Holland & Barrett International Limited and Holland & Barrett Retail Limited (“H&B”).
Modern Slavery Statement of H&B
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery statement for the financial year ending 30th September 2020. This statement has been approved in respect of the period, on 17th August 2021 by Holland & Barrett International Limited and Holland & Barrett Retail Limited. Modern slavery is a crime and violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain (“Modern Slavery”).
We 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 within our supply chain to continually challenge our ability to combat Modern Slavery.
OUR BUSINESS AND ITS 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 Letterone group. Holland & Barrett Retail Limited is a 100% owned subsidiary of Holland & Barrett International Limited. H&B has over 7,000 Colleagues and operates in 4 countries, UK, ROI, Netherlands, Belgium. H&B has a global annual turnover in excess of £36 million, including our subsidiaries. During the relevant period Holland & Barrett ceased its operations in Sweden & Singapore.
In 2016 we published our 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 H&B adopted a more formal Modern Slavery policy, the Modern Slavery & Human Trafficking Policy (the “Policy”), aimed at ensuring that no Modern Slavery takes place in any part of our organisation or supply chain. The Policy reflects our continued commitment to implementing and enforcing effective systems and controls aimed at combating Modern Slavery. The Policy has been approved and reconfirmed for this financial year.
Oversight of Modern Slavery during this financial year is by the H&B Executive Committee which 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 H&B Executive Management Committee. All reports of actual or suspected breaches of the Policy are reported to and investigated by the H&B 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
SUPPLIER ADHERENCE TO OUR VALUES
In order to ensure that all persons within our supply chain comply with our values and zero tolerance policy on Modern Slavery, H&B has built a framework of measures to assess and monitor our supplier’s conduct in respect to Modern Slavery. H&B has taken steps to include specific prohibitions against the use of Modern Slavery in our contracting process:
H&B Modern Slavery template clauses are being used with all new contracts. We expect our suppliers to comply with those prohibitions and hold their own suppliers to the same high standards. We continue to on-board H&B 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 that 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 evaluate and address risks of slavery and human trafficking in the Supplier Code which states, among other standards, that:
We have set up a dedicated process to review and assess supplier feedback and where necessary take further action to follow up any matters arising.
DUE DILIGENCE PROCESS
Since 2019 DGBT provides a stronger contractual basis for and commitment by suppliers to H&B audit requirements.
The current supplier site audit procedures were due to be updated to improve supplier site auditing for Modern Slavery during current financial year. This review and update was to be implemented alongside the refreshed H&B audit calendar financial year 2019/2020. This has been further delayed due to colleague absence, the impact of Brexit planning on internal resourcing and emergency measures needed to deal with the impact of Covid.
H&B has previously communicated its expectation for H&B to join SEDEX during 2019 and for its key suppliers, especially those in high-risk categories to become a member of SEDEX by 2021. The ongoing challenges of dealing with Brexit and the Covid pandemic has brought additional pressure on resources and the supply chain. Consequently, the decision to join SEDEX has been further deferred from this financial year to be subject to review by the business as soon as the business trading environment restabilizes.
ASSESSMENT OF EFFECTIVENESS
A further 68 Suppliers have confirmed compliance with Modern Slavery laws during this period and evidenced policies, training and legally compliant employment contracts while also confirming legally compliant working hours and overtime practices. The relatively few smaller suppliers among our Supply Chain falling beneath the legal threshold for reporting that do not have Modern Slavery Policies in place, are directed to information and training to support the development of their compliance program.
All office-based Colleagues and Colleagues at the Distribution Centres whose role involves access to H&B computer systems continue to take annual mandatory online compliance training courses on Tackling Modern Slavery as well as Anti-Bribery Compliance and other Ethics and Compliance topics. Each year over 600 Colleagues receive the online training. Logistics, distribution, warehousing, and other supply chain Colleagues also receive awareness training in the form of team briefings tailored appropriately.
All Colleagues receive some form of Modern Slavery awareness training on induction, and regular communications are made on the topic throughout the year.
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 behaviour. This ensures that anyone who has concerns has the means of raising these concerns 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 organization. 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.
APPROVAL FOR THIS STATEMENT
The Board acknowledged the continuing work by H&B and the particular challenges for this financial year.
This statement was approved by H&B Board of Directors.
Signature of Matthew Smith, General Counsel, Secretary of the Audit Committee, Holland & Barrett Retail Limited Board and Holland & Barrett International Limited Board.