Slavery, servitude, forced labour and human trafficking; Modern Slavery issues are of increasing global concern, affecting regions and economies. Modern Slavery is fundamentally unacceptable within our business and supply chains and is an important element in our overall approach to business and human rights.
This statement on Modern Slavery and Human Trafficking is made in accordance with Section 54(6) of the Modern Slavery Act 2015 and covers Holland & Barrett International Limited and Holland & Barrett Retail Limited, which includes subsidiaries in Benelux and countries operating for Holland & Barrett. Our last statement was approved by the Boards of Holland & Barrett International Limited and Holland & Barrett Retail Limited on 17 August 2021. The current Modern Slavery statement is for the financial year ending 30 September 2022
The statement sets out the steps taken, and those which Holland & Barrett intends to take in the future to prevent Modern Slavery and human trafficking in our supply chains or in any part of our business.
The UK Modern Slavery Act 2015 (the ‘Act’) requires businesses to state the actions they have taken during the financial year to ensure Modern Slavery is not taking place in their operations and supply chains.
At Holland & Barrett we have taken a pledge to have a zero-tolerance approach to Modern Slavery, and we are committed to the prevention, deterrence, and detection of Modern Slavery within our business and within our supply chain.
It is our policy to conduct all business activities with honesty, integrity and at the highest possible ethical standards. We are fully committed to implementing and enforcing effective systems and controls within our business and our supply chains to continually challenge our ability to combat Modern Slavery.
We believe our trade with suppliers across the countries we source from should have a positive impact, creating jobs and opportunities for people in the UK and in the countries in which we operate. Since we published our first statement, we have gained greater insight into risk and trends relating to Modern Slavery, which has enabled us to strengthen our approach.
The Holland & Barrett International Limited group of companies (the “H&B Group”) was established in 1870 and has grown into one of the world’s leading health and wellness retailers and the largest in Europe, supplying its customers with a wide range of vitamins, minerals, health supplements, specialist foods and ethical beauty products. The H&B Group are part of the Letter One Group. Holland & Barrett Retail Limited is a 100% owned subsidiary of Holland & Barrett International Limited. Holland and Barrett operate out of four countries (UK, ROI, Netherlands and Belgium) and also operate through franchise partners in other countries.
Our vision is to be the trusted partner for over 100 million people globally, to achieve their personal health and wellness goals by 2026. Operating with over 1,600 stores in 18 countries across the world including owned and franchise stores, the business has a strong, consistent brand ethos combined with expert customer advice to be the highly trusted health and wellness brand that we are today. Our growth is made possible by always putting our customers and employees first and through constant innovation, and a commitment to being ethical in everything that we do. We have invested in technology to make over 6,000 products accessible to our customers and continue to invest to become a leading provider of sustainable products and initiatives.
H&B Group recognises the importance of, and is committed to, high standards of Corporate Governance, aligned with the needs of the Company and the interests of all stakeholders.
Overall accountability for the Modern Slavery Statement and risk assessment process is held by the Executive Committee who has the delegated authority and responsibility of Holland & Barrett International Limited for the prevention, deterrence and detection of unethical practices within the supply chain. Responsibility for the policy rests with the Holland & Barrett Executive Management Committee. All reports of actual or suspected breaches of the policy are reported to and investigated by the Holland & Barrett compliance team under delegated authority from the Executive Management Committee. Colleagues are encouraged to raise concerns, in confidence, about possible issues or suspicions of Modern Slavery within our organisation or supply chain. All credible reports of suspected misconduct are investigated by the compliance team and outcomes reported to the Executive Management Committee.
As a business we are committed to upholding human rights and support in full the conventions below:
Holland & Barrett respects international principles of Human Rights and our policies are aligned with the above international conventions. We have several policies, with ownership at Company board level, that aim to protect employee welfare and basic human rights within our business and our supply chains. The policies reflect our commitment to act ethically and with integrity in all our business relationships, helping to ensure that slavery and human trafficking is not taking place anywhere in our business.
In 2016, we published our first policy on Modern Slavery & Human Trafficking and our commitment to ensure that no Modern Slavery takes place in any part of our organisation or supply chain.
In 2018, we adopted a more formal Modern Slavery policy, the Modern Slavery & Human Trafficking Policy (the “Policy”), aimed at ensuring no Modern Slavery takes place in any part of our organisation or supply chain. The Policy highlights the importance to colleagues to:
Raising awareness of Modern Slavery, within our business and our supply chains, is an important part of our ESG strategy. We know that identifying potential and actual cases requires upskilling colleagues and suppliers to understand the drivers and indicators of modern slavery.
64.18% of our colleagues have completed training, including those from key areas such as facilities, to increase awareness and confidence in being able to identify signs of Modern Slavery within our supply chains and how to report any concerns. This includes making colleagues aware of the whistleblowing helpline. We are using a third-party service provider platform for training and will be working to create more enhanced training in house for the business during 2023. Holland and Barrett continue to provide annual compliance training courses to all relevant colleagues, this Includes topics such as tackling Modern Slavery as well as Anti-Bribery compliance.
Our supply chains are extremely complex with over 600 direct suppliers, covering key categories such as vitamins and supplements, food and drink, health and beauty, and sports nutrition. Products and raw materials are sourced from a large number of countries, with key examples below:
| Sourcing Countries | Some key products |
| China | Pumpkin, peanuts, Rice cracker, Goji, Walnuts, Ginger, pine nuts |
| India | Peppercorns, Fennel, Cinnamon, Cashews, Cloves, Chilies, Linseed, Turmeric, spices, |
| Turkey | Hazelnuts, Sultanas, Apricots, Fig, Raisins, Oregano, |
| Pakistan | Dates |
| Bolivia | Brazil Nuts, Quinoa, Chia seeds |
| Thailand | Mango, Arrowroot, Papaya, Pineapple, Coconut |
| Vietnam | Cashews, Peppercorns |
| Indonesia | Coconut, Nutmeg, Vanilla, cloves |
| Philippines | Coconut, Banana |
| USA | Almonds |
Figure 1: Top 10 sourcing countries with commodities
The Policy reflects our continued commitment to implementing and enforcing effective systems and controls aimed at combating Modern Slavery including these key commodity supply chains.
This year we reviewed our responsible procurement and supply chain due diligence processes with our external global consultancy partner. This review covered existing supply chain management processes and the risks in sourcing the key commodities in Figure 1 above, where incidences of Modern Slavery may exist. The review also highlighted the need to strengthen our supplier onboarding process to give more focus on responsible sourcing and ethical trade, and a number of other steps which are being implemented in 2023 including implementing systems and processes to give greater supply chain transparency.
We expect all our supply chain partners to comply with our Policies including own label and branded suppliers. Holland & Barrett has built a framework of measures to assess and monitor our supplier’s conduct in respect to Modern Slavery, and additional supporting policies that reference Modern Slavery include the Supplier Code of Conduct, GNFR policy, worker wellbeing policy, and Holland & Barrett's Supplier Partnership Manual.
We have taken steps to include specific prohibitions against the use of Modern Slavery in our contracting process:
We expect our suppliers to comply with those prohibitions and hold their own suppliers to the same high standards. We continue to on-board Holland & Barrett raw material suppliers, branded product suppliers, and higher risk, higher value suppliers of indirect goods and services using our Supplier onboarding process “Doing Great Business Together" (DGBT) which includes compliance questionnaires and a declaration asking for confirmation they are adhering to the Modern Slavery Act and all its provisions. Our Supplier Code of Conduct is an integral part of our DGBT process.
We are also members of SEDEX, which is a platform to ensure supply chain transparency and compliance to ethical business practices, and all our new and existing suppliers are now onboarded to this platform and risk assessed.
We evaluate and address risks of slavery and human trafficking in the Supplier Code which states, among other standards, that:
Our aim for 2023 is for all of our suppliers to go through a risk assessment process as a part of the group Supplier onboarding process which includes our product suppliers, Goods Not for Resale (GNFR) suppliers and service providers. The risk-based approach is to target those suppliers who are deemed to be exposed to a higher risk of unethical practices. We are currently working through our supply base and have not yet identified any suppliers where there is evidence of Modern Slavery, but we have identified those that may present a potential risk and will carry out further due diligence on those suppliers.
Since 2019 our onboarding process DGBT, has provided a baseline for stronger contractual basis for commitment by suppliers of their social and environmental concerns through a number of self-assessment questionnaires. As a result of the review of our due diligence processes, we have updated our supply chain policies to include greater focus on human rights. We are also implementing a risk assessment and social audit programme using SEDEX, which is a collaborative platform for buyers, suppliers and auditors to store, share and report on supply chain information and conduct risk assessments and reduce audit fatigue
Our Modern Slavery Statement in 2021 stated that we had paused the SEDEX membership due to Brexit and Covid reasons. This year we have re-engaged our membership with SEDEX. With the help of an external partner, we are mapping our supply chain through SEDEX and assessing and identifying higher risk suppliers through risk assessment including questions relating to labour practices and Modern Slavery. Prior to onboarding new suppliers, they will be required to join SEDEX, to complete self-assessment questionnaires and provide any social or labour audits from their manufacturing sites. This will mitigate the risk of onboarding a new supplier that has a risk of forced labour or Modern Slavery.
Our Supplier Code of Conduct states that Holland & Barrett reserves the right to check compliance, for example, through self-assessments and audits which may be carried out by Holland & Barrett or through a third party. We will continue to assess any instances of non‐compliance on a case‐by‐case basis and tailor any remedial action appropriately. In case a breach is identified, the supplier will be required to create an incident report and present a corrective action plan.
This year we also started to monitor our suppliers from China for sourcing from Xinjiang Uygur Autonomous Region (XUAR). We are increasingly aware of the human rights violations, including forced labour, associated with materials sourced from Xinjiang in line with the UK government enquiry on this matter. Holland & Barrett sources food ingredient products as well as vitamins from China, however we do not have own operations or factories in Xinjiang. We are reviewing and monitoring our suppliers of both raw materials and manufactured products suppliers for all categories and ensuring checks are put in place.
We have a 'Speaking Up’ Policy and in 2018 have relaunched our Speaking Up hotline for colleagues and suppliers to report knowledge or suspicions of un-ethical or unlawful behavior. This ensures anyone who has concerns can raise them confidentially. Our hotline is available to report any suspicions our colleagues may have regarding Modern Slavery and our colleagues are signposted to this in our posters, communications, and other resources that we develop in relation to Modern Slavery. Signposts for awareness and reporting are mandatory information for colleague notice boards across the organisation. There is ongoing communication across the business to raise awareness of the Speak Up facility and the usage is monitored and compared to industry statistics to gauge awareness.
Holland & Barrett are members of the British Retail Consortium (BRC) and follow their guidance on Modern Slavery. We have also worked with industry experts who provide support into the sustainable procurement and human rights. Additional stakeholders will be identified during the latter part of this year.
During the next 12 months we will strengthen our approach to managing the risk of Modern Slavery within our business and our supply chains to ensure that our ESG strategy is responsive to changing risks. We will act and address immediately any concerns that are identified. We have identified four key objectives which will form our Key Performance Indicators (KPIs)for the next year. They are as follows:
This statement was approved by Holland & Barrett Board of Directors.
Matthew Smith
Matthew Smith, General Counsel, Secretary of the Audit Committee, Holland & Barrett Retail Limited Board and Holland & Barrett International Limited Board.