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.