Primark: Embedding a commitment to responsible purchasing practices

Between 2022 and 2024, Primark took part in the Learning and Implementation Community (LIC) initiative, as part of their ongoing commitment to implementing and embedding responsible purchasing practices (RPPs) across their supply chain. 

This case study explores how Primark built a foundation of understanding across their organisation and designed and implemented an itemised costing methodology across all of its products and sourcing countries. This action supports Primark’s commitment to pursue a living wage, under the Primark Cares strategy. 

Industry purchasing practices 

The purchasing practices of brands and retailers can have a significant impact on workers in the supply chain. The way in which a company engages with supply chain partners to plan products, negotiate costs and pay for orders has a bearing on the supplier’s ability to invest in good working conditions, manage their workforce in a positive and sustainable way and cascade responsible practices to other tiers in the chain.   

Many brands and retailers have teams dedicated to human rights due diligence, but purchasing practices are influenced by functions across the organisation. Functions such as buying, merchandising, design, finance, and legal all play a part in how the business operates. A common root cause of poor purchasing practices across the retail industry can often be inadequate communication, knowledge sharing and strategic alignment between these teams, which can result in the failure to incorporate human rights considerations into everyday operations. Moreover, failing to engage with suppliers to understand their perspectives on the impacts of these practices and to collaborate on improvements typically hampers industry progress towards making purchasing practices more responsible. 

Primark’s commitment to RPPs 

As an ETI company member and a founding member of ACT (Action, Collaboration, Transformation),Primark have made a commitment to RPPs. Through their commitment to improving purchasing practices and aligning with ACT's Global Purchasing Practices, Primark strives to build stronger, more collaborative partnerships with their suppliers. By implementing meaningful changes in how Primark works together with suppliers, they aim to provide the certainty and support suppliers need to make this possible.  

Primark, like other ACT brands, have committed to improving their purchasing practices globally in five areas where the biggest impact on wages and working conditions was identified. The ACT memorandum of understanding between each member brand and IndustriALL Global Union commits corporate signatories to ensure that their respective purchasing practices support long-term partnerships with manufacturers and facilitate the payment of a living wage. Through their ETI membership, Primark took part in the RPPs Learning and Implementation Community, to support the practical implementation of RPPs and start to embed these into the business. 

The implementation community  

The RPPs Learning and Implementation Community (LIC) is a group of 36 garment brands from Europe and the UK, brought together by multi-stakeholder initiatives (MSIs) including ETI, Ethical Trade Norway, Fair Wear, the German Partnership for Sustainable Textiles (PST) and NGO Solidaridad¹. The community held meetings structured around the principles of the Common Framework on Responsible Purchasing Practices², every two months for two years, to explore practical actions to improve purchasing practices. Sessions focused on sharing perspectives from across the industry, giving a platform to suppliers, manufacturing associations, buyers, and supply chain experts, to build communication and understanding of the likely risks and impacts of purchasing practices in the supply chain, and to explore practical changes that can be made. Between meetings, each MSI followed up with their member companies to support action planning and implementation.  

Primark’s involvement in the LIC 

The LIC represents a combination of two core ETI ways of working. Firstly, it provides guidance to companies to support continuous progress toward improved human rights due diligence. Secondly, it brings companies and other stakeholders together in a confidential space to work on difficult issues collectively. Through active participation in the LIC, Primark engaged in both processes, sharing and learning in a confidential setting, whilst using that learning to promote internal improvements. 

An important element of improving purchasing practices is to avoid the silos that can often exist between commercial and human rights functions at companies. Thus, a key expectation of LIC participating companies was to nominate individuals from both the commercial and human rights teams to participate in workshops and lead activities together, thereby promoting cross-functional collaboration and knowledge sharing. Primark - an international fashion retailer employing more than 80,000 colleagues across 17 countries in Europe and the US - was one of the brands with the greatest global reach in the community, both in terms of sourcing footprint and retail operations. Seeking to scale up the LIC approach to match the size and ambition of the company, Primark created the position of Buying Solutions Manager within the Primark Cares Living Wage Team. They then filled this role from within the buying and merchandising team, to bring the essential perspective of the buying community to the table.  

This position enabled Primark to have an experienced buyer dedicate their time to advancing progress on RPPs. Equipped with cross-functional knowledge, the team participated in LIC workshops, working through the five Principles of the Common Framework, in parallel to implementing the ACT Global Purchasing Practice Commitments. 

Building a foundation of understanding across teams 

Undertaking training to raise awareness and understanding across functions is a key practice within Principle 1 of the Common Framework: ‘Integration’. Training on RPPs is also ACT’s Global Purchasing Practices Commitment #4: ‘training on responsible sourcing and buying’.  

Building on several years of internal training on responsible purchasing practices for buying and merchandising, the Living Wage Team mapped out the various additional functions across Primark. This exercise highlighted the complexity of the many roles that influence purchasing practices and the importance of raising awareness and understanding of their impact. This applied not just within buying and merchandising, but across a wide range of core functions, including legal, communications, ethical trade, finance, and sourcing.  

Using the training modules created by ACT for its brand members, the team rolled out an extensive online training programme, covering forecasting and planning, fair terms of payment, wages as itemised costing, and responsible exits. The aim was to increase the awareness and understanding of the importance of RPPs in their roles and within Primark.   

Developing an itemised costing methodology 

Principle 5 of the Common Framework covers sustainable costing of products. This is an important part of enabling suppliers to pay worker wages compliant with local laws and to make progress towards paying a living wage. Understanding how prices are determined and then protecting the labour component from negotiation in a way that is fair to suppliers, is part of supporting this progress. 

In line with ACT’s Global Purchasing Practices Commitment #1, which requires identifying, ring-fencing and protecting of workers’ wages, Primark adapted their current costing processes to clearly identify the wage component of any product. Reflecting on the challenge, the team explained that the costing methodology needed to deliver on the ACT Labour Costing Protocol, and fit into Primark’s ways of working, for both their buying and merchandising colleagues but also their suppliers.  

To support the development of a methodology that could be understood by manufacturers of a wide range of products at a global level, a working group was formed which included key suppliers, an external costing consultant with industry experience of both buying and supplying, as well as in-country and cross-functional team representatives. Together they developed the methodology, in addition to the training and resources needed for suppliers and buyers to deliver a successful rollout. 

Ongoing collaboration with stakeholders ran through the heart of the project. The working group tested the methodology, fed back on challenges and worked together to find solutions. The Living Wage Team liaised with trading department heads, who recommended how to onboard their respective teams. This resulted in 18 in-person mandatory training sessions on wages as itemised costs, attended by 455 buying and merchandising colleagues. The small group format encouraged questions and engagement. In addition, the business sent a communication to all suppliers, inviting them to training webinars. These separate supplier sessions were tailored to product category and country and reached nearly 400 suppliers. The Living Wage Team designed and conducted the training making sure they were accessible throughout the process to answer any questions. 

Reflecting on enabling factors 

Reflecting on the project, the team describe the key factors that enabled them to push through potential roadblocks. 

Commitment: Primark Cares have made public commitments to RPPs. This has helped keep momentum and focus. “We recognise that responsible purchasing practices are fundamental to supporting our suppliers and pursuing living wages for workers in our supply chain. By embedding these practices into our operations, we’re not only fulfilling our commitments but also setting a standard for collaboration and long-term progress” 
Director of Primark Cares 

Cross-functional collaboration: “To deliver RPPs and especially transparent costing, we recognised very early on that Primark could not do this alone. It was incredibly important to us to not only include our buying and merchandising colleagues, but to have our suppliers’ voices at the table, to be able to develop a solution that all parties could see themselves using.” 
Living Wage Lead, Primark Cares 

The results of the 2023 ACT Survey, aimed at gathering insight from both colleagues and suppliers, had highlighted an appetite for training. There was therefore an existing willingness to engage when this training was rolled out.  

Supplier engagement: Training was developed with the support of suppliers in the working group, who gave feedback on language of the tools and training developed. This input was key to the successful rollout of the supplier training programme. 

Monitoring and communication: Primark’s Living Wage Analyst, tracked all stages of training across internal functions and suppliers. In addition to ensuring a robust process, tracking and communicating progress to department heads, using a league table helped to build engagement and a healthy sense of competition. 

Industry collaboration: As members of ACT, Primark have clear RPP commitments in place. Participation in the LIC supported a well-rounded and considered approach to implementing these commitments and embedding positive behavioural change for the long-term. The team describe the LIC as a really useful confidential platform to exchange ideas and hear different perspectives. “It was heartening and helpful to talk through common roadblocks and how to work around them. Being in a peer group with other companies going through the same process gives you that understanding and reassurance that this isn’t something you are doing in isolation” 
Living Wage Analyst, Primark Cares 

Challenges 

A significant challenge, when rolling out training to a global supply base, was ensuring attendance by the relevant people. For the itemised costing training to be meaningful, it needed to be delivered to those directly involved in costing, on the supplier side. The Living Wage Team needed to build their understanding of their suppliers’ teams and work through the layers of job functions to find the relevant individuals to train. 

In Cambodia, Primark had the opportunity to deliver the supplier training in-person, to all their active Tier 1³ Cambodian factories. This highlighted the importance of considering the cultural and language differences across a global supply base. These sessions were translated live, to engage the Chinese factory management. 

Feedback from suppliers and internal teams 

Next steps 

Use of the itemised costing methodology is still in its early days. The steps being taken by the team aim to ensure understanding of RPPs and positive behaviours are implemented for the long-term and are helping Primark to deliver on Primark’s commitment to pursue a living wage. The team intend to continue monitoring use of the methodology and embedding of RPPs. In addition, the 2025 ACT Brand and Supplier survey will provide Primark with insights on how they are progressing from both an internal and external perspective. These insights will support the development of a roadmap for the future. 

1. The LIC was funded by the Initiative for Global Solidarity (IGS) implemented by Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH (supported by the German Federal Ministry for Economic Cooperation and Development) and the Sustainable Textile Initiative: Together for Change (STITCH) (supported by the Dutch Government)
2. The Common Framework for Responsible Purchasing Practices was developed in 2022 by the Ethical Trading Initiative, Ethical Trade Norway, the German Partnership for Sustainable Textiles (PST) and Fair Wear. The CFRPP is supported as the central reference point on purchasing practices in the garment industry by ETI, ET Norway, Fair Wear, PST, Solidaridad, Ethical Trade Denmark and the Fair Labor Association
3. Tier 1 - Factories manufacturing finished goods.