PRIMARK CODE OF CONDUCT 2023
Introduction
Primark’s Supplier Code of Conduct sets out our requirements to ensure that workers in our
supply chain have good working conditions and that workplace rights are afforded and
respected.
All suppliers, including contractors and other business partners, that manufacture, finish,
pack or otherwise handle goods or perform services for Primark must comply with this
Supplier Code of Conduct and all applicable laws and regulations in the countries and
territories in which they operate. Where the requirements of this Supplier Code of Conduct
set a higher standard than is required by local laws and regulations, suppliers must align
with the requirements of this Supplier Code of Conduct. Suppliers are also responsible for
ensuring that this Supplier Code of Conduct and all relevant laws and regulations are
complied with within their own supply chains.
For further information regarding the policies and procedures that underpin our code, please
click here.
This Supplier Code of Conduct is drafted and is valid in the English language. Where there
are different language versions of the Supplier Code of Conduct, these are considered
translations for convenience only and the English version will prevail in case of any
discrepancy.
Paul Marchant, Chief Executive, Primark
Primark Code of Conduct.V7. January 2023
PRIMARK CODE OF CONDUCT 2023
Employment is freely chosen
There must be no forced or compulsory labour in any form,
including bonded, indentured, trafficked, or prison labour and
overtime must be voluntary.
Any fees associated with the employment of Workers must
be paid by the Employer.
Workers must not be required to lodge any monetary
deposits or their identity papers with their Employer.
Workers must be free to leave their Employer after
reasonable notice.
Freedom of Association and Right to Collective Bargaining
All workers have the right to join or form trade unions of their
own choosing and to bargain collectively.
Employers will adopt an open attitude towards the activities
of trade unions and their organisational activities.
Workers’ representatives must not be discriminated against
and must have access to carry out their representative
functions in the workplace.
Where the right to freedom of association and collective
bargaining is restricted under law, Employers will facilitate,
and must not hinder, the development of parallel means for
independent and free association and collective bargaining.
Individuals who represent workers should do so willingly, and
be freely and transparently elected, without influence from
any other party.
Working Conditions are safe and hygienic
Employers must provide a safe and hygienic working
environment, bearing in mind the prevailing knowledge of the
industry and of any specific hazards. This includes the
physical structure of the buildings and facilities used.
Through policy and procedure employers must take adequate
steps to prevent accidents and injury to health arising out of,
associated with, or occurring in the course of work.
Employers must appoint a senior management
representative to be responsible for ensuring a safe and
healthy workplace environment.
Primark Code of Conduct.V7. January 2023
PRIMARK CODE OF CONDUCT 2023
Workers must receive regular and recorded health and
safety training and such training will be repeated for new or
reassigned workers.
Access must be provided to clean toilet facilities and to clean
drinking water. If appropriate, clean and safe facilities for the
preparation, consumption and storage of food should be
provided.
Employers must provide access to adequate medical
assistance and facilities in the event of illness or injury at
work.
Accommodation, where provided, must be chosen by the
worker, be clean, safe and meet their basic needs.
Child Labour must not be used
There must be no recruitment or employment of child labour.
In any given country the minimum working age, as well as
rules regarding the employment of a Young Worker will be
defined by the conventions of the ILO or national/regional
law, whichever affords greater protection to the individual.
For clarity, Young Worker in this context refers to an
individual above the legal working age but before their 18th
birthday.
Companies must have policies and programmes which
prevent the recruitment and employment of child labour.
Living Wages are paid
Wages and benefits paid for a standard working week must
meet, as a minimum, the national minimum wage, or in the
absence thereof an acceptable industry benchmark. In any
event, wages must always be enough to meet basic needs
and to provide some discretionary income. Primark actively
supports moves to ensure that the minimum wage is
determined by national collective bargaining at industry level.
All Workers must be provided with written and
understandable information about their employment
conditions in respect to wages before they enter employment
and about the particulars of their wages for the pay period
concerned each time that they are paid.
Deductions from wages as a disciplinary measure or any
deductions from wages not provided for by national law are
not permitted without the express permission of the Worker.
All disciplinary measures must be recorded.
Primark Code of Conduct.V7. January 2023
PRIMARK CODE OF CONDUCT 2023
Overtime hours must always be compensated at a premium
rate, which is recommended to be not less than 125% of the
regular rate of pay.
Overtime and benefits should be paid in the period worked.
Working Hours are not excessive
Working hours must comply with national laws and
benchmark industry standards, whichever affords greater
protection.
Standard working hours, excluding overtime, must be
defined by contract and must not exceed 48 hours per week*.
Overtime must be used responsibly, taking into account the
extent, frequency and hours worked by individual workers
and the workforce as a whole.
Total hours worked including overtime, must not exceed 60
hours in any 7 day period unless there are exceptional
circumstances. In such cases, all of the following conditions
must be met:
• This is permitted by national law;
• This is permitted by a collective agreement freely
negotiated with a workers’ organization representing a
significant portion of the workforce;
• Appropriate safeguards are taken to protect Workers’
health and safety; and
• The Employer can demonstrate that exceptional
circumstances apply such as unexpected production
peaks, accidents or emergencies.
Workers must be provided with at least 1 day off in every 7
day period or, where permitted by national law, 2 days off in
every 14 day period.
*International standards recommend the progressive
reduction of standard hours of work (excluding overtime),
when appropriate, to 40 hours per week, without any
reduction in workers’ wages as hours are reduced.
Primark Code of Conduct.V7. January 2023
PRIMARK CODE OF CONDUCT 2023
No Discrimination is practised
There must be no discrimination of Workers including, but
not limited to, hiring, occupation, compensation, access to
training, promotion, termination or retirement based on but
not limited to race, caste, colour, national origin, religion,
age, disability, gender, marital status, sexual orientation,
union membership or political affiliation.
Regular Employment is Provided
To every extent possible, work performed must be on the
basis of a recognised employment relationship established
through national law and industry practice.
Obligations to Workers under labour or social security laws
and regulations arising from the regular employment
relationship must not be avoided through the use of labour-
only contracting, sub- contracting, home-working
arrangements or through apprenticeship schemes where
there is no real intent to impart skills or provide regular
employment, nor must any such obligations be avoided
through the excessive use of fixed-term contracts of
employment.
Overtime must not be used to replace regular employment.
Contract termination must be based on a process which is
fair, transparent and consistent with the requirements of local
law, and which is communicated to relevant workers clearly.
No Harsh or Inhumane Treatment
There must be no physical abuse or discipline, threat of
physical abuse, sexual or other harassment, verbal abuse or
other forms of intimidation including a hostile or offensive
work environment.
Environmental Responsibility
Suppliers must comply with all applicable local laws and
regulations regarding the protection and preservation of the
environment. This includes obtaining and maintaining all
required environmental permits, approvals and registrations.
For more information please read the Environmental Policy
here.
Primark Code of Conduct.V7. January 2023
PRIMARK CODE OF CONDUCT 2023
Legal Requirements
Primark is committed to the laws and regulations in each
procurement location where it conducts business, and will
not knowingly operate in violation of any such law or
regulation.
Where the requirements of this Supplier Code of Conduct set
a higher standard than is required by local laws and
regulations, suppliers must align with the requirements of this
Supplier Code of Conduct.
Grievance Procedure
There should be a procedure that allows workers to raise
and address workplace grievances, without fear of reprisal.
The procedure must be clearly communicated to Workers at
the time of their recruitment and be easily accessible to all
Workers and their representatives.
The grievance procedure must involve an appropriate level
of management.
The management must address Workers’ concerns promptly,
using an understandable and transparent process that
provides timely feedback to those concerned.
The grievance procedure must not be used to undermine the
role of trade unions and collective bargaining processes and
must not impede access to other existing judicial, arbitration
or administrative procedures.
No Bribery or Corruption will be tolerated
The offering, paying, soliciting or accepting of bribes or kick-
backs, including facilitation payments, is strictly prohibited. A
bribe may involve giving or offering any form of gift,
consideration, reward or advantage to someone in business
or government in order to obtain or retain a commercial
advantage or to induce or reward the recipient for acting
improperly or where it would be improper for the recipient
to accept the benefit.
Bribery can also take place where the offer or giving of a
bribe is made by or through a third party, e.g. an agent,
representative or intermediary.
Some examples of bribes are as follows. This is not an
exhaustive list:
• gifts, or travel expenses
Primark Code of Conduct.V7. January 2023
PRIMARK CODE OF CONDUCT 2023
• the uncompensated use of company services, facilities or
property
• cash payments
• loans, loan guarantees or other credit
• the provision of a benefit, such as an education
scholarship or healthcare, to a member of the family of a
potential customer/public or government official
• providing a sub-contract to a person connected to
someone involved in awarding the main contract
• engaging a local company owned by a member of the
family of a potential customer/public or government
official.
Facilitation payments are small payments or fees requested
by government officials to speed up or facilitate the
performance of routine government action (such as the
provision of a visa or customs clearance). Such payments
are strictly prohibited.
Suppliers, representatives and their employees must comply
with all applicable anti-bribery and corruption laws. If no such
anti-bribery or corruption laws apply, or are of a lesser
standard to that prescribed in the UK Bribery Act 2010,
suppliers, representatives and their employees must adhere
to the UK Bribery Act 2010.
Suppliers and representatives must have in place anti-
corruption and bribery procedures to prevent employees or
persons associated with its business from committing
offences of bribery or corruption. Suppliers and
representatives will properly implement these procedures
into their business and review them regularly to ensure that
they are operating effectively.
Primark Code of Conduct.V7. January 2023
