Background
Amazon is an American multinational technology company that engages in e-commerce, cloud computing, online advertising, digital streaming and artificial intelligence activities. As one of the world’s largest retailers, there is strong interest in human and labour rights at the company.
Our engagement
We began engagement with the company on these issues in 2020. We asked the company to demonstrate that it was collecting and using forward looking data and qualitative techniques to reduce workforce health and safety incidents. We suggested that it report its total recordable incident rate (TRIR) and lost time incident rates (LTIR), as well as other metrics, so that investors could assess performance relative to peers.
We also asked the company to perform a human rights impact assessment (HRIA) to identify its most salient human rights risks and demonstrate that it planned to manage them. The company affirmed that in its 2019 Sustainability Report, it had already committed to assessing its most salient human rights risks and conducting HRIAs to deep dive on specific products, regions, and stakeholders.
In 2021, the company confirmed that it is working with a third party to complete an HRIA on raw and recovered1 supply chain materials for Amazon-branded digital devices. In 2022, the company published a public summary of this HRIA2. We thanked the company for this disclosure and asked about the pipeline of future HRIAs covering other topics. We also raised concerns about third-party reports claiming that the company was not accurately portraying its injury rates3. The company disagreed with the data presented and allegations made by the third-party reports.
In 2023, we requested meaningful evidence that the company is complying with its commitment to respect freedom of association. The company asserted that there was low interest in unionization among its workforce, reporting that in 2022, unions met the minimum showing of support required to schedule a representation vote at only four US locations, and that it has not had a union election in the US since 20224. The company invited us to join a public tour of one of its fulfilment centres to see for ourselves the conditions in its warehouses.
We also raised concerns about third-party reports claiming that the company was not accurately portraying its injury rates.
In 2024, we joined a public tour of an Amazon fulfilment centre in New Jersey. The tour highlighted the centre’s use of state-of-the art automation and robotics technology to augment human capacity and maximize operational efficiency. The tour highlighted the company’s commitments to its workforce, but we observed that it could have offered more opportunities to interact directly with workers besides those involved with providing the tour. We observed that tours are offered at dozens of sites throughout the US, Canada, and Europe but not certain sites that have been the subject of media controversy. When we asked about freedom of association, our tour guide said there has been no interest in unionization at the centre.
The tour highlighted the company’s commitments to its workforce, but we observed that it could have offered more opportunities to interact directly with workers.
Engagement outcomes
The company fulfilled our original request to demonstrate that it is collecting and using forward-looking data and qualitative techniques to reduce workforce health and safety incidents. The company discloses continued improvement of its total recordable incident rate (TRIR), which has improved by 30% over the past four years, and its lost time incident rate (LTIR), which has improved by 60% over the past four years5. TRIR and LTIR are well-accepted indicators of workforce health and safety.
Following the publication of its first HRIA on raw and recovered supply chain materials for Amazon-branded digital devices, the company published additional HRIAs on its live streaming business Twitch and its grocery store Whole Foods Market. These HRIAs are part of a broader process of human rights due diligence (HRDD), which the company outlines on its website. Through this process, the company concluded that its approach to freedom of association is in line with US laws and by extension in line with International Labour Organization standards. The company’s approach to human rights due diligence appears in line with the UN Guiding Principles on Business and Human Rights. However, we have observed that the company appears to exert large amounts of control over the process, and there could be a greater role for independent review aside from regulatory oversight.
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