Modern Slavery Statement

Modern Slavery Worldwide

Report: Global Estimates of Modern Slavery: Forced Labour and Forced Marriage (ilo.org)

Modern Slavery in the UK

Modern Slavery: Modern Slavery: National Referral Mechanism and Duty to Notify statistics UK, end of year summary 2023 - GOV.UK (www.gov.uk)

We work with suppliers across our brewing, on trade, off trade and other commercial operations.  We recognise that there is always a risk of modern slavery occurring in our supply chain and have taken steps to understand and to mitigate those risks (as further detailed below).  

Respect for human rights is embedded throughout our business.  Our Human Rights policy has been in place since 2012 as part of our Code of Business Conduct which applies across the entire worldwide HEINEKEN organisation. 

Our policy is aligned with international standards, including the Universal Declaration of Human Rights, the Declaration on Fundamental Principles and Rights at Work of the International Labour Organization (ILO), the Guidelines for Multinational Enterprises of the Organisation for Economic Cooperation and Development (OECD) of 2010, and the United Nations (UN) Guiding Principles on Business and Human Rights. It incorporates the following 10 key human rights standards as a foundation to help us to understand, avoid and address human rights-related risks:

• Health and safety
• Non-discrimination
• No forced labour
• No harassment and violence
• Child protection
• Freedom of association and collective bargaining
• Ensuring rest and leisure
• Fair wages and income
• Access to water
• Respect for human rights in high-risk contexts 

To comply with the high standards we have set for our business and supply chain, we are constantly reviewing and assessing our processes. We take a risk-based approach to identifying and eradicating modern slavery and human rights abuses.  HEINEKEN UK has put in place a series of measures to mitigate risk associated with modern slavery and human rights infringements, the principal ones of which are set out below.

A. Supplier Code

We require all of our suppliers to abide by our Supplier Code which outlines the key behaviours we expect of our suppliers, including ensuring safe working practices, fairly remunerating employees, and complying with the standards set by the International Labour Organisation. Suppliers must confirm that they will agree to abide by our Supplier Code before they are permitted to enter into any tender process to work with HEINEKEN.

B. Risk Assessing Third Parties

In 2021, HEINEKEN deployed a new third-party due diligence programme ‘SHINE’, which is used to assess all new suppliers for the HEINEKEN UK business.  SHINE is designed to identify, assess and remediate risks and automatically performs instant due diligence on suppliers across over 50 risk categories that include sanctions, watchlists and enforcements, corruption, human rights violations, terrorism and trafficking.  A report and risk rating are assigned to each supplier, and these are then reviewed by our internal compliance teams to ensure that appropriate actions are taken.  The SHINE tool monitors suppliers on a real time basis to ensure that we only do business with suppliers who share our values and commitments to responsible business conduct. In the event of a supplier being deemed a risk, alerts are issued to our Procurement department, our Director of Legal Affairs and our Head of Assurance, Risk and Compliance to review and take appropriate action. As is consistent with the position at 2022 close, there were no outstanding Due Diligence Questionnaires for Suppliers as at the end of 2023.

C. Speak Up Policy

We have embedded a Speak Up policy across the HEINEKEN organisation. If anyone (whether it be an employee, supplier, customer or consumer) has a concern about a possible violation of our Code of Business Conduct, including any of the underlying policies, they can report their concerns anonymously online or over the phone.  We actively promote our Speak Up policy across the organisation and encourage individuals to report any concerns, including any possible human rights violations, through this channel. 

D. Human Rights Audit

As a business, our obligations around human rights are a core value, embedded in our Code of Business Conduct and in our commitments to international standards. 

Across HEINEKEN globally, the last Human Rights Survey took place in 2022 and was open to all employees and on-site contractors and input was given on an anonymised basis. The survey consisted of questions around core elements of our Human Rights Policy including non-discrimination, rest and leisure, fair wages and income and no harassment and violence. Thereafter, a HEINEKEN Global Audit team was deployed to the UK, engaging the People Function and Procurement to discuss and review our policies in this area. 

Global Audit review focussed on ensuring that HEINEKEN UK has established sufficient processes and controls to ensure compliance with Heineken Policies including Human Rights. The overall rating was ‘Good’ noting, “HEINEKEN UK (HUK), supported by a robust regulatory environment, started on the journey to embed Human Rights Standards, even prior to the launch of the revamped policy in 2018. The OpCo showed good awareness and adequate ownership of the Human Rights Policy.” 

Through 2023, we closed out the Global Audit recommendation relating to the circulation and communication of our Human Rights Policy with on-site service providers (“OSSPs”). This action was further strengthened by a twice-yearly independent audit performed by the Head of Assurance, Risk and Compliance to confirm the cascade of HEINEKEN policies and also ensures that we have visibility of the equivalent policies of the OSSPs to ensure that they are consistent with relevant HEINEKEN policies.  

Set out below are some of the actions and events that have taken place in 2023.

Brand Promoters Policy

As part of our commitment to human rights, we have embedded our Brand Promoters Policy. Mandatory training for all Commerce, Procurement and People functionHR employees has been rolled out. The Brand Promoters Policy outlines key principles that we expect any supplier who engages brand promoters (brand promoters provide samples, serve or sell drinks in bars, restaurants, shops or at events) to adhere to, such as:

• ensuring the safety of Brand Promoters at all times;
• providing support to Brand Promoters and making them aware of our Speak Up policy; and
• requiring Brand Promoters to complete mandatory training provided by HEINEKEN so that they are clear on what is and what is not expected of them.

Mandatory training

All colleagues must complete mandatory training on the above Brand Promotors policy and on our Code of Business Conduct on an annual basis and in 2023, our completion rates for these two modules were 95% and 97% respectively. 

Chartered Institute of Procurement and Supply (CIPS) Ethics Course

In 2023, all Procurement personnel in our organisation successfully completed the CIPS Ethics Course. The course covered a wide range of human rights and ethical topics, including: 

• Corruption, fraud, bribery and exploitation;
• Human rights and forced labour in supply chains; 
• Ethics and transparency in procurement; and
• Environmental awareness.

Orchard Site Visits 

As part of our Sustainability Audits, a team of dedicated resources regularly visit the orchards that supply our cider mill in Ledbury with locally produced apples. 

Each harvest season, HEINEKEN conducts orchard audits, where colleagues engage with orchard managers at both our orchards and those of third-party apple growers to discuss and observe working practices.  Third-party growers answer a number of questions that cover their company structure and how their business complies with UK employment legislation and as part of the audit visit these responses are reviewed, any relevant records are checked before a wider farm inspection to check working conditions is undertaken. Additionally, all growers are required to sign and comply with the HEINEKEN Supplier Code. 

In addition to the audit cycle, as part of assessing crop estimates we have visited every contract grower which provides a further opportunity to observe how they are conducting business.  

HEINEKEN UK remains fully committed to fulfilling our responsibilities in this important area.