To the management of Marks and Spencer Group plc
The Marks & Spencer Plan A Report 2013 (the Report) has been prepared by the management of Marks and Spencer Group plc, which is responsible for the collection and presentation of the information within it. Our responsibility, in accordance with management’s instructions, is to carry out a ‘limited level’ assurance engagement on the report. We do not accept or assume any responsibility for any other purpose or to any other person or organisation. Any reliance any such third party may place on the report is entirely at its own risk.
What we did to form our conclusions
Our assurance engagement has been planned and performed in accordance with ISAE30001 and to meet the requirements of a Type 2 assurance engagement as defined by AA1000AS (2008)2. The AA1000AS (2008) assurance principles of Inclusivity, Materiality and Responsiveness have been used as criteria against which to evaluate the Report.
In order to form our conclusions we undertook the steps outlined below:
Reviewed progress made in relation to selected Plan A commitments.
Included within our review were the following commitments:
- 1.2 Number of Products with Plan A attributes,
- 1.3 Identifying Plan A products,
- 2.3 Marks & Start,
- 3.1 My Plan A,
- 3.2 Plan A marketing,
- 4.3 Paid volunteering,
- 4.4 Customer Assistant Training,
- 4.5 Employee feedback on communications,
- 4.6 Employee feedback engagement,
- 4.9 All store reporting of H&S incidents,
- 5.1 Business case,
- 7.3 Food Supplier Plan A benchmarking,
- 7.5 Sustainable farming,
- 7.6 General Merchandise traceability,
- 9.2 Efficient packaging,
- 10.4 Carbon neutral,
- 10.5 Store, office and warehouse energy,
- 10.6 Delivery efficiency,
- 10.15 Refrigeration,
- 11.2 Food supplier energy performance,
- 12.2 Recycle 20m garments,
- 12.13 Reducing carrier bags,
- 13.1 Reducing M&S waste by 25%,
- 13.3 Reducing construction waste,
- 13.5 Zero waste to landfill,
- 13.7 Food waste to recycling,
- 13.8 Zero landfill construction,
- 14.2 Reducing landfill at food suppliers,
- 15.2 Reducing M&S water usage,
- 16.1 Water efficiency with food suppliers,
- 16.2 Sustainable farmed fish,
- 16.11 Pesticide Residue-free food,
- 16.15 Sustainable cotton,
- 16.16 Deforestation,
- 16.17 Sustainable wood,
- 16.18 Sustainable sea fish,
- 16.25 Supplier water efficiency,
- 17.1 Living wage,
- 17.6 Food supplier HR performance,
- 17.13 Helping suppliers address ethical issues,
- 17.19 Fairtrade food,
- 18.1 Improve nutritional food content,
- and 19.1 Nutritional labelling.
Reviewed Marks and Spencer’s approach to stakeholder engagement
through interviews with management and employees. Our discussion with employees focused on the following areas: Employee feedback, Sustainable farming, Efficient packaging, Deforestation (Palm and soy) and Living wage. We also reviewed selected associated documentation on stakeholder engagement, including meeting minutes from Marks and Spencer’s Sustainable Retail Advisory Board, and attended the annual stakeholder event.
Reviewed the coverage of material issues
within the Report against key issues and areas of performance covered in external media reports and the sustainability reports of Marks and Spencer’s peers; selected outputs from stakeholder engagement activities; and the topics discussed by Marks and Spencer’s Plan A Governance forums.
For the selected Plan A commitments we:
Interviewed a selection of Marks and Spencer managers responsible for managing progress towards the commitments
to understand current performance and the mechanisms for measuring progress.
Reviewed relevant documentation,
such as guidance documents, status reports, meeting minutes and independent third party reports, for consistency with claims of progress made.
Reviewed the Report for the appropriate presentation of the data
including the discussion of limitations and assumptions relating to the data presented.
Level of assurance
Our evidence gathering procedures have been designed to obtain a limited level of assurance (as set out in ISAE3000) on which to base our conclusions. The extent of evidence gathering procedures performed is less than that of a reasonable assurance engagement (such as a financial audit) and therefore a lower level of assurance is provided.
The limitations of our review
- We have not tested source data used to compile Group-level performance updates on the Plan A commitments.
- We did not interview Marks and Spencer employees at stores or warehouses.
- Our assessment of materiality has focused on the topics addressed by Marks and Spencer’s Plan A.
Based on the scope of our review our conclusions are outlined below:
Has Marks and Spencer engaged with stakeholders to seek feedback on and refinement of Plan A?
- We are not aware of any key stakeholder groups which have been excluded from engagement.
- We are not aware of any matters that would lead us to conclude that Marks and Spencer has not applied the inclusivity principle in developing its approach in relation to Plan A.
Has Marks and Spencer provided a balanced representation of material issues concerning its performance against Plan A?
- We are not aware of any material aspects concerning Marks and Spencer’s performance against Plan A which have been excluded from the report.
- Nothing has come to our attention that causes us to believe that Marks and Spencer management has not applied its processes for determining material issues to be included in the report, as described in About this report.
Has Marks and Spencer responded to stakeholder concerns and feedback on Plan A?
- We are not aware of any matters that would lead us to conclude that Marks and Spencer has not applied the responsiveness principle in considering the matters to be reported with regards to the performance update on Plan A.
Completeness and accuracy of Performance Information
How complete and accurate are the performance data and claims for the selected 43 Plan A commitments (listed above).
- Nothing has come to our attention that causes us to believe that the data relating to the selected 43 Plan A commitments has not been collated properly from Group-wide systems.
- We are not aware of any errors that would materially affect the data as presented in the report for the selected 43 Plan A commitments.
- We have reviewed the performance update against the selected 43 Plan A commitments and we are not aware of any misstatements in the assertions made.
Observations and areas for improvement
Our observations and areas for improvement will be raised in a report to Marks and Spencer management. Selected observations are provided below. These observations do not affect our conclusions on the report set out above.
- Marks and Spencer is continuing to make progress on a number of its commitments, particularly water usage reduction and number of Plan A products. However, for some commitments classified as ‘On plan’ such as Sustainable farming, we encourage Marks and Spencer to articulate more clearly how it is making progress towards its 2015 target. For example, more clarity could be provided on how the engagement with farmers is improving performance in areas such as efficiency, environment and ethical practice.
- There has been relatively limited progress against some of the commitments reported as ‘On plan’ this year, such as the commitment to increase customers’ clothes recycling and helping our customers to identify Plan A products. We encourage Marks and Spencer to consider how it will describe its position on these commitments in the future if ultimately they are too challenging to meet.
- Progress has been made in implementing Plan A benchmark standards with food suppliers this year, notably the improved process for collecting and validating submissions from food suppliers. However, we encourage Marks and Spencer to continue developing the process for scoring these submissions, in order to monitor progress against the commitment to engage all food suppliers and ensure that 25% by turnover will be at Gold level by 2015.
Under forthcoming UK regulations, Marks and Spencer will be required to incorporate its growing international operations within the scope of its reporting on carbon emissions. As Marks and Spencer continues increasing its footprint beyond the UK and Ireland, it should also consider extending the reporting of performance on other Plan A aspects from its international operations.
Our independence and experience
This is the tenth year Ernst & Young LLP has provided independent assurance services in relation to Marks and Spencer’s How we do business Report. We have provided no other services relating to Marks and Spencer’s reporting of social, environmental and ethical matters.
Our assurance team has been drawn from our global environment and sustainability network, which undertakes similar engagements to this with a number of significant UK and international businesses.