About this question 

This question asks for evidence that senior leadership/the board of your company has gone through a formal process of considering the effectiveness of its corporate governance policies and procedures, in order to identify areas of risk that require additional controls or mitigation.

This may happen at Board or senior leadership level, perhaps under the control of a chairperson, with support from the Company Secretarial team, General Counsel, legal advisor or other role responsible for governance at corporate level. Within large groups of companies, this may happen at Group level. In smaller companies this task could be the responsibility of the executive leadership team/committee.

• Answer yes if your company has considered and documented its assessment of corporate governance risks
• Answer no if your company has not assessed its corporate governance risks, or if risks have been considered informally but not documented

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_MQ

Evidence

Either

• Link to published outputs of corporate governance risk assessment process (e.g., ESG strategy or report, corporate governance report, corporate website, Annual Report and Accounts)

or

• Internal risk assessment documentation

and

• Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, board meeting papers)

About this question 

Risks change over time and a new risk assessment should be carried out following changes in business activity or external circumstances. This question asks if there is a process to define when the risk assessment needs to be updated (e.g., during an acquisition, or when entering a new market). Having a process of review, including identification of the factors that should trigger a review enables the company to adapt to regulatory changes, ensuring both legal compliance and best practice.

There could be a scheduled regular risk assessment (e.g., annually), with additional assessments required as part of any change process, such as entering a new market.  This task could be delegated to an accountable individual, department, or board/management committee.  Additionally, the company could outsource or use an advisor to provide regular risk updates or ‘horizon scanning’ for governance risks on behalf of the organization.

• Answer yes if your company has a documented process by which the board/senior leadership identifies the need for a corporate governance risk assessment
• Answer no if your company does not have a documented process by which corporate governance risks are assessed in an appropriately timely manner

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_Mg

Evidence

Either

• Link to published risk assessment policy indicating how often and when risk assessments are carried out  (e.g., Corporate Governance section of company website, Annual Report and accounts)

or

• Internal risk assessment policy and process documents, indicating how often and when risk assessments will be carried out

and

• Evidence of oversight by board/senior leadership (e.g., Director/General Counsel signature, ESG Committee minutes, Board papers)

About this question 

Policies that state a commitment to legal compliance and risk mitigation are a critical component of corporate governance. This question is looking for a high level policy or commitment approved by the board or senior leadership, that describes how the company will comply with the law, act with integrity and address governance risks it has identified – this could include a commitment to make resources available, allocating responsible persons, defining the process by which risks will be assessed or mitigated, and how they will be reported on.

• Answer yes if you are able to provide evidence of high level corporate governance statements, commitment or policies that outline how your company  commits to managing corporate governance compliance and risks
• Answer no if there is no policy of this nature available in your company, or if there has been no formal adoption of a similar policy by the board

CSRD: 

Companies are advised to confirm compliance with specific legal requirements for whistleblower protection relevant to their jurisdiction, such as Directive (EU) 2019/1937 or equivalent.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_Mw

Evidence

Either

• Link to published corporate governance policy, statement or group of policies on company website

or

• Internal (i.e unpublished) policy dated and signed on behalf of the board / senior leadership

and

• Screenshots demonstrating how unpublished policies are made available to stakeholders (e.g., employee intranet, supplier portal)

Note: Policies can be standalone or combined. For example, a company’s published Code of Ethics could be a standalone statement, but could also contain within it, an Anti-Bribery and Corruption Policy and a Gifts and Hospitality Policy. The relevant section of the document should be indicated to the verifier, e.g., page or section number.

About this question 

Policies that set out your company’s approach to all of these topics form the basis of a strong corporate governance approach, providing a framework and enabling the company to manage regulatory compliance. This question is looking for detailed, published policies that are approved at Board/Senior leadership level, and for which the board is held accountable.

• Select Board and senior leadership composition if you can provide evidence of a Board or Senior Leadership Composition policy. This is a policy that sets out how the board/leadership group is structured.
• Select Board or senior leadership management and accountability if you can provide evidence of a policy that describes how your company holds itself and its officers accountable to stakeholders. This will include its accountability for ESG matters and may include responsibilities of specific board or leadership roles, as well as responsibilities of the board as a whole.  It is likely to set out what the company means by ‘transparency’ and what will be placed in the public domain.
• Select ESG performance and incentives if you can provide evidence of a policy demonstrating how employee and/or director compensation is linked to achievement of ESG goals and KPIs
• Select anti-corruption and bribery if you can provide evidence of a published policy that sets out the rules and procedures by which employees and others engaged by your business should handle unlawful practices
• Select anti-competition if you can provide evidence of a published policy that sets out the rules and procedures by which the company competes fairly within its market – for example, avoiding price-fixing, cartels, or abuse of market power
• Select Tax Contribution if you can provide evidence of a published policy that sets out how the company ensures compliance with tax regulation in the territories where it has a presence
• Select Responsible lobbying and policy influencing if you can provide evidence of a published policy that sets out how the company, its employees and directors engage in activities to influence public policy in a way that is transparent, accountable, consistent and legitimate
• Select Data Privacy protection if you can provide evidence of a published policy that describes how your company complies with regulations on the secure collection, storage and use of personal data
• Select Stakeholder Engagement if you can provide evidence of a formal document that outlines your company’s commitment and approach to inclusive stakeholder engagement
• Select Sustainable Investment and innovation if you can provide evidence of a formal policy or commitment to making investments, or funding innovations that drive corporate or industry-wide progress in ESG
• Select none if you cannot provide evidence of your governance policy covering any of the topic areas listed.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_NA

Evidence

Either

• Link to published policies on company website. There should be a policy or statement for each of the topics selected.

or

• Internal (i.e unpublished) policy for each of the topics selected, which should be dated and signed on behalf of the board / senior leadership

and

• Screenshots demonstrating how unpublished policies are made available to stakeholders (e.g., employee intranet, supplier portal)

Note: Policies can be standalone or combined. For example, a company’s published Code of Ethics could be a standalone statement, but could also contain within it, an Anti-Bribery and Corruption Policy and a Gifts and Hospitality Policy. The relevant section of the document should be indicated to the verifier e.g., page or section number

About this question 

Policies provide the basis of the company’s approach to all its stakeholders.  It is important that diverse stakeholder perspectives are taken into account when policies are established.  This can include terminology and language used, as well as content. For example, the policy may require existing policies to be updated in line with updated approaches and regulations (e.g., not assuming a single gender applies to a particular role). Consideration of the applicability of human resources policies to all genders/ages (and other characteristics) should be embedded within this commitment. This question asks if there is a high-level corporate commitment to a process that ensures all the company’s policies are inclusive, rather than examples of specific policies which are deemed to be inclusive.

• Answer yes if you can provide evidence that your company has a policy or systematic process in place to ensure that diversity, equity and inclusion are embedded in your company’s approach to developing corporate policies
• Answer no if there is no such policy or process in place

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_NQ

Evidence

Either

• Link to published policy, process or guidelines indicating the means by which your company ensures that the language, content and intention of all its policies is inclusive  (e.g., Corporate Governance section of company website, Annual Report and accounts, HR Report, ESG Report)

or

• Internal policy, process or guidelines indicating the means by which your company ensures that  the language, content and intention of all its policies is inclusive

and

• Evidence of oversight by board/senior leadership (e.g., Director/General Counsel signature, ESG Committee minutes, Board papers)

Additional supplementary evidence:

• Training materials provided to employees responsible for producing corporate governance policies
• Examples to illustrate how governance policies have been revised to incorporate inclusive language and content

About this question 

This question seeks evidence of a set of principles that guide corporate behavior and decision-making, ensuring that the organization operates with integrity. A Code of Business Ethics (or equivalent policy) is a high-level statement outlining the fundamental principles that steer the company’s actions. These principles may include commitments to respect, dignity, legal compliance, transparency, honesty, and integrity in decision-making—essentially a pledge to ‘do the right thing.’

Codes of Business Ethics should align with international laws, such as the United Nations Convention Against Corruption. Companies should also have additional procedures in place for identifying, reporting, and investigating potential or actual breaches of the code. These mechanisms should be accessible to both internal and external stakeholders.

• Answer yes if you can provide evidence of a published statement of corporate ethics as described
• Answer no if there is no such policy in place, or if the policy is not published

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_Ng

Evidence

Either

• Link to published corporate Code of Ethics/Business Integrity or equivalent policy/group of policies on company website. This question refers to a Code guiding corporate behavior, rather than employee conduct

or

• Internal (unpublished) Code of Ethics dated and signed on behalf of the board / senior leadership

and

• Screenshots demonstrating how unpublished policies are made available to stakeholders (e.g., supplier portal, employee intranet).

Note: Policies can be standalone or combined. For example, a company’s published Code of Ethics could be a standalone statement, but could also contain within it, an Anti-Bribery and Corruption Policy and employee facing versions of the ethical code, and guidance on specific situations such as Gifts and Hospitality Policy. The relevant section of the document should be indicated to the verifier, e.g., page or section number.

About this question 

A Code of Ethics outlines detailed rules and expectations to guide employees in appropriate workplace behavior. It may function as a standalone policy, be included in an employee handbook, or serve as an appendix to the corporate Code of Ethics referenced in GG06. The document may also refer to or integrate other governance policies such as Anti-Bribery Or Anti-Competition frameworks. Examples of a wide-range of likely content include – dealing with conflicts of interest, fairness in decision-making, communication, expectations of conduct, illegal activities such as fraud, corruption, discrimination,harassment and abuse.

Codes of business conduct and associated guidance should align with international laws, including the United Nations Convention Against Corruption. companies are expected to establish mechanisms for internal and external reporting and to investigate breaches of the code. These mechanisms must be accessible to all stakeholders.

• Answer yes if you can provide evidence of an Employee Code of Conduct or equivalent
• Answer no if your company does not have this policy or equivalent

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_Nw

Evidence

Either

• Link to published Employee Code of Ethics / Ethical Code or equivalent policy/group of policies on company website. This question refers to guidance for employees on expected behaviors in workplace situations

or

• Internal (unpublished) Employee Code of Ethics / Ethical Code dated and signed on behalf of the board / senior leadership

and

• Screenshots demonstrating how unpublished policies are made available to stakeholders (e.g., employee intranet, employee handbook)

Additional supplementary evidence:

• Induction, training or communications materials used to inform employees of the requirements of the Employee Code of Conduct

About this question 

Like other corporate policies, an ESG policy creates a shared vision of ESG issues within the business context. By formalizing its approach to ESG at the corporate level, the company is in a position to manage ESG risks, and to understand the relationship between ESG priorities and its other business activities and strategies.  It also supports accountability for ESG at board/senior management level. A published ESG policy is a transparent way of communicating priorities with stakeholders.

The company should be able to provide a diagram of its ESG governance structure that Identifies accountable individuals and governing bodies, and demonstrates how the Board delegates specific ESG responsibilities to entities such as executive committees or ESG steering groups.

• Answer yes if you can provide evidence of a published ESG policy, commitment or equivalent statement (high level corporate policy)
• Answer no if your company has no evidence of such a commitment

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_OA

Evidence

Provide

• Link to published ESG policy, statement or group of policies on company website.

• A governance structure document providing information on accountable bodies and individuals in relation to ESG.

Note: Policies can be standalone or combined. For example, a company’s published Code of Ethics could be a standalone statement, but could also contain within it, an Anti-Bribery and Corruption Policy and a Gifts and Hospitality Policy. The relevant section of the document should be indicated to the verifier, e.g., page or section number

About this question 

Companies have significant influence over supply chains other than those related to product/textile manufacturing. This question asks whether your company’s environmental and social policies are also reflected in responsible procurement policies across the entire company including GNFR (Goods Not For Resale).

Non-stock supply chains can involve significant environmental and social risks and opportunities. Examples of sectors include purchases of technology, third-party logistics, facilities services, infrastructure, vehicles, energy, office materials, catering and machinery.

A responsible procurement or purchasing policy for these types of goods and services seeks to ensure that your company’s environmental and social commitments are reflected in this type of procurement and not exclusively in the purchase of product and stock.

• Answer yes if your company has a responsible procurement policy in place which is applicable to all non-stock GNFR purchases
• Answer partial yes if your company’s responsible procurement policy is applicable to specific products or services only
• Answer no if there are no policies in place to guide responsible procurement of non-stock/GNFR purchases

Procurement policies for product and stock are not applicable here – please see the Worker section of the BRM.

Evidence

Either

• Link to published responsible procurement guidelines or policy, referring to the way that goods and services not for resale are purchased  (e.g., logistics providers, technology, facilities and equipment)

or

• Internal (i.e unpublished) policy dated and signed on behalf of the board / senior leadership

and

• Screenshots demonstrating how unpublished policies are made available to stakeholders (e.g., in requests for quotation, employee intranet, supplier portal)

Note: Responsible Purchasing Practices related to stock and products are dealt with separately in the BRM.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_OQ

About this question 

This question asks your company to demonstrate that its management or board structure is robust and regulated by a formal policy.

A policy that sets out the rules and processes that inform Board Structure and Composition is one way that companies demonstrate robust management to their stakeholders. Some elements of board structure may be set by national law, and by the organization’s governance, and others can be developed through a robust policy.

To evaluate the effectiveness of the policy, companies should have clear KPIs in place to track progress and measure outcomes related to board composition and diversity.

• Answer yes if you can provide evidence of a Board Structure and Composition policy or equivalent document
• Answer no if your company does not have a policy that defines and sets out the structure and composition of its Board or management

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_MTA

Evidence

Either

• Link to published Board Structure and Composition policy or equivalent document on company website

or

• Internal (i.e unpublished) policy dated and signed on behalf of the board / senior leadership

and

• A document providing a breakdown of membership of the board and executive team during the reporting period, such as the number of executive and non-executive members, Representation of employees and other workers, experience relevant to the sectors, products, and geographic locations of the company, percentage by gender and other aspects of diversity that the company considers, the board’s gender diversity shall be calculated as an average ratio of female to male board members or the percentage of independent board members.

Additional supplementary evidence:

• Training materials for procurement team members, and others responsible for purchasing non-stock goods and services
• Guidance on responsible procurement principles produced for potential suppliers, used to accompany requests for tender/requests for quotation

About this question 

This question evaluates whether your company has embedded the identification, assessment, and management of sustainability-related impacts, risks, and opportunities into its overall risk management and strategic decision-making processes. Integration implies that sustainability considerations are not treated as separate processes but are incorporated into the company’s standard procedures for risk management, governance, and decision-making.

Integration of impacts and risks into the company’s risk management framework involves assessing how thoroughly sustainability risks are considered alongside traditional financial and operational risks. Companies should describe the methodologies, tools, or systems they use to ensure sustainability risks are part of their risk assessments, registers, and reporting mechanisms. It is also important to outline how these risks influence the company’s overall risk profile, including their impact on risk appetite, thresholds, and mitigation strategies.

Sustainability opportunities should be integrated into the company’s strategic planning and decision-making processes. This includes identifying and prioritizing these opportunities and using them to guide business development, innovation, and investment decisions. The role of sustainability opportunities in performance management and goal setting should also be highlighted.

Governance and oversight play a crucial role in ensuring integration. Companies should describe the roles and responsibilities of key actors, such as board committees, executive leadership, or risk management teams, in embedding sustainability into the organization. Relevant policies and internal controls that mandate and support this integration should also be discussed, along with mechanisms for monitoring and improving effectiveness.

To demonstrate practical application, companies should provide examples where sustainability considerations have influenced risk assessments, strategic decisions, or operational adjustments. The outcomes or benefits resulting from this integration can further illustrate the effectiveness of these efforts.

Continuous improvement is a key aspect of integration. Companies should outline how the integration process is reviewed, monitored, and adapted over time to address emerging sustainability issues and evolving stakeholder expectations.

• Answer yes if your company has integrated sustainability-related impacts, risks, and opportunities into its overall risk management and strategic decision-making processes.

• Answer no if your company has integrated sustainability-related impacts, risks, and opportunities into its overall risk management and strategic decision-making processes.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_Mu1

Evidence

Either

• Documentation of integration processes, including policies, procedures, and strategic plans showing how sustainability impacts, risks, and opportunities are integrated into business processes.

• Risk management frameworks or tools, such as risk registers including sustainability-related risks.

• Evidence of governance and oversight, including committee mandates, board or executive meeting minutes, or other documentation showing management involvement in sustainability integration.

• Examples of practical implementation, such as case studies or projects influenced by sustainability integration.

• Reports or metrics, tracking the effectiveness of sustainability integration into risk management and business processes.

• Published disclosures, such as sustainability reports, annual reports, or public statements discussing sustainability integration.

Note: unscored question

About this question 

Fashion’s impact on animals, whether through conventional sources such as wool, leather, down, cashmere, alpaca, and mohair, or through the use of fur, exotic skins, and decorative feathers, has become an increasing topic of concern. companies sourcing animal-derived materials for product or internal use should establish clear policies to ensure these materials can be traced back to producers with higher welfare standards.

An animal welfare policy should define the standards expected from employees and suppliers in the sourcing and use of animal-derived materials. Examples of policy elements include:

• Specifying materials certified to recognized animal welfare standards.
• Requiring traceable, higher-welfare materials.
• Banning fur and exotic skins.
• Investing in next-generation materials that avoid animal use altogether.

Additionally, companies should extend their policies to cover the representation of animals in marketing materials. for instance, they should avoid promoting certain dog breeds as ‘fashionable’ or depicting animals in human clothing or makeup.

• Answer yes if your company has policies in place to protect animal welfare, or if your company’s policy is to avoid all animal derived products.

• Answer no if your company has no animal welfare policies in place.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gg_Mu2

Evidence

Either

• A link to published animal welfare policy/policies.

or

• Internal animal welfare policies with evidence of board approval.

and

• Information on how the policy is tracked and monitored.

Note: unscored question