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 2024 - 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 2,019 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 2,351 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

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
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 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 UK Head of Procurement on a monthly basis and performance is shared with the HEINEKEN UK Finance Director and HEINEKEN Regional Procurement Director for Europe on a monthly basis, and quarterly with HEINEKEN UK’s Managing Director.

B. Risk Assessing Third Parties
Since 2021, HEINEKEN has used a third-party due diligence program ‘SHINE’, 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 2023 close, there were no outstanding Due Diligence Questionnaires for Suppliers as at the end of 2024.

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. SMART Outsourcing Audit
Adherence to our Human Rights Policy, Brand Promoter Policy and Supplier Code, as well as local laws, is vital to ensuring fair working conditions for everyone involved in the manufacture, distribution and promotion of our products, whether directly employed by HEINEKEN UK or not. Therefore, employees of Outsourced Service Providers (OSPs) are also covered under these policies.

In 2024, HEINEKEN UK embarked on a globally led program called SMART Outsourcing, which seeks to ensure that OSPs are compliant with human rights standards and meet our Brew a Better World (BABW) commitment: “ensure fair living and working standards for third party employees and brand promoters.”

Through 2024, HEINEKEN UK completed cycle 1 of this program which covered local governance and set-up, value chain mapping, baseline assessment and an external compliance audit of our operations at Manchester Brewery. While we are awaiting the final audit report, preliminary review of the audit findings from the external auditor confirmed that no UK labour risks were found and as such there are no follow-on actions arising.

Cycle 2 of the program will be initiated in 2025. This will be OSP facing, including a self-assessment questionnaire (SAQ) to be completed by management of OSPs and follow on OSP audits for the highest risk OSPs based on the completed SAQs.

Set out below are some of the further actions and events that have taken place in 2024.

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 function 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 2024, our completion rates for these two modules were 99% and 95% respectively.

Chartered Institute of Procurement and Supply (CIPS) Ethics Course
In 2024, 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 scale of our Star Pubs business, a number of practical steps were taken through 2024 to raise awareness of Modern Slavery principles and assess related risks.
With full backing from the Star Pubs Leadership team, a cross-functional project group was formed, including representatives from Safety & Operational Compliance, Security, Corporate Affairs and Legal and Compliance.

Following a review of the onboarding training and procedures across the Leased & Tenanted (L&T) and Just add Talent (JAT) pubs - combined with no reported Modern Slavery concerns raised by our Business Development Managers - this risk of Modern Slavery issues was assessed as low.

Nonetheless, this project team developed a tailored action plan that extends to the end of 2025, and which remains on track. Key actions include enhancing Modern Slavery awareness among all Star Pubs colleagues and as part of an established audit process, Business Development Managers require to confirm that each pub has been assessed for any potential Modern Slavery issues. Outputs from these audits will feed into our annual risk assessment process.

Orchard Site Visits
As part of our Sustainability Audits, a team of dedicated resources visit the orchards that supply our cider mill in Ledbury with locally-produced apples.
Each harvest season, HEINEKEN UK 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. 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. HEINEKEN UK also founded the Sustainable Cider Apples Scheme to promote responsible supply chains.

Given the above governance arrangements, together with the fact that all apple crops are machine harvested, we believe that the risk of Modern Slavery issues across our orchard supply chain is low.

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.