About

Team size: 70

Major legal advisers: Addleshaw Goddard, Allen & Overy, Herbert Smith Freehills, Macfarlanes

‘How can you justify selling T-shirts in your stores for as little as £2 or £3?’ Labour MP Mary Creagh, chair of the Commons Environmental Audit Select Committee, asked Associated British Foods (ABF) director of legal services and company secretary Paul Lister in late 2018.

It is a question the £15bn-plus food, ingredients and retail multinational, which owns household names such as Primark and Twinings, has faced plenty of times before. In addition to his legal role, Lister leads ABF’s corporate responsibility (CR) arm and Primark’s 120-strong ethical trade team. He has done so from the time the company first audited its supply chain 15 years ago to the 3,500 annual audits it does today.

‘Times have changed and it’s grown massively,’ he says. ‘Last year we expanded our sustainable cotton project: we source our cotton from India, China and Pakistan, and are training 160,000 farmers to provide cotton for Primark using environmentally friendly farming methods.’ ABF claims this is the largest retailer-led sustainable cotton project in the world.

Lister says CR landed on his desk because it initially looked like compliance, establishing a code of conduct that sets out the social terms and conditions it expects suppliers to comply with, most of those being legal.

‘There are a lot of laws around it, but enforcement just isn’t happening in the developing world, or even developed world, frankly. We have a team that’s finding out what’s going on and then trying to deal with what we find, either individually by way of just dealing with a particular issue, or collectively if you know you’ve got much bigger issues in some more difficult countries, like working with the Accord in Bangladesh, while also establishing our own structural integrity programme in Bangladesh and Pakistan.’

Lister is widely considered a pioneer for GCs working on CR initiatives at a time when more legal heads have taken on similar responsibilities within their own organisations.

‘He’s right at the forefront of ethical sourcing, sustainability, CSR and diversity,’ adds Addleshaw Goddard partner Chris Taylor. ‘That is unusual, but it’s great to see a GC driving the agenda for his business on these important issues. He embraces these issues, and his energy and enthusiasm encourages others to become involved and share their thoughts on achieving best practice.’

Interview with…

How difficult was it to adjust to a corporate responsibility role, even if it looks like compliance?

Very. The legal team’s values are rigour and integrity, and we decided early on they should be the values of the ethics and CR teams. It is very different but it does mean that when you do it, you’re doing it properly and when you say something, you really mean it. If you’re saying you’re not sourcing cotton from Uzbekistan, you need to make sure you’re not.

It must have been a steep learning curve?

You learn a huge amount over the years. One recent issue has been Syrian refugees landing into Turkey and working in Turkish factories. Is that something that you would necessarily see as legal? Not necessarily, but you recognise you need to look after people in the supply chain. It may not be a legal issue, but if you do it with rigour and integrity you’re applying the same value set to ethics as you are to law and so it’s relatively transferable. Yes, there’s a host of new issues, but as lawyers we’re used to new issues.

We’ve seen a few GCs taking on head of sustainability roles and similar, do you expect that to continue?

Everyone’s got a different view on sustainability. If I go back to social sustainability and making sure you’ve got a code of conduct you comply with, a GC can do that. If it’s environmental sustainability – don’t pollute the air, don’t pollute water and don’t put horrible stuff on your clothes – that’s a sort of compliance thing too. When you move across and down the line to ‘should I sell sustainable cotton in my stores?’ That’s less compliance and more commercial. But you only get the licence to sell sustainable cotton if you’ve done the first bit. My issue in that particular field is when it says sustainable, is it sustainable and what do we mean by that? That would be the same as if the labelling requirements of food are correct. Compliance naturally fits.