Modern Slavery and Human Trafficking Statement
for Financial Year ended 31 December 2022 for Herbalife (U.K.) Limited and its subsidiary, Herbalife Europe Limited (together “Herbalife”)
Herbalife recognize that modern slavery and human trafficking are significant problems in our global society that must be tackled by vigilance and continuous efforts. We are committed to conducting our business ethically and with integrity. That means creating and promoting a culture of honesty, integrity and ethical behavior where there is no tolerance of practices like modern slavery and human trafficking, as well as having in place processes to quickly identify and eradicate any such practices within our business and our supply chains. The starting point of all this is our culture, embodied in our policies and processes. Herbalife has a Code of Conduct (“the Code”). That Code is the roadmap for Herbalife’s purpose-driven mission to improve people’s lives. To fulfil this mission, we must work together to do the right thing and lead with personal and professional integrity. At the heart of this Code is our central value “We always Do What’s Right.” All Herbalife employees are required to comply with the Code and to undertake annual training on the Code. Under the Code, Herbalife commits to “Work Properly in the Global Marketplace.” A core facet of this is the respect for human rights of others. We believe every person, everywhere, has the right to live and work with freedom and dignity. The work we do at Herbalife should positively impact their lives, preserve their basic human rights and comply with all applicable laws to prevent abuse. Under the Code, all employees are required to follow the laws carefully that apply to protect human rights. In particular they must focus on making sure all people have: safe work conditions, fair pay, legal and reasonable work hours, a choice of whether or not to work and freedom of association or collective bargaining. The Code specifically prohibits: child labour, forced labour, and human trafficking. Herbalife extends the requirement to comply with the Code to its suppliers, who are required to comply either with our Code, or an equivalent code of their own. We do not work with suppliers who do not share our values which includes our commitment to protecting human rights. Currently, we screen all new suppliers across all regions of our business using a due diligence solution application, which flags ethical concerns including connections with slavery and human trafficking. We also continuously screen over 20,000 suppliers daily to monitor for new red flags. In 2021, Herbalife launched an additional code of conduct specifically for its Suppliers: the Supplier Code of Conduct (“the Supplier Code”). This Supplier Code contains specific requirements for suppliers in various areas including: human rights, anti-bribery, child labour, forced labour, human trafficking and slave labour. It follows many of the expectations outlined in international conventions such as the United Nations Guiding Principles on Business and Human Rights, the United Nations Global Compact’s Ten Principles, the International Labour Organization’s standards and the OECD Guidelines for Multinational Enterprises and includes a requirement that our suppliers will not engage in human trafficking or modern slavery and will implement procedures to ensure compliance. The Supplier Code must be agreed to by all our direct sourcing suppliers. Herbalife’s direct sourcing suppliers account for the largest percentage of our supply contractors within our supply chain and are our most high risk suppliers for human trafficking and slavery. In addition, the Supplier Code must be adhered to by many of our highest spend indirect suppliers. In 2022, we took a step further and introduced a specific policy for our employees on Human Rights which aims to further reinforce and clearly state our commitment to treating people with dignity and respect as well as providing and supporting all human rights, including labour rights. It is overseen at the highest level within the Herbalife organisation. Our Human Rights Policy conforms to: the United Nations Guiding Principles on Business and Human Right, the United Nations Universal Declaration of Human Rights, the International Labor Organization’s 1998 Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises.
In relation to our employees, those working in our Human Resources team are vigilant in their recruitment processes to ensure potential employees are voluntarily applying for roles and there are no signs of exploitation. Employees have access on our intranet to our policies against discrimination, harassment and retaliation, which detail complaint and grievance procedures and how employees can inform HR personnel of any human rights violations. Employees are free to leave upon giving notice without penalty and to join unions where they wish to. Salaries are regularly reviewed to ensure fair pay in accordance with market standards. In line with Herbalife’s Code and annual ethics training, all employees are made aware that they are personally responsible for reporting possible misconduct, including human rights violations, such as those in relation to modern slavery, within our business or within our supply chain. Failure to report a human rights abuse is itself a breach of the Code. All employees are made aware in trainings on the processes to raise ethical concerns, which includes a confidential toll-free Integrity hotline where violations can be reported. Any complaints or violations that are raised by employees are logged via the global investigation portal and then investigated thoroughly. The channel is also available to third parties who may also report issues through the hotline. Additionally, we have Ethics & Compliance Office ambassadors located in various office locations in EMEA: any reports of slavery or human rights violations noticed by them would be urgently investigated. Herbalife continues to look for ways to further develop processes and systems to reduce the possibility of any involvement in modern slavery or human trafficking by those in our supply chain and in our business.
This statement was approved by the Board of Directors on ___June 2023.