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Modern Slavery Statement

This statement is published in accordance with section 54(1) of the Modern Slavery Act 2015. It sets out the approach taken by HEINEKEN UK Limited and its group companies during the year ending 31st December 2022 to prevent modern slavery in its business and supply chains.

This statement applies to all HEINEKEN UK Limited group companies. At the time of publication, the following group companies meet the reporting threshold contained in the Modern Slavery Act 2015:

Red Star Pub Company (WR III) Ltd
Punch Partnerships (PTL) Ltd

Assessment of Effectiveness

This statement constitutes our modern slavery statement for the financial year ending 31 December 2022. We will continue to assess the effectiveness of the measures we take, and we regularly review and refine our policies and procedures in relation to modern slavery and human rights.

This statement has been approved by the Management Team of HEINEKEN UK Limited. A revised statement, detailing the steps taken and improvements made, will be published on our website each year at

30th June 2023
Modern slavery describes situations where someone is being exploited and controlled by a person or organisation, without the ability to leave or change their situation, such as forced and compulsory labour, debt bondage or bonded labour, human trafficking and child slavery.  It can affect people of any age, gender or race. Most commonly, slavery affects people and communities who are vulnerable to being taken advantage of.

HEINEKEN UK is committed to the highest standards of business conduct, ethical behaviour and integrity throughout its business. We have adopted a zero-tolerance approach to modern slavery in our organisation and are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our organisation or within our wider supply chain network.

Modern Slavery Worldwide

Report: Global Estimates of Modern Slavery: Forced Labour and Forced Marriage (

Modern Slavery in the UK

Modern Slavery: National Referral Mechanism and Duty to Notify statistics UK, end of year summary 2022 - GOV.UK (


We are the UK’s leading pub, cider and beer business and the name behind iconic drinks brands such as Strongbow, Bulmers, Heineken, Foster’s, Birra Moretti, Cruzcampo and Desperados, together with a full range of speciality brands. We employ 2,143 people in the UK and have breweries, cider plants and offices in Edinburgh, Tadcaster, Manchester, London, Hereford and Ledbury. We also own a nationwide pub estate of 2395 outlets.

Our end-to-end supply chain comprises many different elements:


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

Our Human Rights Policy can be viewed here.




In order 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 2021 close, there were no outstanding Due Diligence Questionnaires for Suppliers as at the end of 2022.

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 is a core value, embedded in our Code of Business Conduct and in our commitments to international standards. 

To gain insights as to how we are performing as an inclusive, fair and equitable company, our 2022 Human Rights Survey 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.” As an action point from the review, HEINEKEN UK will further improve its circulation and communication of its Human Rights Policy with onsite service providers.

Set out below are some of the actions and events that have taken place in 2022.

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 HR 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. 

Chartered Institute of Procurement and Supply (CIPS) Ethics Course

In 2022, 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 

We have a team of dedicated resources who regularly visit the Orchards that supply our cider mill in Ledbury with locally produced apples. 

As part of these visits, HEINEKEN colleagues engage with the Orchard Managers to discuss working practices at our orchards and those of our third-party contracted apple growers, and the importance of compliance with the principles of the Supplier Code and Human Rights Policy.