material issues the company has identified?
In its 2016-17 Corporate Responsibility Report Royal Mail identified a range of material issues, such as community relations, customer service, employee relations, responsible procurement. Among these, combatting human trafficking stands out as a key material issue for Royal Mail.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the principle of stakeholder inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups Royal Mail engages with:
| Stakeholder Group | Method of engagement |
| Customers
| · Royal Mail’s customer services engage in approximately 7.5 million customer conversations a year by phone, email and Twitter · www.royalmail.com website · Royal Mail’s postmen and women interact with customers daily · Sales team of account managers – field, desk, new business and specialists – interact with business customers on a daily basis |
| Colleagues
| · Weekly Work Time Listening and Learning sessions for frontline employees · Just Say It (an email link to Royal Mail’s CEO) · Royal Mail TV · Intranet and extranet (www.myroyalmail.com) · Town Hall forums and engagement with senior managers · Royal Mail’s monthly magazine, Courier |
| Unions | · Weekly meetings between CWU representatives and frontline operational managers · Ad hoc meetings to support individuals · Operations directors, project managers and the Industrial Relations team engage with unions on all business-wide issues · Ongoing collaborative meetings to involve Royal Mail’s unions in efficiency improvements and growth opportunities |
| Investors | · A comprehensive investor relations programme · Full year and half year results presentations and first and fourth quarter trading updates · Annual General Meeting · Publication of Annual Report and Financial Statements · The investors section of Royal Mail’s website · Internal communication channels for Royal Mail’s employee shareholders |
| Regulator – Ofcom
| · Royal Mail’s Regulation and Competition Policy team regularly engages through face-to-face meetings, reporting and consultation responses |
| Elected representatives and officials
| · Royal Mail’s Public Affairs and EU Policy teams engage regularly with elected representatives and Government officials through responses to formal consultations, briefings and Royal Mail’s outreach programme. This includes ‘Walking in your postie’s shoes’ and other operational visits |
| Local communities | · Royal Mail’s CR and Community Investment team engages with charity partners and organisations to drive positive social impacts · Colleagues interact with communities daily |
| Suppliers | · Group Procurement liaises with suppliers before sourcing, and monitors compliance with Royal Mail’s Responsible Procurement Code, which sets out the high standards of ethical, social and environmental conduct Royal Mail expect from its suppliers · Contract managers monitor suppliers’ contractual obligations and KPIs · GLS engages with transport providers in Germany to embed ethical principles through its Partner Code |
How stakeholder engagement was made to identify material issues
To identify and prioritise material topics Royal Mail engaged with its stakeholders through surveys, interviews and a stakeholder panel. Participants were asked to rank various issues according to priority and included customers, consumers, employees, unions, shareholders, suppliers and environmental representatives.
What actions were taken by Royal Mail to combat human trafficking?
In its 2016-17 Corporate Responsibility Report Royal Mail reports that it took the following actions for combatting human trafficking:
- Tightening controls
- Royal Mail decided to take some additional steps to further tighten the controls it has in place for higher risk parts of its supply chain and operations:
- Royal Mail’s on-boarding process for UK suppliers now includes a specific question on modern slavery and human trafficking. This requires potential suppliers to confirm their compliance with all applicable labour and employment laws, which include all anti-slavery and anti-trafficking legislation, the Modern Slavery Act, or equivalent national legislation.
- In October 2016, Royal Mail introduced a new clause to the standard Royal Mail contract terms, which requires suppliers to comply with the Modern Slavery Act and notify Royal Mail of any breaches. This applies to all new contracts and contract extensions and amendments with current suppliers.
- In March 2017, Royal Mail created a risk map to identify higher risk supplier categories. The results of this risk mapping exercise will be used to develop and strengthen Royal Mail’s supply chain controls.
- Royal Mail is developing a human rights risk assessment, which higher risk business units will be required to complete each year.
- Additionally, should any instances of modern slavery or human trafficking come to light, contracts with the relevant suppliers may be terminated. Royal Mail takes the necessary action when its Responsible Procurement Code is not complied with and, in 2016–17, terminated dealings with a supplier that failed an unannounced, independent factory audit, raising serious concerns about the supplier’s approach to worker safety.
- Providing training
- In 2016–17, Royal Mail’s UK Procurement team received training on the Modern Slavery Act and the new legal requirements, with further training planned for 2017–18. Through this training Royal Mail makes sure that relevant employees are aware of its procedures for identifying, managing and mitigating any risk of modern slavery and human trafficking taking place in its business and supply chain – including how to report any concerns. Royal Mail also developed an e-learning course on modern slavery and human trafficking, available to a wider group of employees.
- Encouraging employees to raise concerns
- Royal Mail’s whistleblowing helpline, ‘Speak Up’, allows employees (including contractors and temporary workers) to raise concerns about serious wrongdoing, anonymously. This includes any concerns about violations of human rights. Royal Mail’s General Logistics Systems (GLS) also operates a whistleblowing system to enable employees, business partners and third parties to report, in confidence, any concerns regarding criminal acts or other serious offences.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standards addressed in this case are:
2) Disclosure 412-1 Operations that have been subject to human rights reviews or impact assessments
Disclosure 407-1 Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk corresponds to:
- Sustainable Development Goal (SDG) 8: Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all
- Business theme: Freedom of association and collective bargaining
Disclosure 412-1 Operations that have been subject to human rights reviews or impact assessments does not correspond to any SDG.
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References:
1) This case study is based on published information by Royal Mail, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
http://database.globalreporting.org/
2) http://www.fbrh.co.uk/en/global-reporting-initiative-gri-g4-guidelines-download-page
3) https://g4.globalreporting.org/Pages/default.aspx
4) https://www.globalreporting.org/standards/gri-standards-download-center/
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