Modern Slavery Statement

Modern Slavery Worldwide

• 50 million people worldwide are considered to be living in modern slavery
• Globally, there is 1 person who is a victim of modern slavery for every 150 people in the world
• There are 27.6 million people in situations of forced labour on any given day
• In 2021, 10 million more people were in modern slavery compared to 2016 global estimates.
• 3.9 million people are living in modern slavery due to exploitation by governments

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

Modern Slavery in the UK

• In 2025, 23,411 potential victims of modern slavery were referred to the National Refferal Mechanism (NMR) , a 22% increase on 2024.
• Through 2025, 7035 calls were made and 4196 webforms were submitted to the Modern Slavery & Exploitation helpline.
• The most common country of origin for people reffered under the NRM were United Kingdom (22%), Eritrean (13%) and Vietnamese (9%).
• In 2025, Labour exploitation was the most common reported form of exploitation  in adults with 36% of all cases in this category.

Modern Slavery: Modern slavery: National Referral Mechanism and Duty to Notify statistics UK, end of year summary 2024 - GOV.UK

We are the UK’s leading pub, cider and beer business and the name behind iconic drinks brands such as Heineken®, Strongbow, Foster’s, Birra Moretti, Cruzcampo, Old Mout and Desperados, together with a full range of specialty brands and craft brands including Beavertown and Brixton. We employ 2,017 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 2,334 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 HEINEKEN organisation worldwide.

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

Risk Management
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 & Business Partner Policy  
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 Organization. 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.

Supplier Code compliance is reviewed by the Heineken Procurement Manager on a monthly basis and performance is shared with Heineken UK’s Managing Director, Finance Director as well as the Regional Procurement Director.

As part of our ongoing efforts to enhance our business operations and ensure the highest standards of value chain compliance, in 2026 we will transition from our Supplier Code to our new Global Business Partner Policy.

B. Risk Assessing Third Parties

Since 2021, HEINEKEN has used “SHINE”, a third-party due diligence tool, 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 an Amber (Medium) or Red (High) 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 2024 close, there were no outstanding Due Diligence Questionnaires for Suppliers as at the end of 2025.

Through 2025, the SHINE tool was deployed by Beavertown and as with HEINEKEN UK, there were no outstanding Due Diligence Questionnaires as at the end of 2025. 

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. Smart Outsourcing Audit
For employees of Outsourced Service Providers (OSPs), who may be involved in the manufacture, distribution and promotion of our products, adherence to our Supplier Code, as well as local laws, is vital to ensure fair working conditions. 

In 2024, HEINEKEN UK embarked on a globally led program called SMART Outsourcing. The purpose of this was to ensure that OSPs are compliant with our human rights standards and meet our Brew a Better World (BABW) commitments. 

Work under this program continued through 2025. Focus activities undertaken included the roll-out of a Supplier Self-Assessment Questionnaire, several OSP site audits, as well as closing the recommendations from the independent ERSA audit conducted at Manchester Brewery. 

Through 2026, this Global Program will transition to a business-as-usual mode, where direct collaboration with suppliers and partners will ensure that standards on labour conditions, wages, safety, and human rights are upheld. This approach is fully aligned to the BABW 2030 Social Pillar ambition for “decent and safe living and working standards for our employees and outsourced workers”. 

Set out below are some of the actions and events that have taken place in 2025.

Brand Promoter Policy
As part of our commitment to human rights, we have embedded our Brand Promoters Policy, and mandatory training has been repeated for all Commerce, Procurement and People function employees. 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 2025, our completion rates for these two modules were both 95%.

Chartered Institute of Procurement and Supply (CIPS) Ethics Course
In 2025, 25 Procurement colleagues across our organisation, covering Heineken UK Procurement, Star Pubs Procurement and the Third-Party Drinks team, 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.

Star Pubs
Given the importance of Star Pubs to the overall business, further practical steps were progressed through 2025 to strengthen awareness of Modern Slavery risks and controls.

With full support from the Star Pubs Leadership team, a cross-functional working group (Safety & Operational Compliance, Security, Corporate Affairs, and Legal & Compliance) continues to oversee this program.

Following a review of onboarding training and procedures across our Leased & Tenanted (L&T) and Just Add Talent (JAT) pubs, and with no Modern Slavery concerns reported by Business Development Managers (embedded within routine compliance visits), the overall risk remains low.

To sustain this position, the working group continued delivery of the Modern Slavery Action Plan through 2025, with all actions on track.

• Targeted communications to enhance awareness, including briefings to Business Development Managers and wider Star Pubs colleagues via forums such as the Star “All Call”, supported by guidance materials.
• Development and rollout of guidance on Modern Slavery indicators (“red flags”) and escalation routes, integrated into routine pub engagement; and
• Embedding Modern Slavery considerations into audit and assurance processes, including confirmation by Business Development Managers that each pub has been assessed, effective from Q4 2025.

Output from this activity will continue to inform the annual risk assessment, alongside ongoing review of training and communications to maintain appropriate awareness and compliance.

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

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, and 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 and HEINEKEN UK also founded the Sustainable Cider Apples Scheme to promote responsible supply chains.

In summary

Heineken UK remains fully committed to fulfilling our responsibilities in this important area and being able to demonstrate practical actions that support proactive governance across the breadth of the business.