04. Supply Chain Due Diligence
As described above, Aromatherapy Associates’ permanent working group on modern slavery considers more fully our company’s risk of
exposure to these practices and risk mitigation activities. Following a previous review of potential exposure to modern slavery, the group
developed a continuing action plan targeting the highest risk operations through a phased approach.
Aromatherapy Associates works with multiple service providers to facilitate risk and compliance due diligence reviews of business partners
globally. These reviews may include active monitoring for adverse media regarding modern slavery and other issues.
New suppliers are assessed prior to onboarding and then actively monitored for a minimum of one year. Existing suppliers will be monitored
on an ongoing basis.
Our commitment to eliminating modern slavery starts with focusing intensely on our owned brands supply chain where we believe we can have the greatest impact. This includes maintaining and continually assessing and enhancing our well-established program of supplier assessment, which is delivered through our own ethical trading auditors or a small number of pre-approved third-party assessment bodies.
Our ethical trading experts across the globe meet on a regular basis to ensure the program remains effective and drives best practices
throughout our supply chain.
We ensure our owned brand suppliers are fully aware of our standards and expectations. This is achieved through supplier manuals, contracts, technical agreements and mandatory ethical compliance assessments. Suppliers must further agree to provide evidence of their related compliance programs, which should also include a process for assessing the ethical standards of their own supply chains. Analysis of our assessment program shows levels of compliance with our ethical trading standards are significantly higher for existing sites than for new
sites. This reflects increasing understanding and commitment from our supply chain to maintaining our standards.
We also have in place a formal escalation process whereby any modern slavery “Zero Tolerance” violations or other serious violations
of our standards that we become aware of are reported to the senior management team within 24 hours, along with the results of any
In fiscal year 2020, the WBA group conducted more than 900 ethical compliance assessments on new and existing suppliers. Our assessment
ratings are defined by the severity and/or number of incidents of noncompliance identified during the assessment process, these are currently defined as:
- Satisfactory and Needs Improvement: Meets our ethical trading standards expectations but could require differing levels of remedial
- Critical: Falls below the expectations of our ethical trading standards and requires immediate remedial action to address the critical
incidents of noncompliance to enable new or ongoing business relationships
- Zero Tolerance: Issues identified that are not accepted or tolerated by our businesses and are related to incidents of the following but
not limited to:
• Child Labour
• Convict/Indentured/Forced Labour
• Corporal Punishment
• Slavery and Human Trafficking
• Acts of Bribery
• In all cases we view these issues as Zero Tolerance.