At Holland & Barrett we have a long-standing commitment to protecting human rights and combatting Modern Slavery in the United Kingdom (UK) and overseas supply chains. We welcomed the introduction of the Modern Slavery Act in 2015 and are committed to providing an open and honest account of what we are doing to prevent modern slavery in our supply chains and internal business. 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 2022. The current Modern Slavery statement is for the financial year ending 30 September 2023
The statement sets out the steps taken, and those which Holland & Barrett intends to take in the future as objectives to prevent Modern Slavery and human trafficking in our supply chains or in any part of our business.
Introduction
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 and Barrett, we recognise the responsibility to prevent, mitigate and remediate as understood and carried out under the United Nations (UN) Guiding principles (UNGP). 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.
This year we have become members of the world largest corporate sustainability initiative, The United Nations (UN) Global compact abiding the 10 principles under Human Rights, Labour, Environment and Anti-corruption where principle 4 refers to elimination of any forms of forced and compulsory labour.
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.
This year we have made progress in strengthening our approach which includes working through our forward-looking objectives which we mentioned in our last statement. Since we published our first statement, we have gained greater insight into understanding the risks and trends relating to Modern Slavery, which has enabled us to strengthen our approach.
Our Business and Structure
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. Operating within 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 9000 products accessible to our customers and continue to invest to become a leading provider of sustainable products and initiatives.
Governance and Commitment
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. The Risk and audit committee also looks at all risks and 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 such as the United Nations (UN) Universal Declaration of Human Rights, International Bill of Human Rights, International Labour Organization (ILO) Core Conventions, the United Nation Guiding Principles of Protect, Respect and Remedy (UNGP) and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises.
Our Policies
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 Modern Slavery takes place in any part of our organisation or supply chain The Policy highlights the importance to colleagues to:
In 2023 we also introduced new policies to show our commitment against forced labour in supply chains which is now a requirement for all suppliers to be aware of increased knowledge and drive sustainable improvements. This includes our Human Rights Policy, Child labour policy, High Risk Commodity Policy, Deforestation policy, Environment policy supported by our overarching Supplier Code of Conduct which is focused on treating the people in our supply chain with fairness respect and protecting the environment and planet. All suppliers are required to sign up to these policies as a part of their Terms and Conditions. These policies also reflect 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 also revamped our Supplier Partnership manual for Goods for Resale: Finished products and Raw material (UK, ROI and Benelux), Goods Not For resale (UK, ROI and Benelux) and emphasised the use of Social and Ethical compliance verification – Required for all approved suppliers which includes subcontractors.
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 of 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 continue to include specific prohibitions against the use of Modern Slavery in our contracting process:
Progress against last year
Enhancing Due Diligence within our operations
This year we completed assessing our own site of production through Sedex Self-assessment Questionnaire (SAQ) along with third party assessments (SMETA audit). The results highlighted gaps and opportunities on working conditions, policies and process and we set our corrective action plans and closed out any issues within periodic timelines.
Supplier Due Diligence in Supply chains
In 2022, 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 from countries where incidences of Modern Slavery may exist. We created the supplier due diligence process for existing suppliers which formed part of our due diligence process for Goods for Resale (GFR) retrospective suppliers. This was then extended to other business units such as Goods Not For Resale (GNFR) and service providers, International Franchise partners and H&B and me partners.
In the UK, ROI and Benelux we have more than 700 direct suppliers who supply us with both own label and branded products. In 2023, we worked with our key top 80% of spend value suppliers in the UK and Republic of Ireland which is around 160 suppliers and includes all own label and branded suppliers. We have complete visibility of 100 % of our own label suppliers under this category. We use the Authenticate system to trigger assessments to the suppliers which includes policies, Xinjiang and forced labour questionnaire and Sedex checks. Suppliers are checked for their production and manufacturing facilities to meet labour standards, health and safety, environmental standards and business ethics through the Sedex Self-Assessment questionnaire (SAQ).
The self-assessment allows us to gather some of the most vital information which includes information of their management systems, worker numbers, nationalities, demographics, labour policies, grievance procedures, equal opportunity, ethical recruitment, wages and working hours, contracts and environmental policies and process. The SAQ also drives the risk rating for each site based on inherent, product and sector risks based on Sedex Radar scores. This risk information enables us to make informed decisions of risk about the level of further monitoring such as an ethical audit being conducted on site and working on a corrective action plan. Additional elements include universal rights containing UNGP, management systems, entitlement to work, subcontracting and homeworking is checked
At Holland and Barrett, we are against any form of forced labour and as a result, will not source products from countries where forced labour or exploitation against ethnic and indigenous minorities are identified in the supply chain globally.
We also continued the same process with our partner business unit in Benelux with their suppliers with top 80% of the spend. This year we also commenced checking on existing audits done by 3rd party conducted by suppliers at their sites and identifying high risk issues and root cause analysis. We have commenced working on a corrective action plan with these suppliers on definitive timelines.
New Supplier onboarding: We have also commenced the supplier onboarding process for all new suppliers coming onboard with H&B and conducting ESG (Environmental, Social and Governance) due diligence for all GFR and product suppliers which includes corrective action plan. This has been further extended to Goods not for resale (GNFR) and service providers. We have also commenced to look at our Internal franchise partners and make them part of our overarching wider commitment to respect the rights of the people who pick, make, pack and transport the locally sourced products for us and provide services to those living in surrounding communities where we operate and from which we source.
We continue 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 our 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. This year we came across 6 cases of suppliers who were either sourcing or could not confirm that they were sourcing from the Xinjiang region due to their lack of awareness. We worked closely with these suppliers and saw that they established a remediation programme.
In 2022, Sedex announced new changes to improve the Sedex SAQ. This has resulted in a more streamlined self-assessment which gives us a clearer view of the recruitment process for migrant workers in our supply chains, as well as their accommodation arrangements. We can use this data to monitor impacts on workers as they are being recruited and help mitigate any potential risks before they arise. We are currently looking at all the SMETA audits and working with the suppliers to develop a corrective action plan with all suppliers. We currently require High and Medium risk suppliers to demonstrate corrective action plans to demonstrate due diligence and mitigate risk. There are currently 12 High risk suppliers who we are dealing with and have implemented a corrective action plan. Our supply chains are extremely complex with suppliers covering key categories such as vitamins and supplements, food and drink, health and beauty, and sports nutrition for UK, Republic of Ireland and Benelux.
This year we also:
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.
Reporting and Grievance Mechanism
We continue to have a 'Speaking Up’ Policy and Speaking Up hotline for colleagues and suppliers to report knowledge or suspicions of un-ethical or unlawful behaviour. 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.
Training
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.
81% of our UK based colleagues have completed training, including those from key areas such as facilities and our distribution centres 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 global business during 2024. 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.
This year we have commenced the supplier training and engagement sessions within our suppliers as a part of onboarding sessions. This is to support suppliers with knowledge about labour standards and working conditions, policies and process. We conduct weekly engagement with new and existing suppliers through drop-in sessions and conducting internal one to one meetings. We have trained and established 433 suppliers in the last financial year on ESG process and topic areas. We also presented in three of our Supplier conferences last year.
Preparation of upcoming legislations:
Holland & Barrett is also preparing for upcoming legislations which includes the Corporate Sustainability Reporting Directive (CSRD) in line with the new requirements of the European Sustainability Reporting Standards (ESRS) . This new directive will update the EU’s current reporting framework for businesses on issues including modern slavery and exploitation in supply chains with a focus on human rights, the environment, social standards, and sustainability risk projections. In order to prepare for these upcoming legislations we did a gap analysis against the ESRS framework which includes our own workforce (ESRS S1) in our operations, within our supply chain both upstream and downstream (ESRS S2) which highlighted gaps in policies and process, channels of engagement and remedy for material negative impacts on value chain looking at geographies of forced labour, child labour and modern slavery in our supply chains. We will continue to work in these areas.
Stakeholder Relationships
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.
As previously mentioned, we joined the United Nations Global Compact to align with the universal principles of human rights, labour, environment and anticorruption to action against societal goals. UNGC who are also custodians of the UN Sustainable development goals also look at goal 8 of Decent work and economic growth with focus on target 8.7 to take immediate and effective measures to eradicate forced labour and end modern slavery and human trafficking.
Forward looking objectives
In 2023 we developed our ESG 3-year plans with the further development of ESG strategy roadmap where responsible sourcing workstream will highlight work on labour standards, human rights and modern slavery. 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 added an additional workstream objective to commence work on human rights, to our previous five key objectives which formed our Key Performance Indicators (KPIs) the updates are as follows:
APPROVAL FOR THIS STATEMENT
This statement was approved by Holland & Barrett Board of Directors.
Matthew Smith,
Director, Holland & Barrett International Limited.