Excerpt taken from pg. 7 and pg. 8, clearly shows that human rights risks include forced labor, so we have considered this.

pg. 7

“We recognize that inequalities and poverty are often underlying drivers of other systemic human rights risks such as forced and child labor.”

pg. 8

“As part of our ongoing due diligence activities, the HRWG undertakes continuous assessments of our human rights risks and improvements of our due diligence systems, with support of the specialized human rights consultancy twentyfifty ltd. Our ongoing risk assessment is based on social audit results, grievance mechanism data, interviews with internal stakeholders in key roles and geographies, and an analysis of external studies. It confirms the need to focus on salient risks that are shared across the food industry such as child labor, forced labor, living wage/income, health and safety, freedom of association and collective bargaining, land rights, water and sanitation, and women’s rights.”

pg. 9

“In 2021, we started a new auditing cycle using Sedex’s Radar risk assessment tool to prioritize suppliers based on human rights related risk.”

Pg. 13

“In 2016, we partnered with World Wildlife Fund (WWF) to assess the long-term environmental and social sustainability risks of our raw materials supply chain. The prioritized risk assessment run by WWF examined raw materials by source country based on publicly available, secondary data, covering our largest raw materials volume and spend. The assessment confirmed cocoa and palm oil as top priorities from a human rights risk perspective.”

pg. 14

“When a new community joins the program, our NGO partners conduct a thorough participatory needs assessment on focus areas including labor risks such as forced and child labor.”