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. This is the ninth Modern Slavery statement issued in accordance with the Modern Slavery Act in 2015 and we 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 as well as Asia which includes H&B Trading Shanghai Co Ltd & H&B Asia Limited operating for Holland & Barrett. Our last statement was approved by the Boards of Holland & Barrett International Limited and Holland & Barrett Retail Limited on 30th September 2023. The current Modern Slavery statement is for the financial year ending 30 September 2024.
Holland & Barrett is deeply committed to doing the right thing—upholding ethical standards in how we treat people across our business and supply chains. This commitment is integral to building trust with our customers, stakeholders, and colleagues. Ensuring the fair treatment of everyone who works with or for us is a cornerstone of our brand’s values. As part of our ongoing Due Diligence processes, this statement outlines the steps we have taken and our future objectives to prevent modern slavery and human trafficking within our supply chains and across 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.
Last year we became members of the world’s largest corporate sustainability initiative, The United Nations (UN) Global Compact (UNGC), 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. This year we submitted our first annual report committing our ESG and Human rights activities to the UNGC secretariat.
Our policy is 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 as mentioned in our last statement. We have strengthened our due diligence procedures over all categories, commenced risk monitoring through audits, conducted Human Rights Impact Assessments (HRIA) of key commodities and provided training for our suppliers. 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 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 operates globally, key markets include (UK, ROI, Netherlands and Belgium and China) and operating internationally through franchise and distribution 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 adding quality years to life. We have a retail presence of more than 750 stores across the UK and Ireland, we operate in over 300 H&B-owned and -franchised stand-alone stores including Netherlands, Belgium, the EU and Middle East. We are also stocked in more than 2,000 retailer locations and running localised H&B websites in 10 countries including China, Saudi Arabia and South East Asia.
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 company policies, breaches 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. 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:
Our policies, established in 2023, underscore our strong commitment to combating forced labor in supply chains. These policies aim to raise supplier awareness, foster sustainable improvements, and promote ethical practices. They include our Human Rights Policy, Child Labor Policy, High-Risk Commodity Policy, Deforestation Policy, and Environmental Policy, all of which are supported by our overarching Supplier Code of Conduct. This code emphasizes fairness, respect for individuals in our supply chain, and environmental stewardship.
All suppliers are required to adhere to these policies, as well as our updated Supplier Manual, which was revamped last year and forms a key part of their Terms and Conditions during the onboarding process. These policies reflect our dedication to implementing and enforcing robust systems and controls across various supplier categories, including Goods for Resale (finished products and raw materials for the UK, ROI, and Benelux) and Goods Not for Resale (for the UK, ROI, Benelux, and China). Our efforts specifically target combating modern slavery in high-risk commodity supply chains
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:
This year we also introduced the Vendor portal data management system within our business where the policies are stored and signed by the supplier as a part of the supplier onboarding process.
Progress against last year
1. Reviewing Supplier onboarding process
This year we streamlined the supplier onboarding process with the implementation of new technology the Vendor Portal and Canvas 2, these integrate with our Authenticate platform to manage supplier due diligence. The vendor portal is used by our suppliers to sign up to all policies and store supplier data whilst Authenticate records all compliance related activities and due diligence. This process which has been introduced for GFR, and GNFR categories for UK/ ROI as well as Benelux will improve data integrity and will centralise the information. We also included our international franchise partners who are now part of our overarching wider commitment to respect the rights of the people who pick, manufacture, pack and transport locally sourced products for us and provide services to those living in surrounding communities where we operate and from which we source.
In June 2024 the Internal audit team conducted their annual Internal audit reassurance review to assess the controls and governance over the process based on a study in 2022 to identify the risk matrix and supplier onboarding process. The review showed significant progress over the last 18 months. The study identified opportunities to make significant progress in some areas which included supply chain visibility, conduct audits and monitoring of suppliers.
2. Review key critical commodity sourcing and implement new transparency
Reporting transparently on our own-label supply chain practices and operations is core to our approach to sourcing. This year we also commenced defining the scope of critical commodities and raw materials used within our products in line with our high-risk commodity policy and aligning to the EU deforestation regulation commencing in Dec 2025. Some of the key commodities include Palm, soy, cocoa, coffee and timber where we will be asking our suppliers to give more visibility including certifications. Further commodities such as tea, fish oil, collagen, mica, shea butter considered to be high risk ingredients will be phased out in later stages of the study.
3. Developing engagement strategy with high-risk supply chains by commencing the H&B audit programme
Our human rights and modern slavery work is built upon our fundamental monitoring and risk assessment processes. As a minimum, we require that working conditions for those working within supply chains comply with our Supplier Code of Conduct which requires them to become member of Sedex and complete the SAQ. This year we commenced our 3rd party audit programme for monitoring suppliers and created a roadmap in line with our Global Sourcing function, a new function that has been created within the group to encompass sourcing, manufacturing and product integrity and compliance. We set up a grading process for suppliers in line with Sedex methodology and created the traffic light system of Red, Amber, Yellow and Green based on issue criticality. (Fig 1) We have clarified reporting of ‘business critical’ non-conformances on SMETA audits, so they are now more clearly graded within our internal systems and can be acted upon immediately.
| Issue Criticalities* | Traffic light |
| 2 Business Critical NC's or more than 1 critical NCS | Red |
| 1 Critical NCs or more than 2 major NCs | Amber |
| 2 Major NC's or more than 4 minor NC's | Yellow |
| Supplier has 4 minor NCS | Green |
Fig1
Further to this, we also rolled out a pilot on 3rd party audits with our high spend, medium risk suppliers who haven’t previously had a 3rd party social audit in their manufacturing sites. We found a number of non-compliances from this baseline audit and are working with these suppliers on a corrective action plan (Fig 2)
Case Study:
Findings from the current Holland and Barett Social Audit programme conducted as a pilot with 8 medium risk suppliers.
H&B Responsible Sourcing Team is currently working with the concerned suppliers to establish a corrective action plan (CAP) with timelines for completion.
Fig 2. Currently 83% of our own label audited suppliers have a green and yellow rating
4. Continue monitoring Goods Not for Resale (GNFR) suppliers and International Franchise supply chains through our improved risk-based approach to due diligence.
We are continuing to monitor our goods not for resale (GNFR) suppliers and international franchise partners. GNFR includes products and services we buy to run our business and covers Logistics, Operations, Marketing Technology, HR, Property, Facilities Management and Packaging. Our new GNFR partner suppliers currently go through the new supplier onboarding process through the vendor portal and authenticate based on a risk assessment approach. We continue to risk assess our existing supplier base prioritising our top 80% spend.
We believe training and capacity building is an important step in raising awareness of modern slavery risks and mitigation steps within our supply chain. We recognise training needs to be provided regularly in line with both operational and personnel changes. Our supply chains are unique, comprised of small medium enterprises (SME) and there has been recognition within our business of a lack of awareness of modern slavery risks through our current risk assessments.
This year we introduced digital training through our global partner LRQA / Elevate through their EIQ learn platform. EiQ Learn is a comprehensive learning management system and eLearning course library. Focused on supply chains, the course library includes hundreds of interactive animated courses that help businesses understand their ESG risks, promote sustainable and compliant practices throughout the supply chain and remediate issues where they are found. All our own label and top 80% of our suppliers have been given access to these courses in a phased manner commencing with 9 foundational courses. The labour standard courses include Forced labor prevention, recognising child labor, hiring processes, forced labor due diligence, working hours and managing wages and benefits. To date 414 courses have been completed online by the supplier partners.
We also conducted Modern Slavery training with all high-risk GNFR suppliers (UK and Benelux) in partnership with Stronger Together, an impact driven not for profit organisation that provides businesses with practical training, resources, business services and collaborative programmes. The sessions included an Introduction to responsible sourcing, fair work and recruitment. Training was implemented to specifically address UK driven risks as 95% of our service provider partners are based in the UK. More than 50 high risk suppliers and colleagues attended this session.
We hosted an internal "Lunch and Learn" training session on October 18th to commemorate Anti-Slavery Day. This session was designed to raise awareness among our colleagues about responsible recruitment practices, emphasizing that modern slavery is not only a global issue but also a local concern. The event was well-received, with over 45 colleagues in attendance
We also provide supplier onboarding training for our suppliers weekly through open online sessions during these sessions our due diligence process is also discussed. We have conducted 55 new supplier onboarding training and drop-in sessions this year.
In September, LRQA conducted a briefing session for our sourcing offices in China to update on the development around key topics such as labour and environmental standards which included upcoming legislations. This session aimed to further enhance their understanding and awareness of the latest developments of these critical areas.
5. To gain a deeper understanding of how our supply chains impact the people who work within them and the communities that surround them, we also undertook deep dive Human Rights Impact Assessments
In 2024 we partnered with Ergon Associates and commissioned Human Rights Impact assessments on two high spend commodities, Manuka Honey from New Zealand and Fish Oil (Omega 3). The Impact assessment on Manuka Honey helped to embed a robust approach to human rights due diligence (HRDD) in the manuka supply chain. Key suppliers (by volume and / or human rights risk) were ‘nominated’ to report on their approach and present this information to Ergon. A similar approach has been taken with the fish oil study, currently in progress, the manuka honey study has given us a good understanding of some of the challenges facing the sector. One such area includes protecting the rights of indigenous peoples, where the potential impacts related to the right to maintain, control, protect and develop their traditional knowledge, including the control and protection of intellectual property was a finding. Other areas include right to work within a healthy environment, lack of worker representation, seasonality of work, working conditions of beekeepers and looking at living standards. The output from the study has given several action points and ways to work collaboratively with supply chain actors to bring about improvements. We plan to develop and share an action plan, with progression of this a key priority in FY25.
Other activities
Enhancing Due Diligence within our operations
We continue to monitor our own production site through Sedex Self-assessment Questionnaire (SAQ) along with third party assessments (SMETA audit). Any gaps and opportunities on working conditions, policies and process are worked through a corrective action plan to close out any issues within periodic timelines. As a business we also act as a packing and distribution facility for other global brands and there has been more focus on due diligence on our own operations / production sites which includes risk assessments, training and capacity building
Supplier Due Diligence in Supply chains
We have continued the supplier due diligence process for existing suppliers which formed part of our due diligence process for Goods for Resale (GFR) retrospective suppliers, 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 (A+B) suppliers in the UK and Republic of Ireland, which is around 160 suppliers and includes all own label suppliers. We have complete visibility of 100 % of our own label suppliers under this category. This year we have commenced work on the remaining 20% of branded suppliers. We use the Authenticate system to trigger assessments to the suppliers which includes policies, forced labour questionnaire and Sedex checks. Suppliers are checked for their production and manufacturing facilities meeting labour standards, health and safety, environmental standards and business ethics through the Sedex Self-Assessment questionnaire (SAQ).
The self-assessment allows us to gather data to enable decisions. Some of the most vital information gathered includes insight on the supplier's 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 year we also did a trial with the LRQA Sentinel tool which would help us in the prequalification of suppliers, highlighting any risk, the Sentinel tool scans the web for insights on key supply chain ESG risks and media controversies related to suppliers and vendors, including but not limited to human rights, environment, bankruptcy, layoffs, wages, working hours and health and safety. The process covers more than 100 languages and returns thousands of results that are filtered and categorised by our machine learning algorithm to detect near real-time reputation and resilience incidents throughout our supply chain.
At Holland and Barrett, we are against any form of forced labour and as a result, will not source products from countries and or regions 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, also focussing initially on own label suppliers and their branded suppliers that make up top 80% of the spend. This year we also commenced checking existing 3rd party audits conducted by suppliers at their sites, identifying high risk issues and root cause analysis. We have commenced working on a corrective action plan with these suppliers on definitive timelines.
We continue to monitor our suppliers globally for human rights violations, including forced labour, as most of the food ingredient products as well as vitamins sourced from South East Asia. 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 worked closely with these suppliers and saw that they established a remediation programme.
In October 2023, Sedex released an update to their SAQ. The update was designed to provide better visibility around the recruitment and housing of migrant workers, giving users a better understanding of any risks in this area. We have been working collaboratively with our supply chain to ensure completion of the updated SAQ. We 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.
Reporting
Along with providing the monthly ESG steering committee and Bi-Monthly ESG Board Committee with a Responsible Sourcing KPI report, we also report against Own Label sourcing targets to the Group Sourcing and Technical internal Dashboard which is shared with the senior leadership team. We also monitor and work with all high risk branded suppliers identified through our due diligence process
The current audit pilot has increased the number of high-risk own label suppliers from one to three, while 11 branded suppliers fall under the high-risk category. We continue to monitor these non-compliances through time bound corrective action plans and committed to reduction targets.
This year we also:
Expect our suppliers to comply with those prohibitions and hold their own suppliers to the same high standards as we continue to utilise our supplier onboarding process to establish standards and monitoring, including the following:
Reporting and Grievance Mechanism
We continue to have a 'Speaking Up’ Policy and Speaking Up hotline for all 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, training 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.
Supplier Visits
This year we increased our supplier visits to factories which includes new and existing factories in China, UK and Sri Lanka. The visits included engagement with suppliers, conducting risk assessments on site, looking at Health and safety, wages, working hours, contracts, freedom of association, dormitories, canteens. We also reviewed their existing audits and corrective action plans.
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.
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). Additional legislation on Corporate Due Diligence Directive was also signed off this year by the European Union for us to be reporting in the year 2029. 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. As part of the ESRS we are in the process of completing the Double Materiality which will ensure that we focus on material issues. The gap against the ESRS framework includes our own workforce (ESRS S1) within our operations and workforce within our supply chain, both upstream and downstream (ESRS S2). This has helped us to decide the 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.
Memberships & Partner Organisations
1. BRC (British Retail Consortium): As a member of British Retail Consortium (BRC) we follow their guidance on Modern Slavery. We have also worked with industry experts who provide support for sustainable procurement and human rights topics. Additional stakeholders will be identified during the latter part of this year.
2. United Nations Global Compact (UNGC): We are continuing to work with United Nations Global Compact this year 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’ to take immediate and effective measures to eradicate forced labour and end modern slavery and human trafficking.
3. Sedex: We are partnered with Sedex which is global supply chain transparency platform.
4. Stronger Together: We continue to engage Stronger Together, an impact driven nonprofit organisation for Modern Slavery training and engagement.
5. Authenticate: We use Authenticate supply chain transparency software that helps to map products to their sources, monitor suppliers, and measure risk.
6. LRQA /Elevate Global: We use LRQA / Elevate Global to conduct training on Forced labour who are a leading global provider of digitally enabled assurance services including environmental conformity assessments which includes their Sentinel tool.
Forward looking objectives
During the next 12 months we will continue to strengthen our approach to managing the risk of Modern Slavery within critical commodities and wider supply chains, to ensure that our ESG strategy is responsive to changing risks. Some of these actions will sit within the New Product Development (NPD) stage gate process, so that we can capture these risks at an early stage, allowing us to act in addressing immediately any concerns that are identified. In the coming year we have five key objectives, which form our Key Performance Indicators (KPIs):
APPROVAL FOR THIS STATEMENT
This statement was approved by Holland & Barrett Board of Directors.
Matthew Smith,
General Counsel, Holland & Barrett International Limited.