Burberry Chemical Management Report 2020

BURBERRY CHEMICAL
MANAGEMENT PROGRAMME
2020 UPDATE
REPORT BY PHIL PATTERSON, COLOUR
CONNECTIONS CONSULTANCY LTD
BURBERRY CHEMICAL MANAGEMENT PROGRAMME 1

FOREWORD
At Burberry, we continue to deliver on our commitment

to eliminate the use of chemicals that may have
a negative environmental impact, going beyond the
required international environmental and safety standards.
In recognition of this, and aligned with our commitment

to Greenpeace, we commissioned this external review of
our chemical management programme during 2020 to verify
achievements and identify opportunities for improvement. The
following report details the findings of the independent review.

AUTHOR’S NOTE
In order to complete this report, I was granted access to Burberry systems, databases,
teams and suppliers.
I conducted face to face interviews with team members from all key disciplines
in the London head office and in the regional office in Italy and these were supported
by detailed questionnaires.
I also interviewed key vendors and raw material suppliers one-on-one, both in an office
setting and during a factory assessment, and they were clearly able to speak openly
and honestly about their relationship with Burberry and the positive and negative
aspects of the chemical management programme and the approach adopted.
In nearly 25 years of managing restricted substances in brands and supply chains I have
almost always encountered a level of push back from commercial and creative disciplines
that undermines the efforts of chemical management teams to some extent.
At Burberry I experienced almost complete buy-in to the concept that all components
must meet the business standards and an acceptance that it was reasonable to demand
more stringent standards than required by law or by mainstream fashion brands.
Similarly, with vendors and raw material suppliers, there is an acceptance that what
Burberry is trying to achieve, and how they are trying to achieve it, is reasonable and
they are pleased to be part of it. Several commented to me that they believe Burberry
is ahead of the curve and working with them to these exacting standards future proofs
their business to some extent.
Most vendors and raw materials suppliers commented that they were very appreciative
of the fact that engagement with Burberry had improved their business but they would
struggle to assign adequate resources to have similar levels of engagement with other
brands.
In common with many wider sustainability initiatives, there is praise and criticism for
the Burberry Partner Progress Tool (PPT), which has been developed to measure supply
chain performance, with some calls for improvements to the scoring system. In my
experience, the assessment criteria of such schemes are usually sound but there are
always flaws with scoring systems, and they need constant review and refinement.
Ongoing, excellent performance rarely happens without being underpinned by robust
management systems but the balance of scoring between written management systems,
training and activities and resulting performance must be monitored.
Burberry has deliberately described the PPT as a ‘tool’ and, provided it is used in a
mature way to highlight opportunities to improve, rather than attaining the best score,
then it will be beneficial.
In my opinion Burberry is doing a very good job in terms of progressive chemical
management and this is only possible because they do a very good job in maintaining
a small, stable, transparent supply chain with whom they can communicate quickly,
clearly and easily. I can attest to the fact that the supply base is significantly more
consolidated than most clothing brands of a similar size.
Phil Patterson
3
02 FOREWORD
03 AUTHOR’S NOTE
05 BACKGROUND
07 THE BURBERRY SUPPLY CHAIN AND

HOW STANDARDS ARE IMPLEMENTED
10 IMPLEMENTATION OF STANDARDS
INTO THE BUYING PROCESS
12 BURBERRY REQUIREMENTS
12 PARTNER PROGRESS TOOL

(PPT) ASSESSMENT

14 ENGAGEMENT AND TRAINING
15 PRODUCT RESTRICTED SUBSTANCES

LIST (PRSL) COMPLIANCE
17 RESULTS FROM DUE DILIGENCE TESTING

19 INDUSTRY PARTICIPATION
19 MANUFACTURING RESTRICTED
SUBSTANCES LIST (MRSL)
20 WASTEWATER GUIDELINES (WWG)
24 STAKEHOLDER RESPONSES
24 SURVEY AND INTERVIEW SUMMARY
29 SUMMARY AND CONCLUSIONS
32 APPENDICES
32 DUE DILIGENCE TEST RESULTS

36 BULK TEST RESULTS
37 SURVEY RESPONSES – SUPPLY CHAIN
42 SURVEY RESPONSES – EXTERNAL
45 GLOSSARY
BACKGROUND
In 2014, Burberry made a commitment to eliminate chemicals that may have a negative
environmental impact used in the manufacture of clothing, footwear and accessories1.
Simultaneously, the business also committed to greater supply chain transparency and
to drive systemic change in the supply chain in order to achieve those goals.
Over the past six years Burberry has created, developed or adopted four key standards
which their partners are expected to meet on an ongoing basis – along with supporting
training programmes to eliminate chemicals of concern.
“BURBERRY’S COMMITMENT TO
MEET ITS OWN STANDARDS AND
POLICIES IS VERY EVIDENT”
THIRD PARTY VENDOR/SUPPLIER*
1. T
he Product Restricted Substances List (PRSL) – provides maximum allowable
limits for the presence of chemicals which can be present in components in
finished products
2. T
he Manufacturing Restricted Substances List (MRSL) – Burberry adopted
the ZDHC MRSL with an addendum restricting the full list of Per- and Poly-
Fluorinated Chemicals. These limits are applicable for chemicals which can
be present in formulations
3. T
he ZDHC wastewater guidelines (ZDHC WWG) – The WWG has limits for
‘conventional parameters’ such as pH, Temperature, Biological Oxygen Demand
(BOD), Chemical Oxygen Demand (COD) and Total Suspended Solids (TSS)
among others, and a non-detection requirement also for all MRSL chemicals
4. B
urberry Partner Progress Tool (PPT) assesses in-factory equipment and
management systems for storage, dispensing and handling of chemicals, as well
as procuring compliant raw materials/chemicals, upstream supplier/sub-contractor
performance, and due diligence product testing.
This report considers the progress against these standards. It also considers how
Burberry is performing with respect to driving systemic change via a collaborative
approach. Interviews and questionnaire-based surveys have been conducted with
Burberry colleagues, suppliers and other key stakeholders to gauge satisfaction
with the Burberry approach and highlight opportunities for improvement.
*Note: All quotes in this report are taken from answers given in an anonymous survey that was shared with the Burberry Supply Chain
and other external stakeholders
1
https://www.burberryplc.com/content/dam/burberry/corporate/Responsibility/Responsibility_docs/Policies_statements/Chemical_
Management/2014/burberry-commitment-on-chemical-management-in-manufacturing.pdf

THE BURBERRY SUPPLY CHAIN AND
HOW STANDARDS ARE IMPLEMENTED
Annually, there are several product collections and Burberry ensures details of
every component in every style is recorded on Product Lifecycle Management (PLM)
software – this includes all components including main materials, linings, and trims
(including textile, leather, metals and plastics).
With certain sustainability parameters it is not uncommon for companies to report
on selective progress and successes without putting them in the context of the wider
supply chain performance.
With a focus on only finished product compliance it is theoretically possible to focus
solely on the finished components and products but, when MRSL compliance (chemical
inventories in factories) and wastewater are considered, there is a requirement to
consider all manufacturing facilities' activities and their input management and output
compliance.
Burberry has a relatively small, relatively consolidated supply chain and very close,
direct working relationships with finished goods vendors2 and key raw material
suppliers3.
Burberry suppliers accounting for 93.5% of Burberry's annual production are actively
engaged with Burberry’s chemical management programme. The remaining suppliers,
who account for 6.5% of Burberry's annual production are managed directly or
indirectly by the Chemical Managers4 of raw material suppliers or finished goods
vendors. Burberry endeavours that Chemical Managers are trained by Burberry or
through third parties, such as the ZDHC Academy5.
“THE BURBERRY TEAM IS

THE MOST ENGAGING TEAM
I AM WORKING WITH”
THIRD PARTY VENDOR/SUPPLIER
2
Finished goods vendors considers Tier 1 facilities that produce finished product such as Apparel, Soft Accessories, Hard Accessories
and Footwear for Burberry
3
Raw material suppliers are suppliers who provide textile, leather and other materials such as polyurethane and may be a vertical
organisation that conducts wet processing in-house, or a company that subcontracts wet processing on their behalf
4
Chemical Manager refers to the person responsible for implementing chemical management in their own facility and upstream partner/
sub-contractor facilities and acts as the point of contact to Burberry
5
https://academy.roadmaptozero.com/

120 99.4%
OF INDIVIDUAL MRSL
THE LENGTH OF YEARS
SUBSTANCES ARE
WORKING WITH ONE
NOT DETECTED
FINISHED GOODS VENDOR
IN WASTEWATER*
85 91%
OF BURBERRY'S
THE NUMBER OF
PRODUCTION IS FROM
RESPONDENTS
SUPPLIERS WITH
TO THE SURVEY
CHEMICAL TRAINING
2016 164
2016 THE YEAR THE NUMBER OF CHEMICAL
BURBERRY ELIMINATED MANAGEMENT ASSESSMENTS
SHORT CHAINED PFCS BURBERRY HAS PERFORMED
FROM PRODUCTION (2019 – 2020)
99.25% 1700
OF INDIVIDUAL BULK THE NUMBER OF CHEMICAL
TESTS WITH NO FORMULATIONS TESTED
CHEMICAL FAILURES** USING CHEMIQ
*Details found on page 21

**Details found in Appendix 2
“IT IS CERTAINLY THE BRAND
THAT HAS DRIVEN THE MOST
CHANGE, NOT ONLY ON PAPER…”
91% OF TIER 1
PRODUCERS HAVE
82% OF TIER 1
WORKED WITH
PRODUCERS HAVE 1 TIER 1 PRODUCER
BURBERRY SINCE
WORKED WITH HAS WORKED WITH
THE 2014 LAUNCH
BURBERRY FOR BURBERRY SINCE 1900
OF ITS CHEMICAL
OVER 10 YEARS
MANAGEMENT
PROGRAMME
Note: In this report progress is described in terms of numbers of finished goods vendors, raw material suppliers, or wet processors and
also in terms of ‘units’ supplied. This refers to stock units such as a pair of shoes, a coat etc. The figures would be different if reported
by value or by weight of materials.
This stable, small and consolidated supply chain is key to Burberry’s collaborative
approach to chemical management for a number of reasons:
– Direct relationships: It is possible to communicate standards and expectations
directly to those involved in the selection and use of chemicals and ensure
appropriate training is undertaken
– Stability: It is possible to work on longer term improvement initiatives by providing
confidence to suppliers that they will remain part of the Burberry supply chain
The ability to communicate directly, quickly, easily and effectively with partners has
enabled Burberry to explain not just what is required in terms of compliance but why
it is required, and how it may be achieved.
Via education and training, the intention has been to change the mind-set of supply
chain partners from doing what they are told to do, to doing what they know to be
the right thing to do.
“BURBERRY HAS
POSITIVELY STIMULATED
ITS SUPPLY CHAIN”

IMPLEMENTATION OF STANDARDS IN THE BUYING PROCESS
Burberry places orders with established vendors and raw material suppliers who are
fully conversant with the standards and expectations related to chemical management.
When a new partner is introduced into the business there is an established onboarding
process and Burberry’s sourcing and procurement departments arrange onboarding in
partnership with the Burberry Responsibility team and chemical management team. All
new partners must be approved and Burberry must be satisfied with the commitment
of the partner to the Burberry Responsible Business Principles6 before commencing
production.
“BURBERRY CREATED AN
INTERNAL TEAM THAT HAS
SIGNIFICANT IMPACT ON
SUPPLIER SELECTION AND
BUSINESS STRATEGY”
EXTERNAL RESPONSE
Burberry normally nominates the raw materials with which finished goods must be
made and they will almost always be from established component suppliers who are
fully conversant with the standards and expectations related to chemical management.
Burberry is a design-led company but all components in samples and bulk production
must be compliant with the PRSL and all facilities must be compliant, or working towards
compliance with MRSL, ZDHC WWG and the Burberry Partner Progress Tool (PPT).
Where a vendor, raw material supplier or specific wet processing facility fails to meet
expectations and demonstrates a poor attitude to improvements or remediation the
chemical management team are empowered to work with sourcing and procurement
departments to take business decisions accordingly.
“BURBERRY HAS BEEN

A PIONEER BRAND IN
ZDHC MANAGEMENT,
INVOLVING AND ENGAGING
THE SUPPLY CHAIN”
6
https://www.burberryplc.com/content/dam/burberry/corporate/Responsibility/Responsibility_docs/Policies_statements/Policies/Up-
dated_Policies/RESPONSIBLE%20BUSINESS%20PRINCIPLES%20-%204.%20Burberry%20Partner%20Non-Compliance%
20Policy.pdf

BURBERRY REQUIREMENTS
PARTNER PROGRESS TOOL (PPT) ASSESSMENT

In 2016, Burberry developed and launched an assessment protocol for both vendors
and raw material suppliers, which was updated and publicly7 released in 2019.
Burberry uses a “traffic-light” scoring system of Red, Amber and Green ratings and sets
corrective actions to ensure continuous improvements. Ultimately the scoring system
influences sourcing and procurement decisions, and Burberry leaders responsible for
vendor and raw material supplier selection have personal objectives set against the
chemical management performance of their vendors and raw material suppliers.
Vendors and raw material suppliers with poor scores should demonstrate improvements
to Burberry but long-term failure to do so may result in future orders being jeopardised.
Concerns have been raised that orders can be placed with Red-rated facilities. Burberry
currently expects corrective action plans to be in operation in such circumstances and
there is a target to have no Red-rated facilities by 2022. This forms part of Burberry’s
wider responsibility targets, whereby 100% of product must have at least one
positive attribute by 20228. A positive attribute relates to social and/or environmental
improvements achieved at either raw material sourcing or product manufacturing stage.
“IT DOES HIGHLIGHT AREAS

FOR IMPROVEMENT, BUT THE
TRAFFIC-LIGHT SCORING
APPROACH CREATES AN
EMPHASIS ON THE SCORE
RATHER THAN IMPROVEMENT”
Burberry has developed a “Chemical Manager Qualification”, where Chemical Managers

who have demonstrated excellent understanding of the PPT Assessment can become
accredited by Burberry to perform PPT assessments on behalf of Burberry. This process
involves training, shadowing of Burberry or other third parties on PPT assessments, and
gap analyses of scores to prove understanding.
To achieve a Green rating, a score of 70% or above must be achieved. A Red rating is
assigned to any score below 50%.
7
https://www.burberryplc.com/content/dam/burberry/corporate/Responsibility/Responsibility_docs/Policies_statements/Chemical_
Management/2019/Burberry%20Partner%20Progress%20Tool%20Use%20Guidance.pdf
8
https://www.burberryplc.com/en/responsibility/creating-tomorrows-heritage.html

PARTNER PROGRESS TOOL ASSESSMENTS9
95� 92�
OF UNITS COVERED
% OF UNITS COVERED
BY RAW MATERIAL
BY VENDORS WHO HAVE
SUPPLIERS WHO HAVE
COMPLETED ASSESSMENT
COMPLETED ASSESSMENT
PARTNER PROGRESS TOOL GRADINGS 10
% YET TO BE GRADED
%GREEN %AMBER %RED AGAINST LATEST PPT
CRITERIA*
APPAREL AND SOFT

88 5 7
ACCESSORIES VENDORS
SHOE VENDORS 59 15 16
HARD ACCESSORIES
88 8 4
VENDORS
RAW MATERIAL
59 16 6 19
SUPPLIERS
*Some facilities have not yet been graded at all and some were previously graded using an earlier version of the PPT with slightly
different criteria to the 2019 PPT.
9
These figures do not include assessments of vendors or raw material suppliers who have had more than one PPT assessment during
this period
10
Status as of March 20

“WE CAN SAY THAT THE BURBERRY
PPT IS THE MOST PROFESSIONAL
APPROACH WE HAVE EVER SEEN”
ENGAGEMENT AND TRAINING

All partners are briefed on Burberry’s chemical management requirements. The strong,
established relationships with finished goods vendors have enabled Burberry to create
a “Chemical Manager Community”, comprised of dedicated Chemical Managers covering
98% of units produced.
The Chemical Managers are responsible for ensuring compliance, coordinating chemical
management initiatives in their organisations and supply chains, managing corrective
action plans at component suppliers and act as the primary contact for the Burberry
chemical management team.
“BURBERRY HAS INVOLVED THE

SUPPLY CHAIN RESPONSIBLY BUT
FIRMLY, THROUGH INTEGRATION
AND PARTNERSHIP SUCH AS
PARTICIPATION IN ROUND TABLES
AND CHEMICAL MANAGER MEETINGS”
Additionally, the Chemical Manager Community works collaboratively to find answers

to challenges for which there are no obvious solutions, such as highly durable, highly
repellent PFC-free finishes for rainwear. Burberry eliminated the use of all PFCs in 2016.
Burberry has developed in-house training on chemical management for the Chemical
Manager Community and they are also promoting ZDHC Academy external training.
“BURBERRY HAS MADE ITS

EXTERNAL SUPPLY CHAIN AWARE
OF ISSUES THAT WERE OTHERWISE
LARGELY UNKNOWN”

VENDOR (TIER 1 PRODUCERS) TRAINING AND SUPPORT NETWORK
% OF UNITS COVERED BY VENDORS WHO

87%
HAVE ATTENDED ZDHC TRAINING
% OF UNITS COVERED BY VENDORS WHO HAVE

93%
ATTENDED FORMAL IN-HOUSE TRAINING
% OF UNITS COVERED BY VENDORS

98%
WITH A CHEMICAL MANAGER
RAW MATERIAL SUPPLIER (TIER 2 PRODUCERS) TRAINING
% OF UNITS COVERED BY RAW MATERIAL SUPPLIERS

70%
WHO HAVE ATTENDED ZDHC TRAINING
% OF UNITS COVERED BY RAW MATERIAL SUPPLIERS

91%
WHO HAVE ATTENDED IN-HOUSE TRAINING
PRODUCT RESTRICTED SUBSTANCES LIST (PRSL) COMPLIANCE

The Burberry PRSL contains the same restricted substances as many other major
brands and multi-brand initiatives such as the AFIRM Group11. However, to accelerate
the phasing out of several key substances, the maximum allowable limits are lower for
many chemical groups in the Burberry PRSL.
Compliance with the PRSL is mandatory and, on occasions, Burberry will initiate
corrective action plans where there is a “pass” test result where a listed chemical has
been detected below the maximum allowable limit.
During the design and product development process all components must be checked
for PRSL compliance and, equally important, new vendors and raw material suppliers are
made fully aware of their responsibilities with regards to chemical management.
Despite being design-led, Burberry uses many components across multiple styles and
seasons and test results for a component are valid for 12 months provided there has been
no change to raw materials or process route/recipe.
This effectively means many products are built from compliant components from known,
established manufacturers with whom Burberry has close direct relationships.
Burberry partners are required to share a finished product or raw material test report
prior to goods leaving the factory. All chemical failures are reviewed by the Burberry
Chemical Management team, along with sourcing, procurement and regulatory and
11
https://www.afirm-group.com/wp-content/uploads/2020/03/2020_AFIRM_RSL_2020_0130_EN.pdf

compliance teams and any non-compliant results require a Root Cause Analysis and
Corrective Action.
Burberry keeps detailed records of all test data which informs their own due diligence
programmes.
Burberry requires partners to meet standards that are, in many cases, stricter than
industry norms or those required by legislation. They have done this because they
believe it is possible to eliminate the deliberate use of certain chemicals of concern by
careful selection of compliant formulations from the best chemical suppliers and careful
attention to detail.
They have, on occasions, had to involve chemical suppliers to make adjustments to their
formulations in order to make compliance with the tougher standards achievable.
For the Autumn/Winter 2019 and Spring/Summer 2020 seasons, there were 12436
individual chemical tests conducted on bulk components and finished products for priority
chemical groups. In total there were 92 failures against the Burberry standards and less
than 50 of these would have been failures against industry standards that other brands
use. Details can be found in Appendix 2.
All failures were subjected to Root Cause Analysis and Corrective Action.
BURBERRY PRODUCT TESTING AW19/SS20 COMPLIANCE
AP 99.6%
APEO 98.2%
AZO DYES 99.9%
CHLORINATED SOLVENT 92.0%
CHLOROBEZENES 96.5%
& TOLUENES
CHLOROPHENOL 98.4%
FORMALDEHYDE 99.9%
ORGANOTIN
97.2%
COMPOUNDS
PFCS 98.9%
PHTHALATES 98.0%
SCCPS 97.1%

“BURBERRY’S POLICY GOES
FURTHER THAN MOST, PUSHING
TRACEABILITY AND CHEMICAL
DUE DILIGENCE TESTING”
EXTERNAL RESPONSE
RESULTS FROM DUE DILIGENCE TESTING

Burberry has a rigorous due diligence testing programme and this is the most mature
part of the chemical management programme, which has been in place for 10 seasons
(since 2015).
Where there is confidence that particular chemicals have been successfully phased
out, the number of due diligence checks to confirm ongoing compliance has been
significantly reduced – this can however lead to increased spikes in % chemical
detections and % failures if a small number fail.
In order to demonstrate the progression of the chemical management programme it
is necessary to consider historical results and to put them in context, these can be
found in Appendix 1. Overall the failure rate of the due diligence programme has fallen
over the years, despite maximum allowable limits for several chemicals being reduced
considerably over that period of time.
For priority chemical groups included in the due diligence tests from the start of the
programme the picture is positive with decreases in both detections and failures being
observed across the board.
However, the due diligence programme is designed to seek out issues and new chemicals
are included where there are concerns. For example, chlorinated solvents were included
in the Spring/Summer 2020 programme and were detected in 22% of tests – although
the Burberry limit is many times more stringent than common RSLs for these solvents
and includes additional chemicals, this is now the subject of root cause analysis with
partners and the chemical industry.
“BURBERRY HAS HELPED THE

FASHION INDUSTRY AS A WHOLE
TAKE SOME VERY IMPORTANT
STEPS IN TERMS OF CHEMICAL
MANAGEMENT”

INDUSTRY PARTICIPATION
Burberry is a member of several independent, multi-brand initiatives including Zero

Discharge of Hazardous Chemicals (ZDHC), which Burberry is currently a board
member of.
Demonstration of compliance and transparent reporting of MRSL and Wastewater
compliance via the ZDHC Gateway is still evolving and therefore these are deemed
‘progressive standards’:
– Compliance with these standards is expected
– Compliance with these standards does not need to be demonstrated before orders
are placed, unlike the PRSL
– Burberry is progressively rolling these standards out across the wet processors and
will use the PPT to assess progress and report coverage and levels of non-compliance
– Any non-compliance will be subject to corrective action plans
“THE FIRST LUXURY BRAND TO TAKE A

CONCRETE COMMITMENT AND ACTION,
THEY OPENED THE DOORS FOR OTHERS
WHO FOLLOWED. THEY ARE THE BRAND
WHO IS RESPONSIBLE FOR MAKING THE
ITALIAN SUPPLY CHAIN A BETTER AND MORE
ENVIRONMENTALLY CONSCIOUS ONE”
EXTERNAL RESPONSE
MANUFACTURING RESTRICTED SUBSTANCES LIST (MRSL)

Burberry adopted the ZDHC MRSL12 in 2015 and partners are expected to ensure all
chemical inputs meet these requirements, plus Burberry’s restriction on the use of
PFCs.
Demonstrating compliance of a factory chemical inventory is an emerging subject and
the tools for transparent reporting of levels of compliance are in their early stages.
Prior to 2019, whilst ZDHC were developing the acceptable methods of demonstrating
chemical formulation compliance and the tools for transparent reporting, Burberry
adopted ChemIQ13, an analytical testing methodology which can screen chemical
formulations for over 400 analytes. Over 1700 formulations were tested in 30 wet
12
https://mrsl.roadmaptozero.com/
13
https://s3.amazonaws.com/content.stockpr.com/vfcsustainability/files/pages/resources/
policies-standards/VF+CHEM-IQ+Method.pdf

processing facilities and 94% were found to be compliant, with the 6% of failing
formulations removed from Burberry production.
Burberry has helped develop an online chemical inventory tool to aid better chemical
management practices. The tool was first adopted in 2017, and over 50 Burberry
partners are registered, with 25 of these partners being wet processors. This
emergent technology provides information regarding the MRSL compliance of chemical
inventories in the supply chain. Facilities who do not directly use chemicals can “link”
to their suppliers and view with their consent the chemical inventory, for example,
a finished goods vendor with a dyehouse. Other brands are also using this online
chemical inventory tool, and if a facility that is in Burberry’s supply chain is also being
used by another brand, they can also “link” to more than one brand, growing a network
and sharing their chemical inventory. Burberry encourages the use of this tool, but it
is not mandatory for the supply chain to adopt it.
WASTEWATER GUIDELINES (WWG)

Burberry started conducting wastewater tests in 201414 in facilities in their supply
base and they have already published detailed results on their website.
Burberry has now committed to promoting the ZDHC Wastewater Guidelines
throughout the supply chain and making the results available via the ZDHC Gateway–
Wastewater Module, as well as publishing the results and an analysis of trends
on Burberry’s website.15
The ability to demonstrate compliance with MRSL chemicals and conventional
parameters (for direct discharge facilities), is considered in the scoring criteria of the
Burberry PPT. Burberry expects partners to follow the ZDHC Wastewater Guidelines,
meaning testing twice a year, and publishing results on the ZDHC Gateway.
The table below shows details of the tests conducted by Burberry suppliers for the
October 2019 round of wastewater testing:
WASTEWATER ANALYSIS OCTOBER 2019
TOTAL NUMBER OF ZDHC WASTEWATER TESTS 58
% UNITS COVERED BY ZDHC WASTEWATER TESTING 63.3%
TOTAL NUMBER OF WASTEWATER TEST REPORTS

24
WHERE CHEMICAL ANALYTES WERE DETECTED
% OF TEST REPORTS WHERE CHEMICAL

48%
ANALYTES WERE DETECTED
14
https://www.burberryplc.com/content/dam/burberry/corporate/Responsibility/Responsibility_docs/Policies_statements/
Chemical_Management/2014/JUN14%20burberry_water_testing_for_80_summary.pdf
15
https://www.burberryplc.com/content/dam/burberry/corporate/Responsibility/Responsibility_docs/Policies-and-Commitments-as-
sets/Effluent%20Testing%20Trend%20Analysis%20-%20Oct%20Apr%2019.pdf

TOTAL NUMBER OF MRSL ANALYTES TESTED 10863
TOTAL NUMBER OF INDIVIDUAL ANALYTE

62
DETECTION IN RAW WASTEWATER
% OF NON DETECTIONS 99.4%
AVERAGE NUMBER OF MRSL ANALYTES DETECTED PER

2.58
TEST REPORT (WHERE DETECTED, IN WASTEWATER ONLY)
TOTAL NUMBER OF CONVENTIONAL PARAMETERS TESTS 1840
TOTAL NUMBER OF CONVENTIONAL

58
PARAMETER WASTEWATER TEST REPORTS
TOTAL NUMBER OF DIRECT DISCHARGE FACILITIES 7
TOTAL NUMBER OF DIRECT DISCHARGE FACILITIES

TEST REPORTS WHERE AT LEAST ONE CONVENTIONAL 4
PARAMETER DOES NOT MEET FOUNDATIONAL REQUIREMENTS
% OF CONVENTIONAL PARAMETERS
WHICH MEET FOUNDATIONAL LIMITS IN 97.5%
DIRECT DISCHARGE FACILITIES
Breakdown of Raw/Untreated Wastewater MRSL listed chemical tests performed

in October 2019
ANALYTES DETECTED NUMBER OF FACILITIES TOTAL ANALYTES
0 34 0
1 9 9
2 5 10
3 3 9

4 3 12
5 3 15
6 0 0
7 1 7
Each wastewater test checks on average for 191 specific chemicals in effluent before
it is treated and of the individual 10863 tests conducted on raw wastewater there have
been 62 analyte detections (~0.6% detection rate).
However, in 24 out of 58 raw wastewater samples tested (48%) there was at least one
listed chemical group detected. The WWG are guidelines so this does not represent
failure per se but suppliers are required to conduct investigations to find the source
of the chemical.
Burberry does not test for sludge at present but is closely monitoring ZDHC activities
and recommendations.

STAKEHOLDER RESPONSES
Burberry’s approach to chemical management is with a spirit of openness and

collaboration and they are keen to understand how the programme is viewed by
key stakeholders and how the overall process can be improved.
Interviews were conducted with Burberry colleagues across different disciplines
(technical, compliance, buying, corporate responsibility) as well as vendors, raw
material suppliers and external stakeholders. Additionally, a survey was conducted
to allow stakeholders to provide anonymous, constructive feedback. It was completed
by stakeholders including ex-colleagues, other brands, vendors, raw material suppliers,
chemical companies, laboratories and NGOs. Full details are provided in the Appendix
3 and 4.
“I THINK THAT BURBERRY HAVE

ALREADY PLAYED AN IMPORTANT
PART IN THE CONTINUOUS
IMPROVEMENT IN THE INDUSTRY
AND I THINK THAT THEY WILL
CONTINUE TO STRIVE FOR THIS”
SURVEY AND INTERVIEW SUMMARY

Burberry is recognised by their partners and external stakeholders as being leaders
in the drive to eliminate chemicals of concern from production processes.
Burberry is seen as being extremely demanding of their partners with several praising
Burberry for being the most advanced brand in terms of chemical management.
It was not uncommon for partners to report that their own businesses have been
improved significantly as a result of Burberry requirements and that they feel they
have somewhat future-proofed their businesses as a result of Burberry’s approach.
However, several reported that they would struggle to assign adequate resources
should other brands also adopt such a stringent methodology and they would therefore
welcome a single, aligned industry approach.
With this in mind, Burberry transitioned from in-house tools and measures (such as
their own wastewater testing programme) to those used more universally throughout
the industry (e.g. ZDHC) whilst maintaining the chemical management community
within their supply chain.
Burberry has a very compact, transparent supply chain. This is viewed extremely
positively and is clearly what makes their approach doable – the level of collaboration
with a less consolidated supply chain would be more difficult and the approach does
not work without transparency to wet processor level.

*
External Responses = Blue; Supply Chain Responses = Pink
82% 77%
THINK BURBERRY REACTS
AGREE THAT BURBERRY
TO INDUSTRY ISSUES
ARE PROACTIVE LEADERS
QUICKLY AND CREDIBLY
72% 74%
AGREE CHEMICAL AGREE BURBERRY’S
MANAGEMENT IS EMBEDDED APPROACH IS MORE
IN BUYING PROCESSES COLLABORATIVE
AND WAYS OF WORKING THAN MOST BRANDS
94% 87%
AGREE THAT THE CHEMICAL AGREE THAT BURBERRY HAVE
MANAGEMENT POLICIES BEEN EFFECTIVE IN THE
AND STRATEGY IS CLEAR ELIMINATION OF CHEMICALS
92% 81%
AGREE BURBERRY HAS AGREE THAT THE
DRIVEN POSITIVE CHANGE PPT IS BENEFICIAL

“BURBERRY HAS RAISED
AWARENESS OF ENVIRONMENTAL
AND CHEMICAL ISSUES IN THE
FASHION SUPPLY CHAIN”
Product and wastewater results clearly demonstrate that the elimination of chemicals
of concern is working, with detections and failures falling significantly. The ongoing
roll out of education programmes to vendors and raw material suppliers with a clearer
focus on managing chemical inputs throughout the supply base should see both
product failures16 and discharges to the environment continue to diminish in coming
years.
The roll out of the MRSL, Partner Progress Tool and Wastewater Guidelines are viewed
positively but there are some calls for greater clarity on how they are implemented.
Currently Burberry is being demanding and pragmatic – action plans are required
for non-compliances, but suspending business relationships will only be applied for
persistent offenders.
“BURBERRY RECOGNISED IT IS
NOT POSSIBLE TO DRIVE POSITIVE
CHANGE ALONE. IT HAS ALWAYS
COLLABORATED WITH OTHER
BRANDS AND SUPPLY CHAIN
PARTNERS, AND BECAUSE OF THIS,
BURBERRY PLAYED AN IMPORTANT
ROLE IN DRIVING POSITIVE CHANGE”
EXTERNAL RESPONSE
As with any fashion brand, the search for newness and the desire to place the very
best designs on sale requires research and development. Although new materials
are developed by existing supply chain partners, it is recognised that there are
opportunities to strengthen the chemical approval of new raw material suppliers
to the business.
The Burberry approach is respected and the latest version of the Partner Progress
Tool (PPT) is viewed positively. Currently Burberry gives Red-rated facilities the
opportunity to improve and sets 3 months for corrective actions to be put in place.
However, some stakeholders believe that orders should not be placed with ‘Red-rated’
16
Failures may increase if Burberry reduces maximum allowable limits

facilities until issues are rectified. Burberry has committed to eliminating the use
of Red-rated facilities by 2022.
Burberry is recognised by external stakeholders as a leader in the area of change
management to the point where there have been calls for them to pioneer other
initiatives too.
“THE PPT IS A GOOD DOCUMENT

AND I THINK THAT BURBERRY
AND OTHERS WOULD BENEFIT
BY SHARING AND WORKING WITH
THE SAME METHODOLOGY”
EXTERNAL RESPONSE

SUMMARY AND CONCLUSIONS
This report contains details about what Burberry has done, what it has achieved, how it
has achieved it and how it has laid out foundations for ongoing improvements.
It is not uncommon for brands to report what has been done and what has been achieved,
but it is very unusual to provide this information alongside full details of the supply chain
in order to demonstrate how far chemical management practices have been embedded in
vendor and raw material suppliers’ ways of working.
Not only does Burberry have clear, stringent chemical standards, they know they have
been clearly communicated with the raw materials suppliers and that raw materials
suppliers who produce the components for 91% of the units manufactured for Burberry
have undertaken formal chemical management training, 60% which has been performed
by accredited ZDHC trainers. The team knows that vendors who account for 98%
of units manufactured have dedicated chemical managers who are part of a supplier
community who share best practices across the Burberry supply chain.
One survey respondent commented that the Burberry chemical training session was “one
of the best I have ever attended”, but as Burberry transitions to more generic industry-
wide training, there are some calls for in-house specifics to continue to be covered.
Helping the Burberry chemical management team continuously improve their supply
chain implementation is the support from commercial colleagues who maintain a stable,
competent supply base that is fully conversant with the Burberry standards.
“BURBERRY FIRST TRIED

TO UNDERSTAND THE SUPPLY
CHAIN BEFORE CHANGING IT, AND
ALWAYS SOUGHT A DIALOGUE
TO FIND A SOLUTION”
Members of the supply chain understand they are part of a select group and see
the benefits of consolidation for their own organisations. When asked about the
consolidated supply chain with low churn rate, respondents commented that they
understood the advantages in terms or easier communication and engagement.
The low levels of pre-assembly component failures of 0.7% and low levels of due
diligence failures of 4% indicate (considering that Burberry requirements are much
stricter than the industry standard) that progress is being made but there are ongoing
efforts to continuously improve supply chain knowledge through training.
Burberry standards are more stringent than industry norms but vendors and raw
materials suppliers know that they are really implemented and not just for show.
“Burberry’s commitment to meet its own standards is very evident” is a typical
response when asked about policing.

Burberry has deliberately chosen to involve supply chain partners in the chemical
management programme rather than simply demand compliance. This approach
has been broadly welcomed by vendors and raw material suppliers, who, seeing the
direction of travel for the wider industry, have viewed it as an opportunity to future
proof their business.
Burberry’s depth of collaboration is what stands out as being different to the majority of
brands operating in the chemical management space. The following survey response is
from an external stakeholder but sums up the general view: “they believe in engagement,
partnership and improvement through dialogue and collaboration rather than dictation
and giving the tasks to suppliers. This is the best possible way to engage with the
suppliers to meet the objectives however tough and ambitious they are, which are
needed for change management.”
The two-way dialogue with the supply chain is helpful when rolling out initiatives such
as the Partner Progress Tool. Supply chain partners are largely supportive but are not
afraid to provide constructive criticism, for example in relation to scoring systems.
This two-way relationship is healthy. Despite the chemical management programme
being challenging and resource-intensive when surveyed, 90% of supply chain
respondents said Burberry are proactive leaders in relation to chemical management
and 92% said Burberry have driven positive change in relation to the way chemical
management is approached.
However, from the perspective of chemicals on finished products, suppliers do not
particularly want to see standards become more stringent. The standards are, overall,
significantly more stringent than the industry average and the law of diminishing returns
dictates that, in future, enormous efforts will be required for marginal cumulative
benefits.
There are opportunities to improve on-site chemical management practices and
monitoring of chemical inputs and wastewater compliance. Burberry has signalled
their intention to align with industry-wide programmes rather than pursuing a brand-
specific approach and this is likely to meet the approval of their supply chain.
Burberry’s supply chain has found working on the chemical management programme
rewarding but challenging and several remarked that they would prefer industry
alignment of standards and implementation rather than other brands demanding
the same level of individual engagement - which they say would be difficult to manage.
However, despite concerns about workload, there are some calls for Burberry to
extend its programmes further.
“BURBERRY HAS BEEN

COMMITTED TO STRENGTHENING
COLLABORATION WITH THE
SUPPLY CHAIN AND OPERATING
WITH INTEGRITY”

APPENDIX 1: DUE DILIGENCE
PRODUCT TEST RESULTS
– Limit of Detection (LOD)

– Allowable limit (AL)
– Parts per million (ppm)
– Not Detected (ND)
AP [Industry Standard 10ppm, Burberry Standard 3ppm]
APEO AW15 SS16 AW16 SS17 AW17 SS18 AW18 SS19 AW19 SS20
LOD ppm 1
AL ppm 10 6 3
AL Recycled 25
AL Kids Recycled 10
%detection 7 6 7 3 5 6 0 1 0 0
%fail 1 2 1 0 0 3 0 0 0 0
APEO [Industry Standard 100ppm – EU legislation comes into force in February

2021, Burberry Standard 15ppm]
APEO AW15 SS16 AW16 SS17 AW17 SS18 AW18 SS19 AW19 SS20
LOD ppm 3
AL ppm 100 50 25 15
AL Recycled 250
AL Kids Recycled 100
%detection 27 27 21 11 12 7 11 5 3 0
%fail 7 5 7 4 2 4 0 0 0 0

Chlorobenzenes [Industry standard sum 1 ppm, Burberry Standard – Not Detected]
Clorobenzenes AW15 SS16 AW16 SS17 AW17 SS18 AW18 SS19 AW19 SS20
LOD ppm 0.1
AL ppm ND
% detection/fail 0 4 3 1 0 0 0 0
Chlorophenols [Industry Standard 0.5ppm each, Burberry Standard sum 0.5ppm]
Clorophenols AW15 SS16 AW16 SS17 AW17 SS18 AW18 SS19 AW19 SS20
LOD ppm 0.05
AL ppm Sum <0.5
% detection 48 31 23 28 40 45 10 6 6
% fail 37 14 11 13 20 20 2 6 3
PFC’s [C8 - Industry and Burberry Standard Not Detected – EU legislation comes into
force in July 2020, C6 - not routinely restricted, Burberry Standard – Not Detected]
C8 AW15 SS16 AW16 SS17 AW17 SS18 AW18 SS19 AW19 SS20
LOD μg/m2 1-10
AL ND
%detection/fail 18 18 4 5 0 3 0 4 0 9
C6 AW15 SS16 AW16 SS17 AW17 SS18 AW18 SS19 AW19 SS20
LOD μg/m2 1-10
AL μg/m2 2000 ND
%detection 33 24 37 C6 Banned – if detected this is reported as a failure
%fail 18 18 4 5 0 3 0 4 0 9
SCCPS [Industry Standard 1000ppm, Burberry Standard -Not Detected]
SCCP's AW15 SS16 AW16 SS17 AW17 SS18 AW18 SS19 AW19 SS20
50sccp 50sccp 50sccp 50sccp 50sccp

LOD ppm 30 50
100mccp 100mccp 100mccp 100mccp 100mccp
AL ppm 100 100 ND ND ND ND ND ND ND
%detection 2 0 0 0 19 44 20 0 6
%fail 2 0 0 0 15 11 0 0 6

CHEMICAL GROUPS INCLUDED FROM SS18:
Azo Amines [Industry standard 20ppm,

Burberry Standard 5ppm]
Azo Amines SS18 AW18 SS19 AW19 SS20
LOD ppm 5
AL ppm ND
AL Recycled 20
% detection 0 2
% fail 0 2
Chlorinated Solvents [Industry standard – variable,

Burberry Standard Not Detected]
Chlorinated
SS18 AW18 SS19 AW19 SS20
Solvent
LOD ppm 0.1
AL ppm ND
% detection/fail 22
Formaldehyde [Industry & Burberry

Standard AL = Kids 16ppm, Adult 75ppm]
Formaldehyde SS18 AW18 SS19 AW19 SS20
LOD ppm 16
AL ppm 75
AL Kids ND
% detection 3 5
% fail 0 3

Organotin Compounds [Industry standard variable (tbt and
tpht 0.5ppm, others 1ppm), Burberry Standard sum of all <1ppm]
Organotins SS18 AW18 SS19 AW19 SS20
LOD ppm 0.025
AL ppm Sum <1
AL Kids Sum <0.5
% detection 17 9 5 0 0
% fail 0 9 3 0 0
Phthalates [Industry standard 500ppm

each, Sum 1000ppm, Burberry Standard
sum of all 100ppm]
Clorophenols SS18 AW18 SS19 AW19 SS20
LOD ppm 10
AL ppm 250 100
% detection 9 14 8 0 0
% fail 9 0 0 0 0
VOCs [Industry standard 1000ppm, benzene 5ppm,

Burberry Standard sum of all 20ppm, benzene 5ppm]
VOC SS18 AW18 SS19 AW19 SS20
LOD ppm 0.1
20
AL ppm
5
Benzene
% detection 9
% fail 0

APPENDIX 2: BURBERRY BULK PRODUCT
TESTING RESULTS – AW19, SS20
AW19, SS20 %
ANALYTES DETECTED
FAIL PASS FAIL PASS
AP 4 1022 0.4% 99.6%
APEO 19 1022 1.8% 98.2%
AZO DYES 2 2701 0.1% 99.9%
CHLORINATED SOLVENT 27 81 8.0% 92.0%
CHLOROBENZENES
7 195 3.5% 96.5%
& TOLUENES
CHLOROPHENOL 18 1129 1.6% 98.4%
FORMALDEHYDE 4 4666 0.1% 99.9%
ORGANOTIN COMPOUNDS 7 245 2.8% 97.2%
PFCs 3 265 1.1% 98.9%
PHTHALATES 20 987 2.0% 98.0%
SCCPS 1 33 2.9% 97.1%
TOTAL 92 12346 0.75% 99.25%

APPENDIX 3: SUPPLY CHAIN
STAKEHOLDER SURVEY
27 statements were provided and participants were asked if they:

– Strongly agree (SA)
– Agree (A)
– Neither disagreed or agreed (-)
– Disagree (D)
– Strongly disagree (SD)
– Not sure (?)
They were also invited to comment to support their answers and provide general
commentary on the Burberry approach to chemical management.
SUPPLY CHAIN RESPONSES – In total there were 65 responses to the questionnaire:
SA A – D SD ?
Training and continuous improvement

The chemical management policies promoted by Burberry made the
and overall strategy is clear policies very clear for the majority
of actors in the production chain
The chemical management policy General agreement on approach but

contains all the parameters you some calls for tailoring to specific
would expect business types
The chemical management policy and

Overall view is that Burberry teams
strategy is supported by everyone in
are aligned
the Burberry business
The chemical management policy

and strategy is embedded in buying Agreement that the policy is embedded
processes and ways of working
0 20 40 60 80 100

Overwhelming agreement that this a
The Burberry chemical requirements
strong point of the programme but one
are clear
calls for more
The Product Restricted Substance

Strong agreement but a call for
List (PRSL) limits are ambitious but
industry alignment
fair
It is clear how the 'progressive'

Survey indicates most suppliers have
standards (MRSL, Wastewater,
clarity – but comments suggest work
Partner Progress Tool) are
to be done in this area
implemented
Survey indicates most suppliers agree

The policing of the 'progressive'
but some comments suggest the
standards (MRSL, Wastewater,
policing against MRSL and wastewater
Partner Progress Tool) is fair
is not mature enough to be judged
A relatively small, established supply Overwhelming agreement that this is

chain with low 'churn rate' is helpful in the cornerstone of the programme –
implementing chemical management enabling full supply chain engagement
General agreement the PPT

The PPT assessment approach is assessment is beneficial but calls to
benefitial in highlighting opportunoties refine, make peer scores public and
for improvement and raising standards some concerns that good scores may
gloss over some key issues
General agreement but some calls

The PPT approach considers the
for tailoring of approach for different
correct parameters
types of facility
The PPT scoring system gives a good Some concerns over the need to pay
reflection of a partner's ability to to join schemes to get good scores and
manage chemicals some calls for refinement
Only half the respondents agree – it

The PPT grade is used in a fair way to
would appear this is largely due to
stop production with partners and/or
it being a new process. Next year’s
increase or decrease levels of business
response will be important
0 20 40 60 80 100

There is a very strong belief this
Placing orders with a Red-rated practice is high risk but some
partner, or one that is yet to be acceptance the PPT needs to be
assessed, is a risk to the business refined before draconian action/
changes to buying are enacted
There is a split. Some suggest using

The ability to place orders with a Red-
new suppliers is essential but that
rated partner or one that is yes to be
there should be better on-boarding
assessed, is necessary from a creative
process. Others cite ‘creativity’ as a
perspective
poor excuse
Deliberate negative wording confused

Burberry is not interested in meeting some respondents but overall there
the standards and policies it publishes is agreement that Burberry meets its
standards
The Burberry chemical management Strong agreement the Burberry team

team are available and approachable provide a good interface for suppliers
The Burberry chemical management Generally strong agreement the

team deal with queries and issues team provide a prompt, professional
promptly and professionally response.
Strong belief that Burberry are the

most collaborative. During interviews
The Burberry approach to chemical
several said “other brands just tell us
management is more collaborative
what their standards are and that we
than most brands
should meet them but Burberry involve
us in meeting their standards"
Results indicate the supply chain

believes the situation is clear but in
The ownership of any action plans interviews some questioned if they
related to new suppliers is clear should own action plans associated
with wet processors that Burberry
had instructed them to use
Results indicate a split but in

interviews, partners said Burberry
Burberry are difficult/challenging to
were very challenging (in terms of
work with
meeting standards) but that they
welcomed this as it made them better
The Burberry in-house training or

Burberry-recommended training e.g The training has been well received
ZDHC has been relevant and useful
0 20 40 60 80 100

Burberry are proactive leaders in the
Overwhelming agreement
field of chemical management
Strong agreement. One comment that

Burberry react to industry issues
when Burberry work alone they are
quickly and credibly
nimbler than when using industry tools
Suppliers are overwhelmingly

Burberry have driven positive change
appreciative of the way Burberry have
in relation to the way chemical
changed the supply base mindset – so
management is approached
they are future-proofed
Burberry have been effective in

Very strong agreement – PFCs cited
managing the elimination of harmful
as a good example
chemicals out of the supply chain
There is not strong support for tougher

standards – this was apparent in
Burberry should raise the bar with supplier interviews where the general
respect to the standards they set opinion was that Burberry had pushed
very hard to now but pushing harder
would deliver diminishing returns
Some respondents call for improved

Burberry should raise the bar with implementation of standards and other
respect to how their standards are call for better assessment of systems
implemented that impact on compliance / non-
compliance
0 20 40 60 80 100

FURTHER FINDINGS
– Clarity of standards and policies and clear communication with

supply chain.
– True engagement with supply chain to improve chemical

management and to eliminate deliberate use of certain chemicals.
– They have sent out an important message regarding

environmental protection.
– Provision of training and the formation of the Chemical Manager

HAVE HAVE BURBERRY
Community to enhance understanding and to place responsibility
DONE WELL?
for compliance with supply chain.
– Broken down barriers throughout the supply chain to find

solutions via dialogue.
– Created an objective tool and methodology for highlighting risks

and opportunities for improvement.
– Burberry have proved it is possible to make positive changes via

transparency, collaboration and tenacity
FROM YOUR POINT –Changed the mindset of the supply chain from doing what they are
OF VIEW, WHAT HAS
told to wanting to implement good practice and looking forward to
BEEN BURBERRY'S
MAIN ACHIEVEMENT/S? future requirements.
–Industry alignment for sustainability standards.
–Consistency of PPT assessment – moderation of audits and fewer

WHAT WOULD YOU LIKE questions that are open to interpretation.
BURBERRY TO CHANGE
IN THE FUTURE? –The most common request was for “more progress” – the supply
chain feel they are part of a movement and want to see more
training, more labs, greater industry roll out and so on.

APPENDIX 4: EXTERNAL
STAKEHOLDER RESPONSES
This groups includes (ex-colleagues, other brands, chemical companies, laboratories and
NGOs) and they have given their views based on what they know and their perceptions.
They may not be fully informed regarding specific standards and ways of working and
there is inevitably a greater % of “not sure” responses.
In total there were 20 responses to the questionnaire.
SA A – D SD ?
The chemical management policies The standards and policies are clear to
and overall strategy is clear the supply chain but not to the public
The Chemical management policy

Burberry go farther than most but the
contains all the parameters you
policy should be continuously improved
would expect
Agreement that chemical requirements

The Chemical requirements are clear
are clear
The product Restricted Substance

List (PRSL) limits are ambitious Agreement on the PRSL limits
but fair
A relatively small, established supply This approach has to be carried

chain with low 'churn rate' is helpful in through to wet processors to
implementing a chemical management be successful (Burberry do have
programme consolidated Tier 2)
The PPT assessment approach is

General agreement that the PPT
beneficial in highlighting opportunities
is a good approach
for improvement and raising standards
0 20 40 60 80 100

External stakeholders believe that
Burberry is not interested in meeting
Burberry is very committed to ensuring
the standards and policies it publishes
the standards they set are met
The Burberry chemical management Agreement on working well with

team are available and approachable Burberry’s team
The Burberry approach of working

Some other brands believe they do
with suppliers in a collaborative way is
work in a similar way
different to other brands
Burberry are proactive leaders in the

Strong agreement that this is the case
field of chemical management
Burberry react to industry issues

Strong agreement that this is the case
quickly and credibly
Burberry have driven positive change

Strong agreement and recognised
in relation to the way chemical
as early adopters of chemical KPIs
management is approached
Burberry has been effective in Acknowledgement of Burberry’s use

managing the elimination of harmful of root cause analysis to achieve this
chemicals out of the supply chain systematically
Because of Burberry’s success in

chemical management in products
Burberry should raise the bar with
some stakeholders are looking to
respect to the standards they set
them to take the lead in air emissions
and upstream fibre production
This should be viewed as

encouragement to carry on improving
Burberry should raise the bar with
rather than a criticism – no negative
respect to how their standards are
comments were made despite strong
implemented
survey result suggesting Burberry
should raise the bar
0 20 40 60 80 100

FURTHER FINDINGS
– Set clear objectives, communicated them well, collaborated with

supply chain and listened to them.
HAVE HAVE BURBERRY
DONE WELL? – Provided training and implementation tools in order to make the
project a success.
FROM YOUR POINT – Establishing strong relationships with production facilities and
OF VIEW, WHAT HAS driving cultural change throughout the supply base.
BEEN BURBERRY'S
MAIN ACHIEVEMENT/S? – Transparency and public reporting.
– Follow through on proposals to reward better facilities with

more business
WHAT WOULD YOU – Demonstrate that Red facilities are being improved.
LIKE BURBERRY TO
CHANGE IN THE FUTURE? – Guarantee of business for the supply chain to ensure ongoing
engagement
– Expand scope to air emissions and upstream fibre production

GLOSSARY
CHEMICAL FORMULATION: A proprietary mixture of chemical substances that is

available for purchase from chemical suppliers under their own trade name
CHEMICAL MANAGER (CM): A person responsible for implementing Burberry’s
chemical management requirements in all Burberry production and processes
CHEMICAL MANAGER COMMUNITY: Related to vendors and suppliers that receives
monthly updates on chemical management activities and that participates in training
and sharing of initiatives
CMS: Chemical Management System
CONFORMANCE LEVELS: Assigned to chemical formulations by accredited third-
party certifiers to show how confident you can be that a chemical formulation would
always conform (Level 0 is the lowest level of confidence and Level 3 is the highest)
DIRECT DISCHARGE: A point source that discharges wastewater to streams, lakes,
or oceans. Municipal and industrial facilities that induce pollution through a defined
conveyance or system such as outlet pipes are direct dischargers
ETA: Ethical Trade Audit. This forms part of Burberry’s compliance program
FINISHED GOODS VENDORS: Any company that supplies Burberry with finished
goods
INCOMING WATER (IW): Water that is supplied to a manufacturing process, usually
withdrawn from surface water bodies, groundwater or collected from rainfall. This
includes water supplied by municipalities and condensation from external sources of
process streams
INDIRECT DISCHARGE: The discharge of wastewater to a treatment facility not
owned and operated by the facility discharging the pollutants, for example a municipal
wastewater treatment plant or industrial treatment park
KPI: Key Performance Indicator, a measurable value that demonstrates how effectively
an activity is implemented
MRSL: Manufacturing Restricted Substances List
PPT: Burberry Partner Progress Tool, the framework used to implement the chemical
management expectation
PRSL: Product Restricted Substances List
RAW MATERIAL/TRIMS SUPPLIER: Any company that supplies goods or a service to
Burberry PLC directly or indirectly. This includes but is not limited to printing, weaving,
knitting, dyeing, processing, etc
RAW WASTEWATER (RAW WW): Wastewater that has not yet been treated prior to
direct or indirect discharge from the facility, or prior to water recycling efforts
ROOT CAUSE ANALYSIS (RCA): Method of problem solving, by identifying the cause
of the failure and why it is happening

RM: Raw Material
UNIT: a single sales unit such as an item of clothing, pair of shoes or a bag. Progress
is reported in terms of the % of total units manufactured that are covered by specific
standards or initiatives
WET PROCESS: Any manufacturing process that makes use of water in association
with chemicals, such as garment dyeing, laundering, printing, dyeing, finishing, tanning
etc. Also any process that discharges wastewater (special cases: digital printing is a
wet process when the Chemical Managers and the fixation are performed in the same
facility; placement print is a wet process when the facility discharges wastewater for
example from screen/cylinder washing)
ZDHC: Zero Discharge of Hazardous Chemicals, a group of major apparel and footwear
brands and retailers who made a shared commitment to help lead the industry towards
zero discharge of hazardous chemicals
ZDHC ACADEMY: A training platform for sustainable chemical management
ZDHC GATEWAY – CHEMICAL MODULE: An online database that provides an easy
way to register and browse safe and sustainable chemistry solutions. This builds trust
and reduces the administrative burden
ZDHC GATEWAY – WASTEWATER MODULE: An online platform to upload
wastewater test reports and share the results simultaneously with all clients
ZDHC INCHECK: A report to show how much a chemical inventory conforms to the
requirements of the MRSL
ZDHC WASTEWATER GUIDELINES (WWG): A standard for wastewater discharge
and sludge quality

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BURBERRY CHEMICAL

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 1

At Burberry, we continue to deliver on our commitment

In recognition of this, and aligned with our commitment

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 2

07 THE BURBERRY SUPPLY CHAIN AND

12 PARTNER PROGRESS TOOL

15 PRODUCT RESTRICTED SUBSTANCES

17 RESULTS FROM DUE DILIGENCE TESTING

20 WASTEWATER GUIDELINES (WWG)

24 SURVEY AND INTERVIEW SUMMARY

29 SUMMARY AND CONCLUSIONS

32 DUE DILIGENCE TEST RESULTS

37 SURVEY RESPONSES – SUPPLY CHAIN

42 SURVEY RESPONSES – EXTERNAL

THIRD PARTY VENDOR/SUPPLIER*

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 5

“THE BURBERRY TEAM IS

THIRD PARTY VENDOR/SUPPLIER

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 7

*Details found on page 21

THIRD PARTY VENDOR/SUPPLIER

THIRD PARTY VENDOR/SUPPLIER

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 9

“BURBERRY HAS BEEN

THIRD PARTY VENDOR/SUPPLIER

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 10

PARTNER PROGRESS TOOL (PPT) ASSESSMENT

“IT DOES HIGHLIGHT AREAS

THIRD PARTY VENDOR/SUPPLIER

Burberry has developed a “Chemical Manager Qualification”, where Chemical Managers

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 12

PARTNER PROGRESS TOOL GRADINGS 10

APPAREL AND SOFT

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 13

THIRD PARTY VENDOR/SUPPLIER

ENGAGEMENT AND TRAINING

“BURBERRY HAS INVOLVED THE

THIRD PARTY VENDOR/SUPPLIER

Additionally, the Chemical Manager Community works collaboratively to find answers

“BURBERRY HAS MADE ITS

THIRD PARTY VENDOR/SUPPLIER

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 14

% OF UNITS COVERED BY VENDORS WHO

% OF UNITS COVERED BY VENDORS WHO HAVE

% OF UNITS COVERED BY VENDORS

RAW MATERIAL SUPPLIER (TIER 2 PRODUCERS) TRAINING

% OF UNITS COVERED BY RAW MATERIAL SUPPLIERS

% OF UNITS COVERED BY RAW MATERIAL SUPPLIERS

PRODUCT RESTRICTED SUBSTANCES LIST (PRSL) COMPLIANCE

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 15

BURBERRY PRODUCT TESTING AW19/SS20 COMPLIANCE

AZO DYES 99.9%

CHLORINATED SOLVENT 92.0%

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 16

RESULTS FROM DUE DILIGENCE TESTING

“BURBERRY HAS HELPED THE

THIRD PARTY VENDOR/SUPPLIER

BURBERRY CHEMICAL MANAGEMENT PROGRAMME 17

Burberry is a member of several independent, multi-brand initiatives including Zero